IndianPointTranscript of Oct 16 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 Tuesday, October 16, 2012 9:00 a.m.
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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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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 On Behalf of the Nuclear Regulatory
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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 (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 New York:

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

Exhibits: NRCR40001 NRC Staff 000165 NRC Staff 000166 Revised Staff Exhibit List 000001 Mark Recd 1474 1613 1613 1613 1613 1613 WITNESSES Robert M. Aleksick Nelson Azevedo Alan Cox Allen Hiser Joram Hopenfield Jeffrey Horowitz Ian D. Mew Matthew Yoder TABLE OF CONTENTS
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JUDGE McDADE: come to order. P R O C E E D I N G S 9:00 A.M. Okay, the hearing will
There's a couple of preliminary
matters that we wanted to take up first of all with regard to the proposed settlement agreement. Is Cortlandt present this morning? Apparently not. Have the parties heard from Cortlandt and have they expressed an opinion with regard to the viability of the settlement agreement? MR. BESSETTE: Applicant, Your Honor. Paul Bessette for the
We contacted Town of
Cortlandt attorney representatives and we did hear from them yesterday. We forwarded them the proposed
settlement and the question posed by the Board and they said that the Town of Cortlandt does not take a position with the proposed settlement, with respect to the proposed settlement. JUDGE McDADE: Okay, one of the other
things that we had asked yesterday is with regard to the REMP, how the settlement agreement would fit into that from the standpoint of the NRC staff. Mr. Turk? MR. TURK: Yes, thank you, Your Honor.
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I did speak with our regional inspector who is involved very much with the groundwater monitoring and other aspects of releases from the plant. This
was Mr. James Noggle, who was listed as one of our witnesses on the spent fuel pool leak contention. I am informed that the NRC staff inspects against the Radiological Environmental Monitoring Program every two years. They do go out
and during that inspection observe whatever sampling is being done at the time of the inspection. Sometimes that may involve fish tissue sampling, sometimes it does not. It depends what's going on
at the plant at that particular time. I understand that there are two aspects of the agreement between Entergy and Riverkeeper and Clearwater. One aspect is that an additional fish
tissue sampling location will be established either in or in the vicinity of Haverstraw Bay. That
additional tissue sampling location would be put into the REMP. So the staff, during its
inspections, will be able to observe whether or not that fish tissue sampling is going on. And in fact, every year, the REMP must be updated and the results of the tissue sampling program are reported to the NRC pursuant to the
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Turk. Is that acceptable to Riverkeeper? MR. MUSEGAAS: JUDGE McDADE: MS. GREENE: JUDGE McDADE: Yes, Your Honor, it is. And to Clearwater? Yes, Your Honor. Okay, one question and it In the REMP. So even if the staff was not present during
tissue sampling, they will receive reports annually of the tissue sampling that's being conducted. So
the staff will be aware and will be able to inspect against the REMP and that additional condition. JUDGE McDADE: Okay, thank you, Mr.
came up from what Mr. Turk just said.
settlement agreement, it talks about monitoring at Haverstraw Bay or the vicinity. Can you explain to
me what "or the vicinity" means in that context? MR. BESSETTE: Paul Bessette. Yes, Your Honor. This is
It's my understanding that there are
certain requirements for where fish samples cannot be taken if the water is too warm. And my
understanding is that Haverstraw Bay is fairly shallow. So under the unusual circumstance where
we're trying to take a fish sample, and the water is too warm, per the permit requirement and the REMP, we would have to go slightly outside the area for
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deeper water where it's cooler. So it is not -- we It's only
fully intend to sample in Haverstraw Bay.
if the temperature permit requirements require us to go outside. JUDGE McDADE: And Riverkeeper, that's
consistent with your understanding and acceptable to you? MR. MUSEGAAS: Yes, it is. That
depiction or description of Haverstraw Bay and the environment and that part of the river is fairly accurate. We would assume Entergy would seek a
sampling location either slightly north or slightly south where the channel is deeper and you would be able to collect the fish samples we would need, so yes. JUDGE McDADE: Okay, and that's
consistent with your understanding for Clearwater, Ms. Greene? MS. GREENE: JUDGE McDADE: MR. TURK: Yes, it is, Your Honor. Okay, thank you. I
Your Honor, I'm sorry. Sherwin Turk
need to make one more statement. again.
One more statement so there's no The staff does not require that a
misunderstanding.
sampling location be established at Haverstraw Bay,
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so following the inclusion of that tissue sampling location in the REMP, Entergy would be able to change it without the NRC staff taking enforcement action. What the staff will require is that every pathway that could be hazardous to man be sampled. So in this instance, Entergy is already
sampling fish tissues near the outfall from the effluent outfall from the plant. additional sampling location. So what the NRC staff will be concerned about is to make sure that the ingestion pathway is sampled so that if there's any hazard to man, the NRC will be aware of it. But we will not require This would be an
any specific location at Haverstraw Bay be included in the program. JUDGE McDADE: I understand there is an
REMP in place and that will continue to be in place. This is an additional commitment on the part of Entergy made to Clearwater and Riverkeeper in proposed settlement of this contention. understood in that light. One other thing I would ask about this, we had had a similar discussion back in January, back in December. There was a settlement motion And it's
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Honor. (Pause.) No, Your Honor, we have no objection to that added language. JUDGE McDADE: Judge Kennedy, Judge with regard to a New York contention, and specifically, in the settlement agreement on New York-24. At the end of that agreement, there was
language on the representation of Entergy that any attempt to enforce the terms of the settlement agreement or this order in any Court will not be subject to objection by Entergy or any successor interest to Entergy due to a lack of subject matter jurisdiction. That was part of the agreement with
regard to the settlement on New York-24. Would Entergy have any objection to that language being added to the settlement agreement in this instance? MR. BESSETTE: Just one moment, Your
Wardwell, do you have any other questions about a settlement agreement? JUDGE KENNEDY: JUDGE McDADE: I do not. Are there any other
matters with regard to the settlement agreement that any of the parties think that we should be aware of?
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settlement. Ms. Greene? MS. GREENE: Yes, Your Honor. Mr. Turk
just made reference to the measurement at the outfall. And I just would like to go on the record
as saying the measurement at the outfall is not the same as the measurement at Haverstraw Bay. One of Clearwater's concerns and we have settled and we've agreed to the settlement, but one of our concerns is that Haverstraw Bay is a potential drinking water source. It does not seem
to us that the oversight that is in place and I reread all of the documents last night. And it just
seems to me that that is seriously missing inasmuch as several other drinking water sites are mentioned as being at higher elevations. And what occurs to me is that other than this testing, the responsibility then becomes the responsibility of the United Water of New York to assure that they test and protect the people of Rockland County. But it does seem to us that that
should, that that investigation should have been part of this process. Nonetheless, we agree with the Just given that the outfall was just
cited as a test for drinking water, I think we -- I
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felt compelled to make that correction. JUDGE McDADE: Okay, thank you. And I
understand that in that context and again, it's our understanding from the settlement agreement that as part of the settlement Entergy is agreeing to this additional condition. that could be enforced. First of all, through the monitoring of the REMP by the NRC and in the event that either of the parties believe that Entergy for some reason or a successor interest was not living up to the terms of its agreement, that they would not have any objection to subject matter jurisdiction based on subject matter jurisdiction in the event you were to seek to enforce it. MS. GREENE: JUDGE McDADE: Thank you. What we're going to do, And we've talked about how
we're not going to announce right now from the bench what we're going to do with regard to the settlement agreement. We understand that the parties are
concerned to get to this quickly because you want to know what to do with the witnesses who are going to be coming on that particular contention. What we would propose to do is to discuss it among ourselves. After the lunch break,
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Honor? Thank you. JUDGE McDADE: MS. GREENE: JUDGE McDADE: MR. TURK: Excuse me. Clearwater? Applicant. we will announce our decision with regard to the settlement agreement. We're required to issue on
any settlement agreement a written order, but we would announce it orally after lunch and that we would get the written order out as quickly as possible thereafter. Anything else with regard to the settlement agreement? MR. BESSETTE: Paul Bessette for the
Nothing here, Your Honor. JUDGE McDADE: MR. MUSEGAAS: Riverkeeper? Nothing from Riverkeeper.
We're okay, Your Honor. For the NRC staff?
Nothing further, Your Honor. Okay, yesterday, there
JUDGE McDADE:
was a discussion of additional testimony or a revised testimony with regard to New York State-5. What is the status with regard to that? MS. DEAN: Could you clarify, Your
We discussed yesterday the motion, the
redaction that was incorrect? JUDGE McDADE: Yes. And I take it we're
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not going to receive an additional exhibit. just going to go with what was done orally. correct? MS. DEAN: I'm sorry, Your Honor. I We're Is that
understood that you did not want me to file a corrected version, but I'm happy to if you'd like. It might make -JUDGE McDADE: No, it was totally up to
the State of New York whether they wished to file it or not. I realize we're all here in the hearing and
the idea is not to create more administrative issues than necessary. MS. DEAN: We do intend to file a
corrected version later today, Your Honor. JUDGE McDADE: Okay. One of the things
that I should mention with regard to that, we are in all probability going to be receiving additional exhibits and changes in testimony. There are other
contentions that we have dealt with that we're not going to deal with during the course of this particular hearing. We just won't get to and some
of them that we had asked about doing in December and there were witness availability issues then. If we do have any changes in the future, what we need to do is to have a motion to strike
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what's already been received and a motion to replace it with the new version. What I'm talking about is
just a very brief, just a one page simply explaining what you're doing. The other is last night we talked about the new NRC 000165 and 000166. Are there any
objections to the admissions of those two exhibits from any party? Entergy? MR. BESSETTE: Paul Bessette for the
Applicant, no, Your Honor, no objections. JUDGE McDADE: MR. SIPOS: New York? We
Your Honor, John Sipos. Ms.
had some difficulty accessing the material.
Mizuno has handed us paper copies this morning. With the Court's indulgence, we would request a little extra time to review it. I would imagine we
could resolve that by the end of the day. JUDGE McDADE: Okay, why don't we take
this up again after lunch with regard to those two exhibits. Also with that the NRC submitted it's
revised exhibit list which would be Revision 4 on the exhibit list. And in the event those exhibits
are accepted, then we would also accept NRC 4, Revision 4 and have that bound into the transcript
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rather than the transcript having Revision 3. (Whereupon, the above-referred to document was marked as NRCR40001 for identification.) Are there any other preliminary matters that we should take up before we proceed to the testimony? Mr. Sipos? MR. SIPOS: the State of New York. Your Honor, John Sipos for Just following up on your
first point of a few minutes ago, if there is revised testimony or things of that nature, with the motion to strike, how would you like the new document that is being submitted designated following the R protocol? Would it be the next
number after the R or would you like us to use the same number, assuming it has already been revised? JUDGE McDADE: If, for example, New
York-2 were revised, it would just simply be with the R and 2. And as I sit here right now I don't
know whether or not New York-2 has already been revised, but we have the revision number and then the number of the exhibit later on. MR. SIPOS: And so the motion to strike
would -- for example, in New York-5, I believe it's
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York? Entergy? MR. BESSETTE: JUDGE McDADE: Nothing, Your Honor. Nothing further from New staff. JUDGE McDADE: First of all, from already an R in front of it. Do you wish it to be
another number after the R or are we replacing the one in place through the motion to strike? JUDGE McDADE: Yes. And I'm sorry that
that was somewhat confusing, but it would be New York R-3 meaning revision 3 and then we have a certain number of zeros and then we have 5 meaning that's the exhibit number. So just like we have
with the -- and we've had a number of revisions with regard to the exhibit lists, and the exhibit list is usually exhibit 1, so it would be New York R-17, then 0001. And if you revise the exhibit list
again, it would be R-180001. MR. SIPOS: understand, Your Honor. JUDGE McDADE: haven't misled you. Any other preliminaries from Entergy? MR. ROTH: David Roth, counsel for the Very good. Thank you. Okay, I hope I do and I I think I
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you. MS. GREENE: Otherwise, nothing else, you. JUDGE McDADE: from left to right here. From the NRC staff? MR. ROTH: David Roth from NRC staff. I We're just sort of moving MR. SIPOS: Nothing further. JUDGE McDADE: MR. MUSEGAAS: Riverkeeper? Nothing further. Thank Correct, Your Honor.
think you just answered the question already on how to replace the testimony, but we've identified the NRC's staff testimony in FAC is off in its numbering for NRC exhibits. For instance, NRC, it lists
Exhibit 000101 when it should list Exhibit 000123. And so we need to file a correction on that. JUDGE McDADE: Okay, thank you.
Anything further from Clearwater before we get started with the testimony? MS. GREENE: Just an update, Your Honor,
that I did speak with the person I thought might be an excellent translator and that person is not available. So we'll keep looking as I expect --] JUDGE McDADE: As will we, but thank
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Your Honor. JUDGE McDADE: ready, hopefully. Judge Kennedy? JUDGE KENNEDY: JUDGE McDADE: JUDGE KENNEDY: I'm ready. Go for it. This is Judge Kennedy. All the witnesses are
I'd like to take us back through some of the testimony yesterday. In the petition and in the
admitted contention, the inspection frequency, inspection method, and the repair/replacement criteria was called out as specific issues with the Aging Management Program. In other words, they were And
not identified in the Aging Management Program. we heard some testimony yesterday that shed some
light on it and I'd like to go back to that and make sure I understand it clearly. So I'd like to start with Mr. Cox and I think we were going through NSAC-202. If it's I
useful to put it up, we'll have that put up. think it was Riverkeeper 000012.
And I guess what
I'd like to do, if that's the appropriate exhibit to talk about where the inspection frequency criteria, inspection method, and repair/replacement criteria process is described.
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I recognize that specific numbers weren't identified yesterday as much as a way to get to that inspection frequency. exhibit? MR. COX: Yes, Your Honor, it is. This Is this the correct
is Alan Cox for the Applicant.
Specifically, we
were looking at Section 4.7.3 on page 4-25 of that exhibit. JUDGE KENNEDY: What particular aspect
does this address then, Mr. Cox? MR. COX: This is -- the first sentence
of this section is the recommendation that the remaining service life be determined for each component. And again, that's done every inspection We evaluate the
cycle, every refueling outage. remaining service life.
And in doing that, that
defines what components require inspection and when. We look at how much remaining service it is, compare that to the next scheduled inspection, and then we either say that's acceptable or we can extend it to a later inspection or we have to do a repair/replacement at that point. JUDGE KENNEDY: Then this is based on
the output of the CHECWORKS program? MR. COX: Yes, Your Honor, it is.
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Applicant. JUDGE KENNEDY: And this is the process
that would be used to establish the inspection frequency for all locations? MR. COX: all locations. This process would be used for
Again, you're not necessarily
establishing a frequency, but you're establishing the necessary date for the next inspection. JUDGE KENNEDY: MR. MEW: Understand.
Your Honor, Ian Mew for the
The service life of a component is done It's done in accordance
independently of CHECWORKS.
with Entergy procedures determining when a component needs to be repaired or replaced or it has sufficient life to last through more than one cycle. JUDGE KENNEDY: So what part of this
process then does CHECWORKS play a role in in terms of this Section 4.7.3, if any? MR. MEW: CHECWORKS only tells us what
the wear rates are and ranks it for us so we can do -- perform an inspection scope. Once we get
measured data that's done in accordance with our procedures. JUDGE WARDWELL: And by that -- let me Is the
make sure I understand you correctly.
service life based on the wear rates from measured
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values or from CHECWORKS predictions? MR. MEW: From measured values. And likewise, are not
JUDGE WARDWELL:
most of these calculations -- well that's what, 4.7.3 NSAC-202 is at service life, so that's based on measured values not CHECWORKS, is that correct? MR. MEW: That is correct. I see heads nodding
JUDGE WARDWELL: from other witnesses.
No one objects to that, that
representation of Mr. Mew? JUDGE McDADE: Apparently not, but let Your testimony
me just make sure I understand it.
is that CHECWORKS is used to prioritize inspections, so based on CHECWORKS you will identify what areas you should inspect, but once the inspections are done, then your decisions with regard to remaining service life are based exclusively on the actually observed data? MR. MEW: That is correct. Are all the location's
JUDGE WARDWELL:
selections for inspections based on CHECWORKS or are there other mechanisms to do that? MR. MEW: of the FAC Program. There are different elements One of the elements is the Okay? There are operating
predictive methodology.
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experience. There is engineering judgment. And
there is the non-modeled portion of piping in our program. JUDGE McDADE: What would enter into
your prioritizing a particular area for inspection inconsistent with the CHECWORKS priorities? MR. MEW: We look at the rankings and
based on the negative time to Tcrits we would look at those and determine whether or not to be included in the inspection scope. If we don't have a valid
reason as to whether or not they should be inspected, we include them in the scope. JUDGE McDADE: do you mean you? MR. MEW: That's correct. And your position again Now and when you say "we"
JUDGE McDADE:
at Indian Point, you are in charge of the FAC Program? MR. MEW: That is correct. If I might offer a This is Rob Aleksick for
MR. ALEKSICK: clarification, Your Honor? the Applicant.
I would just like to point Your Honors to Answer 77 in our prefiled testimony which discusses this issue in some detail. Specifically,
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it provides figures illustrating for each inspection set of components that is done for each refueling outage, what percentage of them come from CHECWORKS, what percentage of them come from re-inspections, operating experience, and so forth. JUDGE McDADE: JUDGE KENNEDY: Thank you. Could we continue on and
talk about the repair/replacement criteria, if that's possible through this exhibit? Cox or Mr. Mew. MR. COX: The repair/replacement is Either Mr.
covered in the next section on this exhibit under Repair and Replacing Components. I'll let Mr.
Azevedo or Mr. Mew to discuss that further. MR. AZEVEDO: Yes, Your Honor, this is The criteria that were
Nelson Azevedo for Entergy.
used for repair and replacements is discussed in our Q&A 73 and 78. And also comes from NSAC-202L,
Section 4.8 and also from our EN-DC-315 Section 5.13. And from a high-level standpoint, what that requires is that it requires us to calculate the critical thickness that we need to ensure that we don't exceed the code stress allowables and ensure that we schedule an inspection or replacement
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or repair prior to reaching that point. JUDGE KENNEDY: the EN-DC-315 procedure. You now introduced again I guess what I'm looking
for the link in through GALL, through the Aging Management Program is this document NSAC-202. What
is different between what's in NSAC-202 and what would be provided in EN-DC-315? MR. AZEVEDO: There really is nothing.
EN-DC-315 implements NSAC-202L. JUDGE KENNEDY: So would NSAC-202 be the
guidance document that is implemented by 315? MR. AZEVEDO: JUDGE KENNEDY: about inspection methods. Yes, that's correct. Just one last question Does NSAC speak to the
recommended inspection methods for flow-accelerated corrosion or min. wall thickness? MR. AZEVEDO: Yes, it does, Your Honor. It's on page 4-11.
That's, I believe, Section 4.5. JUDGE KENNEDY: JUDGE McDADE:
All right, thank you. Before you move forward,
if I could just follow up on one thing that was mentioned by Mr. Aleksick, if you could clarify for me. You had made reference to the earlier testimony And it talks about a percentage
that was presented.
of overall inspections that are based on CHECWORKS,
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but it differentiates between new inspections and repeat inspections. So what percentage of the new inspections, put aside the total number of inspections, just of the new inspections are based on -- are informed by the CHECWORKS priorities? MR. ALEKSICK: cycle to cycle. It varies a bit from
But on average, it's around one
quarter of the total inspection scope would be newly identified, previously uninspected components that come from CHECWORKS. JUDGE McDADE: Right, and that's what it
indicates in the testimony, but that's of new inspections, areas that haven't been inspected before, 25 percent. My question is of those new areas, are they all identified through CHECWORKS or a percentage of the new as opposed to the reinspections done through other mechanisms, engineering judgment, experience at other facilities, that's the nature of the question. Because the first inspection identifying an area to be inspected, that's what I'm curious about. they all informed by CHECWORKS? MR. MEW: Your Honor, Ian Mew for the Are
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Applicant. I can answer that question. If you will
turn to Exhibit 000057 which is the 2R19 scope for Indian Point 2, there is -- you will see in there that typically for that outage you will see CHECWORKS has 26 percent of the inspections, re-inspections were 46 percent, OE was 7 percent, and components from the SMN model was 21 percent. Similarly, if you look at Exhibit 61, 3R14 inspection in 2007, you will see CHECWORKS at 36 percent, re-inspections at 31 percent, SPU contribution was 31 percent -JUDGE WARDWELL: MR. MEW: What's SPU?
Stress power uprate. Okay, Mr. Mew, the thing
JUDGE McDADE:
that I'm not clear on, based on the exhibits and based on the testimony, is a distinction between reinspections and initial inspections. And I
understand that re-inspections are based on a number of criteria. You've looked at it. You actually
have data on that particular location. The exhibits, the testimony indicates that -- I think it was about 24 percent, 26 percent are based on CHECWORKS that are new inspections. That's 26 percent of all of the inspections. My
question is of the new inspections, that 26 percent,
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are they all identified as locations to be inspected through CHECWORKS or is there a percentage of that 26 percent, the new inspections that is identified through some other mechanism? And if so, what is
the percentage and what is the mechanism? MR. ALEKSICK: This is Rob Aleksick.
Roughly speaking, perhaps half of the inspected components from each inspection set during an outage are re-inspections. So if we set that aside and we
just look at the new inspections, roughly half of those come from CHECWORKS, sometimes more, sometimes less, but that's the general order of magnitude. And then roughly half -- the other half come from other sources including operating experience, engineering judgment, and the susceptible non-modeled rankings. Those are
components not modeled in CHECWORKS, but that may be experiencing FAC. JUDGE McDADE: Okay, and when you're
saying in there and I believe the testimony was 21 percent come from susceptible non-modeled components, can you describe for me what a nonmodeled component is and why it's non-modeled? MR. ALEKSICK: Certainly, Your Honor.
CHECWORKS was designed originally, as we discussed
Page 1487 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
yesterday, to address the high energy, large bore piping that was -- well was originally identified in the Generic Letter. As FAC programs developed over
the decades, greater awareness or greater focus was placed on additional plant piping that might not be able to be modeled for one reason or another. By far, the largest category of that piping is small bore piping. In fact, yesterday, in
Dr. Hopenfeld's presentation, he alluded to one of those components. And if you look at the figure, it
shows that it was a three-quarter inch pipe and for small bore lines like that instead of being buttwelded, they're socket-welded. And the nature of
that joining technique makes it difficult to model and predict the extent or occurrence of FAC in those lines. And so for small bore lines, we have a different ranking methodology. It's documented in We
Entergy Exhibits 000048 and 000049, I believe.
can go into as much detail as Your Honor would like, but at a high level, essentially what we do is we take these small bore lines and apply a more qualitative ranking process to them. I'd also like to point out that in addition to the small bore lines, there are a few,
Page 1488 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
small percentage, but a few large bore lines in that category, for example, a balancing line that has no well-defined flow rates, lines that are very infrequently operated or that are operated in a manner of changing operating conditions, maybe a start-up line where the flow rates and pressures change while that line is in service. And so lines
like that are covered under the FAC Program and are inspected and are evaluated in the same manner once we have the inspection data, but are not modeled. And I would point Your Honors to Question 68 in our prefiled testimony for additional detail on this topic. JUDGE McDADE: And the exhibit you just
referenced 000048 and 000049, excuse me, those are the ones we looked at yesterday, 000048 for Unit 2; 000049 for Unit 3? MR. ALEKSICK: I think we may have
looked at -- there are a large number of exhibits, so I'm not -JUDGE McDADE: susceptibility evaluation. MR. ALEKSICK: I was mistaken. Those It's the system
are the wrong exhibit numbers. my memory.
I shouldn't rely on
If you give me one moment, I'll give you
Page 1489 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
Kennedy? JUDGE KENNEDY: Just a -- if we take -the correct exhibit number. (Pause.) Those were exhibits -- Entergy Exhibits 000052 and 000053, Your Honor. JUDGE McDADE: Okay, thank you. Judge
we've just walked through the inspection frequency process, the repair/replacement criteria discussion and the inspection methods, all based in NSAC-202. If Entergy chose to make a change to those processes that are currently founded on NSAC-202, how would they go about doing that? used? MR. AZEVEDO: Entergy again. This is Nelson Azevedo for What process would be
The process that we would use would
be the 10 CFR 50.59 process where there's a review process and the outcome of that process tells us whether we can make the change and just document and have the documentation available for NRC inspection or whether we need to get NRC approval prior to implementing the change. process. JUDGE KENNEDY: So if I understand what So that's the 50.59
you said, if the answer goes one way, you would file
Page 1490 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
Hiser? Applicant. a license amendment. If the answer goes in another
direction, you could make the change and then file a notice with the Agency that you have made such a change? And how is that filed? MR. AZEVEDO: We would make the change. That will be
We'll keep the documentation on site.
available for NRC review and I believe at the end of the year, once a year, we update the NRC of any changes that are made, but I'm not positive of that. JUDGE KENNEDY: answer to that question? From Entergy's side? MR. COX: This is Alan Cox with Does anyone know the
We do once a year as part of FSAR
update, I believe, we provide records of 50.59 reviews that were done on site associated with procedures changes. JUDGE KENNEDY: Thank you. Maybe Dr.
Site lines are tough. You've just heard Entergy walk us
through using some specific examples of attributes of GALL that I believe Riverkeeper has some issues with. I guess I'd like to get your take on their
description and their process for control. DR. HISER: This is Alan Hiser with NRC.
Page 1491 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 think in general, we would agree with the characterization by Entergy and in particular, the use of 50.59 or the 50.90 license amendment process, if they were to make changes. JUDGE KENNEDY: It seems in listening to
Entergy's testimony that the inclusion of 202, I guess as a check on my understanding, the inclusion of 202 in the program description and I guess in the UFSAR update, leads to a process that the important characteristics that they've identified would be controlled and identified to the Agency if a change is made. Do you see any flaws in that
understanding? DR. HISER: No, I think you've The use of the NSAC
accurately characterized it.
guidance document is an essential part of the program. JUDGE KENNEDY: I think yesterday we
walked down this path and what we've uncovered is that by the reference, as I understand it, the reference to NSAC-202 through GALL and then brought in to the description of the Aging Management Program is a linkage to the additional details for the Flow-Accelerated Corrosion Program. be your characterization? Would that
Page 1492 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. HISER: yes, I would agree. JUDGE KENNEDY: Entergy, again, I think I think that's accurate,
that's been your view, but would you concur with that assessment? MR. COX: Yes, Your Honor. This is Alan
Cox with Applicant and I do concur with that. JUDGE KENNEDY: And I think it's only
fair to ask Dr. Hopenfeld, these are three specific issues that I think the petition has raised and were admitted as part of the contention and you've just heard Entergy provide an explanation of where that level of detail, where that information is provided. I guess I'd like to get your perspective on this discussion that we've had over the ensuing two days. DR. HOPENFELD: I just want to make sure I just want to
I don't wander off the time here.
make -- because I really don't know where to start because I have so many issues here. However, I'll just -- the last that was mentioned and I'm sure, Your Honor, that you understand that 50.59 is not a prescriptive document. There's a lot of leeway. There's a lot
of judgment in there.
The bottom line in a 50.59
and I read it very carefully is is there an effect
Page 1493 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 safety or whether the changes you make, whether it's a big change or small change? effect on safety? Is there an You
How can you determine that?
do some risk analysis. Now in this particular case, the first step is to make sure that you inspect the component before you reach the critical thickness. have seen those equations. here. And we
You can derive it right It's
You don't need the document for that.
just an obvious thing. critical thickness.
You don't want to exceed the
If, if, you know which
component and if you know how fast it wears and because of the local phenomenon and that's why we went to all this mechanism thing, because of the local phenomenon they don't know -- all three of them. Now if you assume, if the assumption is correct, then the rate is linear and it could be, as I said, a straight pipe or even if you use some averages, it's not too bad. But because of the
locality of this, you cannot determine whether it's one line or two lines or two identical components whether they're going to behave the same. the crux of the problem. JUDGE KENNEDY: Let's -- you've said a That's
Page 1494 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
lot. DR. HOPENFELD: JUDGE KENNEDY: I'm sorry? You've provided a lot of
information and I think that if I understand the way the rest of the day will proceed, we're going to get to a lot of the specific issues that you've raised. What I'd like to focus on here, what we've been pursuing over the latter part of yesterday and through the beginning of this morning, is whether there's a documented process and I understand you may disagree with some of the assessments that are performed that provide input to that process. But do you or don't you agree that
Entergy has defined a process for these three specific elements of GALL and that that process has a documented basis for controlling the changes to those processes? DR. HOPENFELD: general framework. correct. I agree there's a
The verbiage is generally
The question is the implementation of it. Look, I don't know after looking at all
of this how many components they inspect.
You've
got thousands of components, do they inspect two or three or five, what are we talking about -- like it was a known.
Page 1495 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
get to that. JUDGE KENNEDY: I think we're going to
I think that -- if we just again for
argument sake let's take the inspection frequency discussion that we just heard. I believe they
pointed us to a document that they've committed to and that if they were to make changes to that process, it would go through either a 50.59 process or ultimately if it fails the 50.59 test, a 50.90 process. So it seems to me and I'm really trying to make sure I understand your perspective that the process has been identified. committed to. It's documented and
And changes to that process will see
the light of day driven by documentation provided by Entergy to the Agency. DR. HOPENFELD: JUDGE KENNEDY: understanding? DR. HOPENFELD: JUDGE KENNEDY: JUDGE McDADE: Yes. Okay. Dr. Hopenfeld, if I I have no problem. Is that your
could, just to make sure I understand your position, yesterday, we were led to Exhibit 000038 which was the EN-DC-315 and we were led to Exhibits 000048 and 000049 which were the System Susceptibility
Page 1496 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: for right now. Well, forget the numbers Evaluation Reports for Units 2 and Units 3. DR. HOPENFELD: I can't remember which
But is it accurate to say that you
would concede that there is documentation provided by Entergy, but it is your view that the documentation is so vague that it leaves so much to individual judgment that it does not guarantee that there is a reasonable assurance that the FAC will be managed during the period of extended operation? It's not the lack of documentation. It's the lack
of specificity in the documentation that you take issue with? DR. HOPENFELD: Yes, absolutely correct.
I would just like to add one point for clarification, if I may. And that is from the
outside and I'm not familiar with the procedures of Entergy. From the outside you look at it, it looks
like a contractor put all that together, the people that did the ultrasonics or whoever does the CHECWORKS summary, filed that thing, and it's somewhere there. I don't see -- some of the stuff
there it's so out and I don't see any comments on that.
Page 1497 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
stands -DR. HOPENFELD: JUDGE WARDWELL: Yes, yes, yes. You are satisfied with Okay, go ahead. JUDGE WARDWELL: Can I ask you this?
Probably stepping back a bit, but getting back to our discussion of what's in an AMP, do you have any criticisms of their AMP as it stands, not again in regards to some of the issues you're raising, but just as an AMP, as presented in Appendix B, do you have any criticisms of that? DR. HOPENFELD: question as close as I can. aspects to it. I'll try to answer your What I see in AMP three
One, you must inspect the component One, one
before it reaches critical thickness. requirement. JUDGE WARDWELL:
And does it -- let me
just ask, doesn't the AMP have a procedure for doing that in there? DR. HOPENFELD: It may have a procedure,
but the results don't reflect that because they constantly -JUDGE WARDWELL: But the AMP, as it
that area of the AMP in Appendix B. DR. HOPENFELD:
It says in 1801, you've
got to follow CHECWORKS and if CHECWORKS is working,
Page 1498 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 got it. I wouldn't be here. Number two, you have to assess what happened if you didn't reach that, if for some reason you missed the inspection and the critical thickness of that component has been reached. JUDGE WARDWELL: DR. HOPENFELD: JUDGE WARDWELL: AMP have a mechanism to -DR. HOPENFELD: haven't seen it. no. I don't believe so. I And in that area -That's number two. And that area, does the
Maybe I didn't see it explicitly,
Let me tell you where the area is. JUDGE WARDWELL: So didn't we just have
a discussion of that earlier this morning in regards to getting down to the NSAC-202 presentation of addressing that issue? DR. HOPENFELD: Yes, but I didn't finish
what I was trying to say about what the second element was. May I? JUDGE WARDWELL: DR. HOPENFELD: Yes. I'll go back to that.
The second element is to assess what happens if you didn't reach the critical -- if for some reason missed by inspection, the critical thickness has been reached. What you do there, you have to make you
Page 1499 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
third. third? JUDGE WARDWELL: Yes, go on to your something of a safety assessment. happen? Obviously, if that happened, some components in the service water, who cares? But if What would
it happens somewhere in the blowdown line, it may be very important. risk analysis. Now I'm sure that there's verbiage there if you go to 50.59, it's right there. whole picture, yes. you couldn't find -JUDGE WARDWELL: So you are satisfied So in the So the second thing, some kind of a
There is nothing in there that
that the AMP through its series of threads that we've talked about yesterday will get you to -DR. HOPENFELD: correctly, yes. If you implement it
If, but that's a big if. For now we are assuming We will
JUDGE WARDWELL:
that implementation will take place.
address whether or not that takes place further on -DR. HOPENFELD: Sir, can I finish the
How many of these do you have by the way? DR. HOPENFELD: I'm sorry?
Page 1500 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 have? DR. HOPENFELD: I have only three. JUDGE WARDWELL: How many of these do
Forgetting all these documents and all that, I only have three elements. If I can get those across, I And so the third, I think I
think I've done my job. got the first two.
The third one is very important
is after all this experience to identify the right components you are going to inspect, I've got thousands of components, which one do I inspect. JUDGE WARDWELL: And do they have a
procedure in their AMP as reflected in Appendix B of the license renewal application that tries to achieve that endeavor? DR. HOPENFELD: JUDGE WARDWELL: JUDGE McDADE: Sure. Thank you. If I could, Dr.
Hopenfeld, just and make sure I understand what you're saying. And we heard from Mr. Aleksick and
he was talking about the percentage of new inspections that are based on CHECWORKS, the percentage that are based on something other than CHECWORKS. There's a differentiation between The non-
susceptible and non-susceptible systems.
susceptible systems, small pipes aren't used with
Page 1501 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. For the non-susceptible systems, not involving CHECWORKS, have you identified any reliable mechanism for prioritizing the inspections of those systems within the AMP of Entergy? DR. HOPENFELD: I didn't compare
prepared to get into that kind of detail and I really haven't put sufficient thought into that. realized at some time EPRI was talking about doing some safety analysis about small bore piping, but I don't know what happened on it. whether they're doing it. I don't know I
But I think you've got to
approach it from the safety aspect of it. JUDGE McDADE: Okay, and then going back
to the other, to those that are susceptible, again it's that there's too much reliance on CHECWORKS for the initial identification. DR. HOPENFELD: JUDGE McDADE: Right. And you don't think
CHECWORKS serves that purpose? DR. HOPENFELD: I don't know. I know
the oil industry, there are a lot of small diameter lines. The problem there is there's a lot of local You can't pick up
corrosion, pitting corrosion. with any computer.
Page 1502 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: MR. ALEKSICK: Aleksick for the Applicant. Okay, thank you, Doctor. Your Honor, this is Rob I apologize for
interrupting, but I think it's a point of clarification that is somewhat important. Your Honor referred to susceptible, then non-susceptible components and lines. better term is modeled and non-modeled. I think a They're all
susceptible to FAC and they're all addressed under the FAC Program, but only some of them are modeled and the ones that are susceptible, but not modeled, that's the population of components that we were discussing. I just wanted to make that clear. JUDGE McDADE: Okay, and those are the
ones that you do not use CHECWORKS on. MR. ALEKSICK: JUDGE McDADE: Yes. Okay. Now on the others
that are modeled, when you say modeled, you mean modeled by CHECWORKS? MR. ALEKSICK: JUDGE McDADE: Exactly, yes, Your Honor. Okay, and the -- and for
those that are modelable, I guess is a way of saying it, do you rely exclusively on CHECWORKSs for prioritizing those systems for inspection or do you have a system in addition to CHECWORKS that
Page 1503 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. identifies modeled systems for inspection as sort of for lack of a better phrase check on CHECWORKS? MR. ALEKSICK: For those components that
are modeled in CHECWORKS, I think it's fair to say that CHECWORKS is the primary tool used in identifying and selecting them for inspection. However, it is certainly not the sole tool. There's a fairly detailed process that Mr. Mew goes through when he compiles, selects his inspections and without taking too much of Your Honor's time, I would just say that he considers CHECWORKS' predictions, but he also considers operating experience, uses engineering judgments, and some other factors as well. JUDGE McDADE: Can either you or Mr. Mew
refer us to a particular exhibit that we should study to be able to better understand those other factors that informs your judgment? MR. ALEKSICK: I think Your Honor might
look at Question and Answer 95 in our prefiled testimony for additional information on that. JUDGE McDADE: particular exhibit? MR. COX: This is Alan Cox for the Does that refer to a
There is a section in NSAC-202, an
Page 1504 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
exhibit that we looked at earlier today that talks about selecting components for inspection. JUDGE McDADE: back to EN-DC 315. MR. COX: This is actually the NSAC Okay, now it refers us
document that -- this is the guidance that EN-DC 315 was based on. NSAC-202L. Okay, which is what we
JUDGE McDADE:
talked about yesterday, but in the testimony you're referring to Entergy Exhibit 000038 which is the ENDC 315, correct? MR. COX: Yes, yes, that's correct. And that's where Mr. Mew,
JUDGE McDADE:
you would look to get guidance on how to exercise this judgment with regard to additional testing, identification of susceptible, but modeled systems? MR. MEW: Yes, Your Honor, that would be
one of the areas that I'd look at. JUDGE McDADE: Okay, any other place
that you could direct us to that we should look at so that we could evaluate it? MR. MEW: could point you to -JUDGE McDADE: Okay, we can go and look For engineering judgment, I
at pages 20 through 30 of Exhibit 000038 and we can
Page 1505 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. JUDGE McDADE: JUDGE WARDWELL: Thank you. To make sure I study those. judgment. It's tough to study your engineering
So at this point, is there any other
document that you would specifically like to address us to that you think would be important or helpful to us to better understand the process? MR. MEW: As I was saying, Your Honor,
for engineering judgment I would look into the CHECWORKS as a bay model and look at the negative time to Tcrit and if there's a component immediately downstream of that negative time to Tcrit, in better trying to understand what was happening, usually I try to inspect those components. JUDGE McDADE: Okay, so even though it
hadn't been identified by CHECWORKS, you would look at it because it was downstream from a system that had been identified by CHECWORKS and had been identified based on prior testing as susceptible to flow-accelerated corrosion. MR. MEW: That's essentially correct,
understand now going back again to these numbers of the model versus the non-modeled. Mr. Aleksick, you were saying that for
Page 1506 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
those that are modeled, CHECWORKS is a primary tool. We were saying that 25 percent of all inspections are derived from CHECWORKS. approximately? MR. ALEKSICK: Let me clarify. And this Is that correct,
is Rob Aleksick for the Applicant.
Once a component
is initially inspected, regardless of its origin or the reason for that selection, whether it was CHECWORKS or anything else, it goes into our trending database and the inspection frequency is determined by the discussion we had earlier today. So I think this part of our discussion, if I understand Your Honor correctly, we're focusing on how previously uninspected components are selected. Am I correct in my understanding? JUDGE WARDWELL: Initially, no, that
wasn't my question, but as you clarified it, it is now my question. (Laughter.) MR. ALEKSICK: JUDGE WARDWELL: good, bad, or indifferent. MR. ALEKSICK: I suppose that's good. I don't know whether It is what it is. With that clarification
then, Your Honor, yes, I think it's a fair statement that approximately one quarter of the inspections
Page 1507 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
nicely. are identified based on CHECWORKS which is to say approximately half of the newly inspected components come from CHECWORKS. Let me say that another way. Each
outage we inspect perhaps 100 components, perhaps 50 of those have been inspected before. Perhaps 50 of
them are new and of those new 50, 25 might be from CHECWORKS. JUDGE WARDWELL: Okay, that fixes it
By the way, that might not be bad
information to having an AMP for some people to understand better or generally what's going on, but that's just a sidebar from yesterday's discussion which we may get back to a little bit. Where I'm going now is this statement that I'm trying to now see how the model versus the non-model fit into this and you're saying that all of those 25 percent are model components? Naturally, because that's how they came from CHECWORKS. If the component -- how much of the components that are modeled end up being inspected? MR. ALEKSICK: There are approximately
8,000 components modeled across both units at approximately 3,700 of those have been inspected
Page 1508 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
since 1992 when we -- which is the earliest data that we have. JUDGE WARDWELL: those numbers, I'm sorry. MR. ALEKSICK: There are approximately And so that -- repeat
8,000 modeled components in CHECWORKS, so there are additional components in the FAC Program, the nonmodeled components. But in terms of CHECWORKS Of that
modeled components, we have about 8,000.
population, 3,700 or so have been inspected since 1992. JUDGE WARDWELL: And are there hundreds
of thousands of total components that are in a plant that are susceptible to flow-accelerated corrosion? MR. ALEKSICK: No, Your Honor. Our overall The
number would not be that large.
approach is to start with -- there are hundreds of thousands of components period. JUDGE WARDWELL: MR. ALEKSICK: Right. Some small fraction of Those are the ones
those are susceptible to FAC.
that we focus on and some subset of that is modeled JUDGE WARDWELL: And what I was trying
to get a handle on is what are the leftover numbers that are non-modeled?
Page 1509 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
one counts. MR. ALEKSICK: I see. It depends on how
The modeled components are, generally
speaking, the components of highest priority, highest concern. Those are the large bore, higher
energy piping systems that were the focus of the Generic Letter. However, they comprise a less than half -- if one counts the number of lines that are susceptible to FAC, maybe a quarter of those lines are modeled in CHECWORKS and maybe three quarters of them are in the susceptible, but non-modeled category and are ranked in a separate analysis. JUDGE WARDWELL: make sure I understand that. Okay, and let me just If you looked at some
of those non-modeled components, are the SNMs, the susceptible non-modeled, could some of those actually be modeled or have you truly looked at them and said no, we can't model them? MR. ALEKSICK: We've looked at them in
great detail, Your Honor, and using very specific criteria and very tight documentation on these. have dispositioned every single line. There are We
approximately 1,200 lines that we've gone through, listed, put in a table, and put each one of those lines either into the modeled box or the non-modeled
Page 1510 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. and 000049? MR. ALEKSICK: Yes, thank you, Your box based on strict criteria. JUDGE WARDWELL: I have one last fixed
point and I lost it because I was listening too close to your answer. JUDGE McDADE: While Judge Wardwell is
trying to recall that, where would we look to find those strict criteria? MR. ALEKSICK: The -- I'm sorry, the
system susceptible evaluation that we discussed yesterday JUDGE McDADE: And those exhibits 000048
Those -- the main mission of those documents
is to present that list of 1,200 lines and the disposition of each one and the criteria used to make those dispositions are contained in those documents. JUDGE McDADE: JUDGE WARDWELL: Thank you. Thank you, Judge
McDade, because I have remembered my last fixing point. Could you elaborate a little bit more on the procedures that are used with the SNMs to rank them?
Page 1511 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: Certainly, Your Honor. The first one is
We considered two primary factors. the consequences of failure.
If a given line, a
non-modeled line might upon failure cause a threat to human safety or might cause a plant shutdown or a derate or damage equipment or have any other consequence that would be highly undesirable, or even moderately undesirable, then those lines are ranked as high consequence of failure. If the line is in a locked room, it's inaccessible, it would be unlikely to cause a problem and so forth, then we would designate those as not high consequence of failure lines. our first cut. We make a second pass through that to assess the level of susceptibility, the likelihood of FAC actually occurring and those assessments are made based on operating conditions such as temperature and flow rates. They're based also on So that's
maintenance records from the plant, so if a given line -- and remember, these are typically small bore lines. So if a given line has experienced leakage
or had repairs or replacements in the past, then that line would be judged to be highly susceptible. And finally, we would look at operating
Page 1512 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 across the entire United States and actually global fleet of nuclear plants to judge which lines are likely to be higher levels of susceptibility. And then we assign a ranking of
high, medium, or low level of FAC susceptibility. And that's how we compile the rankings. JUDGE WARDWELL: JUDGE KENNEDY: Thank you. This discussion of
modeled and non-modeled lines makes me think of a question for Dr. Hopenfeld. I thought I heard you say yesterday that you don't have a problem with CHECWORKS modeling certain lines in the plant. Is that true?
Well, let me say it differently, is there a range of applicability in modeling some of the lines in the plant where CHECWORKS could do a good job and consequently are there some you would recommend will not do a good job? generically or at some high level. DR. HOPENFELD: Generically, I would say Looking sort of
all lines which are straight, simple geometry, that's fine. JUDGE KENNEDY: No matter what diameter?
Irrespective of the diameter of the line? DR. HOPENFELD: Yes, irrespective of the
Page 1513 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
everywhere. DR. HOPENFELD: Straight pipe, except I'd look at some diameter. JUDGE KENNEDY: So straight pipes
the weld area I would worry about. welding -JUDGE KENNEDY: DR. HOPENFELD:
Any kind of welding? Sorry? Not specifically But the welding
because the weld material varies. itself, the process varies.
But straight line,
irrespective of the diameter wouldn't bother me. The problem where you get is into the geometrical problems, that which I alluded to yesterday or tried to. So the answer to your
question, no, I don't have a problem with the -with one exception, but even then it's not that critical, that you don't know what the chromium content of that material is. of it. It varies. That goes to the input
The specs vary.
So there is going to be a -- but in straight lines, the corrosion rate is not that fast, even after 60 years, you're still okay, probably, but it's the complicated geometry that I'm concerned with. JUDGE KENNEDY: Could you explain a
Page 1514 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
problem. little bit more the geometry concern you have? DR. HOPENFELD: Yes, all the geometry
that would cause local turbulence, it's not only the velocity, the bulk velocity. You see, there's a
distinction between just the velocity itself. Obviously, there's a relation between the tube, the Reynolds number to the common number indicating the intensity of turbulence is directly related to the diameter and to the velocity. complicated than that. It's much more
It is the local instability
that caused creation of large areas, small areas, whatever you have. So that gets into turbulence and
it's an entirely different area. So it's the turbulence that causes the So any area where you have high This code cannot
turbulence, stay away from it.
predict it, whether it's straight or whatever it is. JUDGE WARDWELL: This gets back to our
discussion yesterday that we briefly touched upon in regards to local issues and linear versus non-linear wear rates. Can you provide us with any references or cites or evidence that supports your contention that this local type failure does result in nonlinear rates has actually caused either impending or
Page 1515 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
actual flow-accelerated corrosion failures? DR. HOPENFELD: I can start with Surry
because over there all the corrosion occurred at the elbow and it was very, very uneven. plant. I touched it. JUDGE WARDWELL: grand daddy of them all? DR. HOPENFELD: JUDGE WARDWELL: That's right. So nothing was really Surry is one -- the I went to the
done on flow-accelerated corrosion prior to Surry? DR. HOPENFELD: JUDGE WARDWELL: Sorry? Was anything done to
monitor flow-accelerated corrosion prior to Surry? DR. HOPENFELD: Your observation at Trojan. '87. I don't believe so. We're going back to So
These reactors were just getting online.
we didn't have much -- it was a huge experience in offshore industry. refineries. There's a huge experience in
And if you wish, I'll take a few
minutes to tell you how they were handling it. JUDGE WARDWELL: I think there's enough
difference between refineries and power plants that -DR. HOPENFELD: JUDGE WARDWELL: To some degree. I'd be more interested
Page 1516 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
then. DR. HOPENFELD: I think the initial one case -JUDGE WARDWELL: Have you provided cites in what types of failures have occurred since Surry and the power plants. DR. HOPENFELD: There are quite a few.
Well, there was one in San Onofre which I thought was very considered -- they found extreme thick reduction in thickness in the distribution ring. The distribution ring is the one on the top of the steam generator, sits on top of the tubes and you come with J-tubes and you distribute the flow. What
happens if I was a little man going with the flow, I suddenly come to a stagnation point of distribution where the flow splits and that's a very high turbulence area. So in that component has a very That one did so
serious safety significance. considerably at San Onofre.
Now there were two cases -- there was
to these in your testimony or anywhere so we could refer to them? DR. HOPENFELD: At San Onofre? I
believe it was referenced in one of the -JUDGE WARDWELL: I'll word search it
Page 1517 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
hear you? position, I think I provided more reference in the case of Vermont, but I did provide them here, too. I don't know if all of them -JUDGE WARDWELL: I'm sorry, I didn't
In the case of what? DR. HOPENFELD: In the case of Vermont,
I provided maybe a larger number of reference, but also provided a number of references here. remember how many. I don't
But the next one -- there were I think it And it was
two in Japan and one fairly recently.
was 2005 where a few people were killed.
very, very local, completely unpredicted and I don't know what their procedures are. have procedures. Maybe they don't But
I don't know what they are.
there were two cases which were very serious. There were two cases fairly recent, one was in Callaway, I believe and by the way, I think the NRC mentioned that, then in the case of Callaway when they looked at that thing there was a combined erosion/corrosion mechanism. That's one reason why I
they modified their definition of FAC recently. think it's out for public comments. So Callaway, and going by memory, I
remember coming, when I was at NRC, there were blips about looking at this line and getting this, but I
Page 1518 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
method. fancy. DR. HOROWTIZ: Okay, well, the first don't remember all of them. There were quite a few.
You have to go to all the announcements, the NRC announcements on failures. JUDGE WARDWELL: Maybe I'll turn to
either NRC or Entergy to comment on those potential failures. DR. HOROWTIZ: Jeff Horowitz.
Certainly, Judge, which would you like me to comment on first? JUDGE WARDWELL: One that tickles your
one, Mihama which was I believe in 2004 in Japan, and I would hardly characterize it as local. If you
look at the pictures you can see the large amount of thinning evolves downstream of an orifice. The Japanese do not use a predictive They have a much more prescriptive method,
much like the ISI folks in that they have to inspect all of the components in a certain temperature range and certain quality range and it's all spelled out. And what happened was they missed it. When they used a procedure to follow -- in the plant to follow the new procedure and they did their breakdown, the engineer doing it used the wrong
Page 1519 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
August. procedure and he left out downstream of the orifice. And in the roughly 15 years since, nobody had thought to check. That's what happened in Mihama. They didn't use
They did use CHECWORKS. anything similar to CHECWORKS. a prescriptive program.
They, as I said, had
We discussed it at some
length in our pre-filed testimony. Callaway was, I think it was 1999, in Re-did the drain line. We spoke about this Dr.
at some length at Vermont Yankee as I recall.
Hopenfeld is correct in that in some reports that there was FAC and droplet impingement involved. Frankly, I disagree with that assessment, but I've never seen the photographs of the failure analysis, so I don't really have a strong opinion one way or another. As to Surry, I would direct you to Dr. Hopenfeld's rebuttal testimony on page 40. you put that up, please? JUDGE WARDWELL: that, the rebuttal testimony? DR. HOROWTIZ: JUDGE McDADE: rebuttal testimony. What's the number for I believe is 000111? Could
000108. 000108 is Dr. Hopenfeld's
It's Exhibit 000108? Yes.
DR. HOROWTIZ:
Page 1520 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 page. JUDGE WARDWELL: DR. HOROWITZ: JUDGE WARDWELL: Which page? Page 40. Page 40. Page 4 or 40, Horowitz? DR. HOROWITZ: The first paragraph on JUDGE McDADE: DR. HOROWTIZ: JUDGE McDADE: Riverkeeper 000108, yes. Riverkeeper 000108. And where in that, Dr.
I'm sorry, I didn't understand. DR. HOROWITZ: JUDGE WARDWELL: DR. HOROWITZ: (Pause.) When I read this, this rang a distant bell in my mind where the 20 percent of all thickness was lost in the 18-month sentence range a bell and I checked into it. And it turns out that Four zero. Yes. "Since starting at."
sentence comes from the Generic Letter 89-08 which is an exhibit, I don't know the number offhand. I know it's an exhibit. But
And the significance though
is that if you read that paragraph it seems that the 20 percent wall loss came before the rupture. that isn't the case. The 20 percent wall loss turns out to be And
Page 1521 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
an erroneous conclusion made at the inspection of the outage after the rupture. So I think that the
-- after reading this, you get the impression that since the Surry elbow operated roughly 10 years that the process was non-linear, but that turns out not to be the case at all. JUDGE WARDWELL: MR. AZEVEDO: Any other --
Yes, Your Honor, let me
comment on a couple of other issues of a couple other incidents that came up. ring. One was the feed
The feed ring is located inside the secondary We have a separate
side of the steam generators.
program to monitor the degradation of the feed ring that's generated in the program. It is true that early during the original steam generator design, there were issues with FAC and the feed rings in the J-tubes. However, both Indian Point Units 2 and 3 have replacement steam generators. design modification. That issue was a
It was addressed, so the
current Indian Point 2 and 3 steam generators are not susceptible to feed ring wear. And this has
been confirmed by the inspections that we have done since. JUDGE WARDWELL: Are any of those steam
Page 1522 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? DR. HOPENFELD: It is true that my generator components susceptible to flow-accelerated corrosion? MR. AZEVEDO: No, they could have been
because of the original design, but the current steam generators, no. JUDGE WARDWELL: And furthermore, as you
stated, that a steam generator has its own AMP associated with -MR. AZEVEDO: It's monitored Entergy That's correct.
steam generator integrity program. JUDGE WARDWELL:
But it doesn't have
flow-accelerated component associated with it in that AMP? MR. AZEVEDO: No, the Flow-Accelerated
Corrosion Program are outside the steam generator. JUDGE WARDWELL: Dr. Hopenfeld, would
you like to comment on that statement that the steam generator is not susceptible to flow-accelerated corrosion, if I paraphrased it correctly? DR. HOPENFELD: It should. My
conclusion was based prior to the installation of the modification of the J-tubes. JUDGE KENNEDY: Could you speak up,
Page 1523 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
conclusion -JUDGE McDADE: (Pause.) JUDGE McDADE: DR. HOPENFELD: Please continue. It is true that my Excuse me one second.
conclusions regarding to the distribution ring was based on San Onofre at that time and if they had modified the J-tube, welding was a material problem. And if they modified the code, it would be to the distribution ring and IP, that's great. I have no problem with that. it. I don't know. With respect to Dr. Horowitz' comments, I'm sure he's right. He's done much more detailed I just go as to what -I visited I didn't get into the detail of
analysis of it than I did.
I talked to various people at the time.
the plant at the time and I saw literature following the accident and that's what I reported here. If he
has done additional analysis, I wish he had shared it with us. I don't know. With regard to this point that was just brought up that the distribution ring, it's not the only component in there. And maybe I'm straying off
the point here, but let me just tell you what it is. There's a related issue that we have in a case of
Page 1524 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 fatigue problem. Over there, one of the issues is stress corrosion cracking of the divided plate down there in the lower plenum. If it is true and there's been
European experience showing that those -- that the coating under the plating on that plate is cracking, if the base material is exposed to a lot of turbulence and you go with the main flow in the plenum on the primary side, although the dividing leg is not a pressure item, okay? pressure of the same side. It's a gradient-active flow. Because it's
It's a primary flow. It's a prime system.
So if that material is corroded and cracked, then it is exposed to auxiliary corrosion locally. Also on nozzles, nozzles in the steam generators have been known to crack and they also are susceptible to cracking to local auxiliary corrosion. It depends how much cracking is. And
the blowdonw line.
I haven't seen blowdown line as I haven't -- I know they are
a safety-related item.
inspecting them and I haven't seen anything in CHECWORKS of how they predict it. JUDGE WARDWELL: Back to the steam
generator components which was the start of this questioning, line of questioning, is the fatigue
Page 1525 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
does occur. JUDGE WARDWELL: Well, in fact, that's a monitored under an AMP for the steam generator to your knowledge? DR. HOPENFELD: Yes, the question is how Yes, it
-- the question relates to the frequency. is monitored. JUDGE WARDWELL: Okay.
And that's not
part of this contention, right, as to the fatigue analysis of the steam generator. DR. HOPENFELD: It touches on it.
There's an interface there because what I just mentioned that when you say I cannot predict how the cladding is going to behave, one way is to say well, let's pull out the cladding out of there, especially in the nozzles. Then the underlying material is
exposed to flow-accelerated corrosion. JUDGE WARDWELL: If fatigue did not
occur in the steam generator, then this is a nonissue, correct? DR. HOPENFELD: That's correct, but it
fatigue issue to start with and then sure, if fatigue isn't, that can lead to all different kinds of problems? DR. HOPENFELD: That's why I say, you
Page 1526 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. have to be careful. JUDGE WARDWELL: Isn't fatigue monitored
as part of the Aging Management Program for the steam generator? MR. AZEVEDO: Yes, it is, Your Honor. Thank you.
JUDGE WARDWELL: MR. MEW:
Your Honor, Ian Mew for the
The steam generator blowdown lines are So you
part of the susceptible non-model program. wouldn't find it in CHECWORKS. JUDGE WARDWELL:
So they are part of the
Flow-Accelerated Corrosion Program? MR. MEW: That is correct. Your Honor, just to
MR. AZEVEDO:
clarify, that's the blowdown lines that's external from the steam generator. JUDGE WARDWELL: So separating -Right. I want to cut
Dr. Hopenfeld off at that point and then come back to that because I wanted to fix the points on the steam generator first. Now I'll let you finish if you have anything more to say. DR. HOPENFELD: I don't have anything to
say except the blowdown, I don't what -- where the interface is connected there.
Page 1527 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. JUDGE McDADE: Okay, thank you. JUDGE WARDWELL: MS. BRANCATO: Thank you. Your Honor, this is We'd just like to
Deborah Brancato for Riverkeeper.
note in response to your request for specific references, if I could just note for the record and for your benefit regarding the safety significance fact that Riverkeeper Exhibits 000006 through 000011 do discuss the issues that Dr. Hopenfeld raised as well as his expert report which is Riverkeeper Exhibit 000005 at page 3. JUDGE WARDWELL: And is that in regards
to both the history problems at other plants and some of these issues that he's raised on the steam generator and blowdown lines, etcetera? MS. BRANCATO: you've just mentioned. To the former of what
Yes, thank you. Great, thank you. And I think in his
JUDGE WARDWELL: JUDGE McDADE:
report, Riverkeeper 000005 starting at page 16 is where he referred to it. And then starting at page Any
40 on Exhibit 000108, he also refers to it. other references you'd like us to focus on? MS. BRANCATO: No, Your Honor.
Thank
Page 1528 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. JUDGE WARDWELL: And since, I guess, I
still have the floor, I'll kind of switch gears a little bit or I probably -- put the train in reverse. But if we've got others that -JUDGE KENNEDY: No, I was just curious,
after all the back and forth, I'm not sure that we heard from the staff on at least U.S. operating experience with flow-accelerated corrosion? have anything to add to what Entergy and Dr. Hopenfeld has brought forth in terms of examples of plant-operating issues? DR. HISER: No, I think actually with Did you
the principal citation being the 1986 Surry event and no major FAC-related issues since then, I think speaks to the effective of the NSAC Program that the industry has implemented. JUDGE KENNEDY: Did the Agency look into
the Japanese reactor accident which, as I remember, was somewhat serious and if they did, what were their conclusions, lessons learned, if you will? DR. HISER: I'd have to go back and
We did issue, I believe it was an
Information Notice on the event and my recollection without going back and re-reviewing that Information Notice was that the system was not modeled and was
Page 1529 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. time. not considered within the Japanese FAC Program. that was a sort of a fundamental programmatic problem. DR. HOPENFELD: JUDGE KENNEDY: DR. HOPENFELD: May I comment on that? Yes, sir. Go ahead. So
I read the report at the And there was a
It has been some time ago.
very comprehensive report.
I think a group of NRC And it was a
people went there or talked about it.
very detailed report, but you really couldn't relate it to what we're doing because we don't know what their procedures were. there was no way. I do know they do have a code, equivalent to the ASME code which they follow, so it's not that they are not, maybe they don't have it exactly running a computer code like a CHECWORKS, but the methodology is the same, I believe. MR. YODER: Matthew Yoder from the NRC And as you said, they --
I want to make sure that we're very clear
that when we're talking about an ASME code we're talking about a required component thickness. not talking about modeling of wear rates. not present at Mihama. is an exhibit. We're
That was
And that information notice
We can get the number for that, if
Page 1530 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
appreciated. you'd like it. JUDGE KENNEDY: That would be
I guess I need to go back to Dr. You've brought forward this
Hopenfeld, then.
Japanese reactor accident to provide some insight into the issues here related to flow-accelerated corrosion and I'm not sure -- I gathered that in your most recent comments. Take us back through the
Japanese events and its relevance here to this contention? DR. HOPENFELD: There is. One, if you
look at the distribution of the piping and they have a very detailed UT examination of the piping downstream at various locations. And again, I'm
going based on memory here from about six or seven years ago, there is a very clear indication from their reg how local the phenomenon is. First of all, it did go down the orifice, but then I think went to the elbow. And if
you look at various sections, the locality is just extremely similar to what you see here. Secondly, there is data there. Up to
about 4,000 or 5,000 hours that they ran and I think in some different facility show that there's no linearity between time and corrosion on that
Page 1531 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
NRC report. staff. particular thing. It went up to 6,000 hours. So
there's no linearity. And again, when you talk about linearity, you have to be careful because when we talk about linearity we always talk here about average values, but that's relevant. one critical point. Relevant is And
That's what's relevant.
very little data on that. thing to measure. DR. HISER:
It's just a difficult
This is Alan Hiser from the
The exhibit is Riverkeeper 000011 and that's
Information Notice 2006-08. JUDGE KENNEDY: So the issue, Dr.
Hopenfeld, is the localized effects and nonlinearity that that causes? DR. HOPENFELD: indicated the locality. it. I have the profiles. Yes, definitely
There's no question about Maybe I have it in my
hotel room. JUDGE KENNEDY: DR. HOPENFELD: That's sufficient. You can find them in the
They did a good job on that. JUDGE KENNEDY: I appreciate it. I
think we'll come back to this later on, but I think we've noted your concern about the localized effects
Page 1532 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
solution? DR. HOPENFELD: Well, I thought about and the non-linear wear rates. to that. MR. KUYLER: Kuyler for the Applicant. Your Honor, this is Ray Before we leave the And we'll come back
subject, I just wanted to point you for the record to Entergy's testimony, Question and Answer 135 which addresses these various other events at other facilities. JUDGE KENNEDY: operating experience events. MR. KUYLER: This addresses the Is that -The four
Yes, sir.
operating experience events at other facilities that we've been talking about. JUDGE KENNEDY: JUDGE WARDWELL: Thank you. If I dare leap into the
breach here of staying with this topic for just a while, for the sake of argument, let's assume you are correct and local issues are a significant concern. What would you suggest that the Agency
look at in regards to what addition should be added to an Aging Management Program to address localized conditions? You've raised an issue. What's a
Page 1533 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 ways of solutions. I honestly didn't come
prepared very well to discuss all the various details. One, and you may not want to hear it, if
you get away with the CHECWORKS, it gives you misleading results. similar to -JUDGE WARDWELL: Can I just stop you Next, what you do -- very
right there so I don't forget this? DR. HOPENFELD: JUDGE WARDWELL: Yes. So you're saying that
CHECWORKS has no use whatsoever in flow-accelerated corrosion? DR. HOPENFELD: JUDGE WARDWELL: DR. HOPENFELD: JUDGE WARDWELL: Yes. Is that your position? Yes, yes. And doesn't that cover That's a
all facilities and not just Indian Point? global issue, is it not? DR. HOPENFELD:
Globally, yes, but I've
been focused on Vermont seriously and now with IP, so I really am not going to go to others. really looked at enough. JUDGE WARDWELL: you've looked at -DR. HOPENFELD: I have gone to just But of all the plants I haven't
Page 1534 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. JUDGE WARDWELL: counsel if she remembers? DR. HOPENFELD: JUDGE WARDWELL: You're asking your Shame on you people. She has the reference. But your testimony is remember? MS. BRANCATO: I can look that up for their code? DR. HOPENFELD: Deborah, do you primarily this and Vermont, I would say yes. There's a difference between Vermont and here. JUDGE WARDWELL: DR. HOPENFELD: Yes, I understand. To answer your question,
I would do globally, first, I'll give you the overall answer. The French, and again, I go -- I
did visit them many years ago, but what I'm telling you now is based on what I read in the literature and very recent literature. They have a computer
code to do exactly the same thing because there's a huge financial advantage. JUDGE WARDWELL: What was the name of
that you don't have the name of that code -DR. HOPENFELD: JUDGE WARDWELL: MS. BRANCATO: I don't have the name. That's fine. We'll try to get it for
Page 1535 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 got it. you. JUDGE WARDWELL: I've got a couple in my
background and I was wondering if it was one of those and if you don't know it -DR. HOPENFELD: JUDGE WARDWELL: answer, okay. DR. HOPENFELD: JUDGE WARDWELL: DR. HOPENFELD: It's a French name. It's not CICERO? Yes, yes, that's right. Yes, yes. That's It's some French name. That's a legitimate
That's correct, sir.
what I asking the attorney. JUDGE WARDWELL: DR. HOPENFELD: JUDGE WARDWELL: DR. HOPENFELD: Proceed then. I'm impressed. I shock myself. Anyway, what they have, CICERO.
if you look at it, the data they presented out of 3,000 or 4,000 data points and I don't know they got it, whatever it is. They all are within a very They're all bunched They're
narrow of uncertainty.
together, not scattered all over the place. bunched together.
Now where they bunched up is on the nonconservative side. They're like 40 percent. But
what you can do there and I'm trying to answer your
Page 1536 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, if you had a code like that that you know it's consistent, then you can say okay, it predicts non-conservative. I put a safety factor on it. And
that's my first point. So if it's inconsistent by say a factor of 50 percent, I'll put it, you know, twice as much and I'll be conservative and I've got a data point. Now, the CAGE code also had data points on erosion, droplet erosion, cavitation erosion. They have
constance there that they have derived from their experience. They don't have this F1, F2. They do
have also erosion, corrosion by chemical dissolution, but they also have constance for droplet cavitation or other erosion in the equation. That's how many points out of those 3,000 do they show? know. JUDGE WARDWELL: So you would recommend What kind of geometries they use, I don't
a revision of a code to incorporate some of the similar items that are in that particular code? DR. HOPENFELD: Yes, the most important
thing what I've seen and I've been surprised, in the French work is they don't rely on input that -- on the chromium input that is being used in CHECWORKS. They measure it. They use an x-ray fluorescence to
Page 1537 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
true. codes. measure on each component what the chromium content is and they showed in one of their papers relation between the chromium content uncertainty and the resultant corrosion rate. It's a factor of 10.
That's why they're measuring it. Now I'm not here to sell French computer I don't know what they're doing. All I'm
just referring to what I read in the literature very recently, a few months ago. JUDGE McDADE: Now your comparison, just
to make sure I understand it, conservative, nonconservative, all that is is does it predict more or less than the reality. DR. HOPENFELD: JUDGE McDADE: Right. That when you test it.
So it really doesn't make any difference in your view whether it's conservative or non-conservative, as long as it's consistent. DR. HOPENFELD: Well, no -- yes, that's
Because if I know, you see, if you know where
are we going here, then you can put a factor of factor. But if it's all over the place, it's exactly the instance, yes. JUDGE McDADE: So it doesn't matter
whether there's 50 percent that's conservative or 80
Page 1538 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
right. percent that's conservative or 85 percent that's conservative, if it's consistent. with the standard deviation. You're concerned
First of all, if it is
conservative, if you're testing and it's less than what's actually observed, the prediction is less than what's observed, or more, it's how much. In
other words, if it's only slightly more or slightly less than what's predicted, you would view it as a viable predictor. On the other hand, when you have significant outliers where on one instance you will have it by a factor of 10 and another instance a factor of 1, that then you consider the code not a viable predictor and we're going to get into the data later. your opinion. DR. HOPENFELD: Right, you're absolutely That's sort of the overview of what is
Except one thing, the definition of In some places
slightly, that goes to safety.
where, you know, I see a component that I have a major effect and luckily on the secondary side, you don't have that many, unless you get into the steam generator, as I mentioned before, and the nozzles, most of the stuff is not that safety related. not a major -- but safety is a concern. It's
You should
Page 1539 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 into it. So when you say slightly, I look at it. Obviously, I'm not going to look at every component to safety risk analyze every component. I'm trying
to answer, to be responsive to the question you asked me, what would you do and I would look into a code that is consistent. on the other side. JUDGE WARDWELL: Given the fact that Not 10 on one side and 10
CHECWORKS only accounts for 25 percent of the inspections and the previous testimony that says that the service life is predicated on actual measurements, why is the need to address the model such a significant importance to you considering it doesn't appear to be as significant tool as the way it's being applied by Entergy? DR. HOPENFELD: For two reasons. It's
good to have a computer code because it saves you money, because if you don't have, if you go based on plant experience, trending basically. If you look
at their graphs they showed you, most of the stuff is trending. What that means is that you assume
that you have a linear rate and therefore I can just look at two or three points and say well, it's going to continue like that. That's a basic assumption.
Page 1540 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 another thing why you want a computer code is because if you are doing what you're doing here, you'll measure -- you've got two things. How many points do you measure and how accurate do you measure on a particular component? You know, there's accuracy to what you measure. you really looking at the minimum? I was trying Are Are
yesterday to go to the grid to discuss that.
you really, when you trend, do you really have the number that you're really basing your future projection? And even if it was linear, which you And then how good is We haven't heard
have, so that's number one. your statistical sampling? anything about that.
The 75 percent, I've looked and looked. I don't know what's included, what's not. I mean
talked about this line is safe and our feeling is this. The only way you can say that it's safe or
not safe is to show somebody some kind of a risk analysis, some kind of assessment, some statement to the effect that if something happens here only the rabbit is going to get killed. nothing there. I'm sorry I'm emotional. It's my I mean there's
Page 1541 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
where? MS. BRANCATO: Exhibit 000110. That is Riverkeeper personality. JUDGE McDADE: Let me just ask you a
question based on a question that Judge Wardwell just asked, I may have a misconception in my own mind that I'd like to clear up. Mr. Aleksick, if you could, as I recollected and what I took from what you testified earlier, and correct me if I'm wrong, but about 25 percent of the inspections are informed by CHECWORKS, but only about 50 percent of the new inspections are informed by CHECWORKS and of the new inspections of modeled components virtually all of them are informed by CHECWORKS. MR. ALEKSICK: JUDGE McDADE: MS. BRANCATO: Is that correct?
Yes, Your Honor. Okay, thank you. Your Honor, this is Just before you
Deborah Brancato from Riverkeepers.
move on, if that's your intention at this point, I just refer you to Riverkeeper Exhibit 000110 which does discuss the French CICERO model that Dr. Hopenfeld and you were discussing. JUDGE McDADE: Could you repeat that
Page 1542 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: Thank you. It was Ten
suggested this may be a good time for break. minutes, Judge Wardwell, is that sufficient? JUDGE WARDWELL: JUDGE McDADE: Oh, yes.
Why don't we take a 10-
minute break and again, it's important to try to get back on time. It's now -- I have 20 minutes so we
will come back at 10 minutes of. (Off the record.) JUDGE McDADE: MR. KUYLER: On the record. Your Honor, this is Ray Before the break,
Kuyler from the Applicant again.
we were talking about the BRT-CICERO program and Dr. Hopenfeld's testimony on it which I believe came up for the first time in rebuttal. And I do believe
that our witnesses can also provide some information on the paper that Dr. Hopenfeld is referring to. JUDGE McDADE: JUDGE KENNEDY: Good. Thank you.
Dr. Hopenfeld, I'd like
to go back and talk a little more about these localized effects. I think in the context of that Is
you brought up the operating experience issues. there anything else you'd like to point to to support the importance of the localized or geometrical effects?
Page 1543 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: Well, but again can I
talk about offshore oil observations? JUDGE KENNEDY: I think we concluded
that it may be difficult to make that transition from -DR. HOPENFELD: Yes, I'm just saying the
localized corrosion you can even go on the internet and click on the localized corrosion and get a whole bunch of articles, pictures, anything. common experience. It's a
It's a multi-billion dollar --
It happens in -- I mean there are more non-nuclear facilities and that's a major cost item. And they haven't solved that still. It's a major cost estimate item. replacing material. Constantly
And it was mostly based on my It's
experience, my discussions, everything.
because of the local nature of that beast. JUDGE KENNEDY: I guess what I'm
struggling with here is I think the sum total of the operating experience considering the amount of operating reactors in the world or in the United States even that it didn't seem like a large amount of anecdotal information. So I'm trying to
understand in this context what seems to be passionate concern about these localized effects.
Page 1544 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
100 grids. And you need to help get us there. DR. HOPENFELD: Yes. I looked at about
The grids is the ultrasonic map of those
components and an estimate of one or two and all you've got to do is to go through there and you even see a pattern. And what the pattern is is that you
get most of it -- In the case of an elbow, you can almost predict where it's going to happen you know on the outside. It varies, but it's consistent.
It starts pretty uniform and then it goes extremely fast high. examples I gave you. six inches. And you can look into
It was one inch change within I mean your
That's a big change.
probe can't read it. I think I'm trying to answer this in other places that I've seen. I really spent some And I went
time looking all the data they gave. through each one of those.
And it stares at you.
So when I hear they say it's not a local phenomena, it depends on how you define local. If
you say I have a line and maybe within the line it's not a local, I don't know. But I'm trying the local
within the component that I look and I'm worried about where it's going to leak. JUDGE KENNEDY: The grid data and the
Page 1545 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
experiential data you're talking about, is that in the Entergy submittals? DR. HOPENFELD: the French data, yes. Their reference about All I
I don't know exactly.
have is reading the paper they wrote. JUDGE KENNEDY: I guess I'm thinking
about you reviewed some data about the localized effects. Is that Indian Point data you reviewed or? DR. HOPENFELD: believe that was referenced. The Japanese and I It definitely was
referenced in the -- But I believe it was referenced here, too. But if it's not that would have a very
clear indication. And the Indian Point, I mean I believe I did attach to one of those figures that I presented yesterday. And by reference I believed we
referenced all the 100 figures or 200 figures that they gave us in the offshore local phenomena. JUDGE KENNEDY: I don't want to diminish But
the importance of flow-accelerated corrosion.
if this localized effect is such a dominant issue I'm struggling with why we don't see more operating experience of failures related to these localized effects. DR. HOPENFELD: I think we do. I think
Page 1546 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
exhibit? they have referenced or mentioned like 16 leaks and numerous if you go to the data of exceeding the critical thickness. And so the local thing they say it's not flow-accelerated corrosion because they don't define it that way. occurred. They say it's erosion. But the leaks
So you see it. JUDGE KENNEDY: The leaks occurred even
though they were above the -DR. HOPENFELD: JUDGE KENNEDY: Even though what? There were leaks that
occurred even though they were above the Tcrit or min crit. DR. HOPENFELD: reported that way. I don't know. It wasn't
All they reported was a leak and
I've seen like 16 over a certain period of time. And obviously I'd seen references up to 2006 or 2007 of hundreds of leaks all over the place. cost item. the plant. But it's a
It's to a large degree a cost, cost for If I was running the plant, I wouldn't It costs me money unnecessarily. Can you focus this to an
want to have that.
JUDGE KENNEDY:
And I guess in that regard are we talking
about Indian Point data again or other operating data?
Page 1547 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: Right now I'm talking
about the 100 figures, something like 100 figures, that Indian Point 2 and 3 provided us. you samples of two. line. And I gave
One of the things was a small One of
The other one was a 30 inch line.
them I think was a steam line. wet steam.
So it must have been
And the other one was a feedwater line. MS. BRANCATO: Your Honor, this is If I may, Dr.
Deborah Brancato from Riverkeeper.
Hopenfeld is referring to the graphs that were in his presentation yesterday which come from Riverkeeper Exhibit 000130 and Riverkeeper Exhibit 000049. And in addition the instances of leaks that
Dr. Hopenfeld is referring are also provided as Riverkeeper Exhibits 000025, 000026 and 000027. JUDGE KENNEDY: Thank you. Maybe we
could get Entergy to address this. JUDGE WARDWELL: Before you do, I have
another question for Dr. Hopenfeld on this issue. And I don't know whether I -- I may have to pull back my brilliance last time and maybe in this model. there. Maybe there are two different models out That's why I had several in my mind. The French model, could it actually be CIROCO rather than CICERO?
Page 1548 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
attorney. DR. HOPENFELD: I'd have to ask our I don't.
She's got the references. JUDGE WARDWELL:
Well, regardless, have
you ever heard of CIROCO model? DR. HOPENFELD: JUDGE WARDWELL: that's it or not. DR. HOPENFELD: read the article. JUDGE WARDWELL: The French model, in I don't know. I just I may have but. You don't know whether
their modeling, what do they say about this linearity issue? DR. HOPENFELD: The thing that impressed
me what they said -- It's not anything that they said because I don't know anything about the model. But I was impressed with the fact that they have the right approach. And that is "Look. I've a large
uncertainty in the input. And that is important.
I'm going to measure it."
The other thing that I was impressed with is all the data points were consistent. all. I really don't know anything about that. I'm really not an That's I
don't know what they did. authority on that analysis.
But I do remember that when Dr. Horowitz
Page 1549 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
was talking about all these labs he did mention the French. When I read the French articles about that,
they did mention that either the issue of FAC whether it's a corrosion or erosion is not clear because there was a clear indication -- I referenced it in several places -- that the velocity independent was not a straightforward Reynolds type of an equation. It wasn't.
At some places, the velocity was to the cube which indicates that this is just not a straightforward mass transfer control. Now they had
a theory, the British had a theory, where it is mass transfer controlled and why it is to the cube, but it was just a theory. There's no way of telling it
was corrosion or erosion or both. I think what you see here is the practical answer. cares what it is? doing it. You look at that elbow. Who
All I see -- It could be bananas
But all you really care is I see these
huge differences over a local distance and I don't know how to predict it. That's all. Okay. The thing I'm
JUDGE WARDWELL:
referring to is Entergy's Exhibit 000036B on page 76. Could we pull that up quickly if possible? I
think this is the model that I'm referring to is the
Page 1550 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
Hopenfeld. DR. HOPENFELD: When I gave you a CIROCO and the author is a French name. I will
probably slay with great dexterity, Bouchacourt. Does that author sound familiar to you, Dr. Hopenfeld? DR. HOPENFELD: talking about? JUDGE WARDWELL: DR. HOPENFELD: interesting. Oh yeah. Sure. I read it. It was Can I see it what you're
I believe so, yes. Well, there is a plot Yeah. You can show It's best to
JUDGE WARDWELL: of some results on page 7-6. the plot, too.
Show the whole thing.
leave the whole page up I think because they'll be able to see -DR. HOPENFELD: I don't believe that
that's the data I was looking at. JUDGE WARDWELL: Say it again, Dr.
reference, all the data were about -- The reference I provided were way above. The last one I used in
the reference that I provided you, all the data points were non-conservative. side. That's all I remember. JUDGE WARDWELL: What I'm interested in They were on one
Page 1551 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: It wasn't this figure. What I was interested Really that's a That's
in is the first bullet item there.
core key dot, but I won't get into that. another time for that.
The item there it says, "The thinning is directly proportional to time" in regards to their results. Would you like to comment on that? DR. HOPENFELD: reference this document? JUDGE WARDWELL: No, I'm providing this Where is this? Did I
to see if first whether you recognize this author that's under that figure as being the author of the French code. And is the French code in fact the
CIROCO loop test results that were described here? That's what you were referring to or not. DR. HOPENFELD: was referring to. JUDGE WARDWELL: DR. HOPENFELD: Okay. No, I was referring to a No, that's not the one I
very recent document like a few months ago. JUDGE WARDWELL: But then I go on to
point out that you'll note that it does talk about that the thinning is directly proportional to time.
Page 1552 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 if you haven't studied this exhibit, you can't really comment on this. DR. HOPENFELD: I did look at it and the
point is here that these are laboratory studies and sure they're running the control condition. If they
are run at low Reynolds number or low velocity, relative low turbulence, you'll get a linear relation. There's no problem. JUDGE WARDWELL: DR. HOPENFELD: complex geometries. Okay. Thank you.
I'm talking about
I don't think it's here. Thank you. I think we've been all But I'm
JUDGE WARDWELL: JUDGE KENNEDY:
over this issue about localized effects. not sure what Entergy's position is.
How is this
aspect of the Flow-Accelerated Corrosion Program treat the nonlinearity effects or the localized geometry effects that Dr. Hopenfeld is talking about, if it does? MR. ALEKSICK: the Applicant. This is Rob Aleksick for I didn't
I'm sorry, Your Honor.
hear the last half of your question. JUDGE KENNEDY: did ramble a bit anyhow. Let me try it again. We've been talking about I
nonlinear, localized effects either due to geometry
Page 1553 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
or flow conditions. And I'm wondering how the Aging
Management Program for FAC at Entergy deals with these localized effects or if they're real at all. I mean if it doesn't deal with them, is it because they don't exist or if they do exist, how are they treated? MR. ALEKSICK: I would characterize FAC,
flow-accelerated corrosion, as a line level phenomenon. FAC is like cockroaches. If you see
one, there's more going on there.
And if the line
conditions, if the temperature and flow rates and base material and pH which are typically constant across a given line, if those conditions are conducive to FAC and if you observe FAC in one fitting, you often -- you typically in the majority of cases observe FAC in some of the other fittings along that line. And so in that sense I consider
FAC a line level phenomenon. Now, of course, it's a local phenomenon in the sense that the components wear locally and the degree of wear may vary from component to component based on its local geometry. But in order to have an effective program, we have to recognize that FAC is not a random phenomenon that occurs in an unpredictable
Page 1554 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. manner at a component level. thousands of components. We have thousands and
And if we had to treat
FAC as a random or purely local phenomenon we would have an enormous challenge. Fortunately, FAC is predictable at the line level and we generally treat things at a line level programmatically. And we dive down into the
component level for individual inspections and model results and things like that. But thinking programmatically we think more about the line. now? JUDGE KENNEDY: I guess I'm -- So you Does that answer your question
said fittings, so like elbows and other geometrical effects on the line flow conditions. MR. COX: This is Alan Cox for the
I could maybe clarify that a little bit.
Rob says line level, but you're correct that the individual fittings are modeled in that line. So
basically what that means is if you've got a pipe that has several bends and elbows in it that each of the elbows of that line is going to see the same flow conditions, the same temperatures. So each
elbow would be expected to see the same wear. Now when you say line levels, that
Page 1555 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
doesn't mean the pipe between the elbows is going to see the same level because it doesn't have the same geometry factor. But all the same components within
that line to see the same conditions are going to see similar wear. JUDGE KENNEDY: Is there some effect of
the fittings on the turbulence and flow regimes? And does that have any bearing on the calculated wear rate for that piece of the component or piece of the line? MR. ALEKSICK: again, Your Honor. This is Rob Aleksick
Yes, the local geometry, say a
90 degree elbow, will typically wear more rapidly than a 45 degree elbow. But in terms of the
calculation of the wear rate based on the measured wall thicknesses, the geometry doesn't play much of a role. Once we know the wall thickness and knowing
that it's a linear phenomenon we can project flow rate. Perhaps an example would help. Dr.
Hopenfeld referred to what he called the huge differences in measurement from point to point on the grid that he presented in his presentation yesterday. Do we have that? Could we perhaps put
that on the screen?
It's not an exhibit, but it was
Page 1556 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 fine. you. a PowerPoint from yesterday. JUDGE McDADE: Exhibit 00002. MR. ALEKSICK: Yes, that's it. Thank It was part of Board
And it would have been about the fourth or I believe it's the -- Right there. If we could zoom in perhaps on that
fifth page. Yes, great. figure.
That's good. That's fine. So this is a specific component, an
elbow, a 30 inch feedwater elbow, at Indian Point. And if we go to the next page in this presentation and if you could please zoom in on the sort of lefthand side of the grid there, you can see that at Coordinate C08 there's a parent measurement of 0.513. And next to it are measurements of on the That looks like a fairly
order of 1.5 inches.
significant step change. Now if we could bring up Riverkeeper Exhibit 000130. And that exhibit is the full
inspection package that Dr. Hopenfeld kind of excerpted for his presentation here. JUDGE WARDWELL: While we're doing that,
is it Dr. Hopenfeld or Dr. Hopenfeld or is it both? DR. HOPENFELD: I'll answer. Anyway you call me
Page 1557 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
way. MR. ALEKSICK: That the good doctor JUDGE WARDWELL: DR. HOPENFELD: What do you call it? Usually you call me
Hopenfeld or some of them -- my son is called Hoppy. MR. ALEKSICK: And if you could go down Stop right there
to the third or fourth page. please.
Now this is the same figure that Dr.
Hopenfeld, right? DR. HOPENFELD: MR. ALEKSICK: JUDGE WARDWELL: DR. HOPENFELD: Hopenfeld. Hopenfeld. Just think of Hoppy. You can say it either
excerpted it for his presentation. DR. HOPENFELD: MR. ALEKSICK: That's better. Unfortunately, in
preparing his presentation, he cropped out a key fact here. If we could zoom in on that word Thank you. What we're looking at on
"lamination."
the lefthand side of the screen here was omitted from yesterday's presentation. important fact. A lamination. It's also if you scroll And it's a very
down to the lower lefthand corner of this page you'll see it again. There. Stop please. You see
Page 1558 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 second to bottom reading or second to bottom sentence. It says, "Low readings due to
lamination." A lamination is a condition that occurs not infrequency in thick walled pipe like this. This is a one and a half inch thick pipe roughly. And in thick piping like that you sometimes come across what is called a lamination which is essentially a discontinuity in the metallurgy of the pipe. And it will give when a standard UT reading
is taken an erroneous reading. So this 0.513 reading is the depth of that lamination. pipe. It is not the thickness of the
And we know that because it says it actually
in three different places on this inspection package. So my point, Your Honor, is that the example that alleges huge differences in measured pipe wall thicknesses is in fact due completely to a lamination, not due to any kind of wall thinning or reduction in wall thickness whatsoever. just like to point that out. JUDGE McDADE: From an engineering I would
standpoint, how do you determine that it's the result of lamination?
Page 1559 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. AZEVEDO: Yes, Your Honor. This is
Nelson Azevedo for Entergy. different things that we do.
There are a couple Normally, the pipe
thickness is measured using a given transducer at a given frequency or what we call a straight beam. When we find conditions that look suspect, we go and do a couple different things. One is use a different frequency transducer and if the lamination which is originally started as an inclusive that was flattened out, if it's tight, you can actually punch right through it and you can see a reflection from the back wall with using a different frequency transducer. The other thing that we do is we shoot on an angle and see if we can see the inside service of the pipe underneath the inclusive. And that's
how we determine whether it's an inclusive called lamination or whether it's true wall thinning. JUDGE McDADE: MR. ALEKSICK: Okay. Thank you.
I guess I'd just like to
reiterate our conclusion which is that these wall thickness readings are not due to flow-accelerated corrosion and they do not reflect any reduction in the wall thickness or the pressure retaining capability of that component. They merely reflect a
Page 1560 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
metallurgical property. JUDGE KENNEDY: So they're not
demonstrative of a localized, nonlinear wall thinning. MR. ALEKSICK: Exactly, Your Honor. And
I completely reject the assertion that this dataset represents "huge variations" in the wall thickness. JUDGE WARDWELL: that grid of the data points? others. And can we go back to Yes. And there are
So is that true of the one right below it I mean there's almost --
and the one following it?
And is that why they're shaded on this grid sheet also because those are the ones that you consider to be laminations? MR. ALEKSICK: The shaded area is However, shading The shading is
representative of the lamination. is not because of the lamination. because of the number. the -JUDGE WARDWELL: then that it happened. MR. ALEKSICK: JUDGE WARDWELL: JUDGE McDADE:
The shading is applied by
It's just fortuitous
Yes, precisely. Okay. But is it also your
testimony -- I just want to make sure -- that that
Page 1561 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
an accident. Honor. JUDGE WARDWELL: It's an artifact. It's lamination phenomenon in no way impacts the integrity of the piping, its capacity to take the pressure? MR. AZEVEDO: Yes, that's correct, Your
not a reality, this lamination. is there.
And the thickness
It just happens at these locations to
create a lower than what it should be reading. MR. AZEVEDO: Yes, as Mr. Aleksick said, And the reason why
that's a metallurgical effect.
it's structurally insignificant is because it's parallel to the load path. even see that it's there. JUDGE WARDWELL: Dr. Hopenfeld, do you So the load path doesn't
agree that laminations are not an issue? DR. HOPENFELD: Could be an issue, but First of all, I I even
I'd like to answer your question.
saw the lamination and I was very clear.
went to the dictionary to make sure I understood what they were talking about. The bottom line question is if there was Let's say you let that lamination go
on or whatever happens here for another two years. And then suddenly the valve somewhere or local
Page 1562 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
occurred somewhere in the system. blow up that pipe? Is that going to The other
That's the question.
question is is it going to leak whether it's lamination or it's imperfection or whatever it is. Secondly, this is one that I brought up because it was a large size. section. It had a straight
My main purpose was to show that the
process is not -- In the grid there, I picked up was 1.491 which doesn't indicate that it's a lamination point because it's similar as they say. And then I picked up a number next to it which was the 0.513 which they reported. Plus they
also reported on the same grid a number even less than 0.513. This just represents -- I can give you other elbows and orifices that doesn't say anything about lamination. And you see the same ratio. You It's
see that it is not flow-accelerated corrosion. an erosion problem. only 50 minutes.
I picked it up because I had
But I can give you more if you wish and I'll show you the same numbers after I have it in my notes. So this was not picked up. But the bottom
line with this lamination, imperfection, whatever it is, doesn't really matter. What matters is am I
Page 1563 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
safety. going to have a LOCA and Part 50 requires you that this component would withstand LOCA. So when I hear lamination I say it's I don't care whether it's FAC or not. What
it is, is it safe. it was safe.
And we didn't get an answer that
I can tell you if you ask me what is a constructive thing and how to do it. to I'll get into more detail on that. wish I would like to. different industry. JUDGE WARDWELL: Do you disagree that If you want me If you would
But I'll have to go to a
the actual thickness at C08 is not 0.5 at that location and in fact a value closer to the 1.5 inch? Or do you believe that the actual thickness at C08 is 0.5? DR. HOPENFELD: I looked at these from
three or four different angles on that very point that you asked. One way of looking at it is to say I
let me look at the one next to it and it's 1.492. don't know if it was lamination or not. Let me put it just for a second. is so bad, don't present it. If it
Don't give it to me.
I don't want to waste my time with something if it's bad data. Don't give it to us. Don't present it to
Page 1564 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
lot of work. us. It's your judgment. That's fine.
If you're going to their procedures and how they presented the data, there is a whole bunch of discussion as to the guy selected the notes. selected because of this. this. He selected because of He
If this is bad, if this is not But they gave
representative, don't give it to me. it to you.
They gave it to us. And I believe that
these numbers represent something. Now whether they represent -- I'll tell you one thing. I don't believe that that 0.513 The minimum actual It does not
represents the minimum number. thickness, that's what counts.
represent the minimum actual thickness in that grid. It's less. But how much less? I don't know. I would have to do a
You see there's one And if I was running the
thing you don't have here.
plant, I would insist that the contractor who did the ultrasonic to give it to you to show you what is the probability of detection for this particular case, what's your accuracy, what the coupling that you're using. I assume everything -- How many
points did they measure here? Don't forget. That probe is only 0.32
Page 1565 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
intentional. JUDGE McDADE: question here. But let me just ask you a inches. This is what you're looking. 50 mL drag across the probe. average. You have about
That probe reads If it's an So the number
So it must be less than it.
average, it must be at least 25 mL.
must be at the minimum less than that. But now if you have waves and pittance and lamination or whatever you want to call it, who knows what it is. safe to run. That's the problem with it. It's
That's what the gentleman said.
That's what the problem is. I have no problem with the -- I apologize. I did say the lamination and it didn't come on the figure. It was not intentional. Doctor, if I could
JUDGE McDADE:
interrupt and again we want you to be talking to us, not talking to you. DR. HOPENFELD: Yes. It wasn't
I mean we had from Mr. Azevedo an
explanation of how they are able to identify whether or not it's lamination as opposed to flowaccelerated corrosion or erosion. Based on your expertise, do you have any reason to take issue with the explanation that they
Page 1566 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
there. are able in fact to identify lamination as opposed to corrosion or erosion? DR. HOPENFELD: No, I don't know. First
of all, this is the only one I believe that had a lamination note on it. But I didn't focus my -- I This one just came I
looked at most of the others. out.
And I didn't pick up because of lamination.
was debating whether I should. But I did because it had a clean section Because you have to realize -JUDGE McDADE: to that later. I understand. We'll get
But we heard the testimony of Mr.
Azevedo and he explained how they were able to identify that this is in fact lamination. You don't
take issue with the technology that he described that that would be able to in fact identify lamination. DR. HOPENFELD: I've done -- I have some Not seeing But I
hands-on experience with these probes.
what the technician has done, I really can't.
trust that the gentleman knows what he's talking about. that. JUDGE McDADE: But you can't really Okay. Next Mr. And it's his judgment. I'm not questioning
speak to it one way or the other.
Page 1567 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
second. DR. HOPENFELD: JUDGE McDADE: Yes. Mr. Aleksick, as I Aleksick testified that having identified it as lamination that in his professional judgment the lamination would not in any way affect the integrity of the piping. Now if in fact -- And it seemed to be from your testimony if you had a LOCA, if you had something else occurred, that the integrity of the piping could be compromised. Do you believe that
the lamination can affect the integrity of the piping and, if so, why? DR. HOPENFELD: Yes. When you go
through the hoop stress, you don't ask yourself if it's laminated or whatever it is. You just take the
operating pressure and multiply it by the radius, divide it by the thickness and you look at the allowable stress. And if the allowable stress is
not what the code allows you, then it's not going to hold it. But if it's lamination or whatever is a Now -Let me interrupt for a
pit or whatever it is. JUDGE McDADE:
understood your testimony that if you ran those tests if it was laminated it would pass those -- If
Page 1568 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 was lamination as opposed to flow-accelerated corrosion, it would pass the stress tests. correct? MR. ALEKSICK: Yes, Your Honor. That's Is that
correct because there is no metal loss.
The pipe
wall is approximately 1.5 inches thick at that point. It's merely indicated at 0.513 because the
ultrasound bounced off that discontinuity and gave it erroneous reading. JUDGE McDADE: And I believe actually it
came from Judge Wardwell rather than the witness, but he described that as a artifact as opposed to the reality. MR. ALEKSICK: I think that's an
excellent choice of words, yes. JUDGE McDADE: So that's something that
you would agree with that characterization. MR. ALEKSICK: JUDGE McDADE: Yes, Your Honor. Dr. Hopenfeld, would you And, if so,
disagree with that characterization? why? DR. HOPENFELD:
I don't know enough
about it, but if this is a fluke, if this is an outlier, if this doesn't represent anything, that's fine. But I didn't really look at that.
Page 1569 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
thickness. thickness. it's -DR. HOPENFELD: notes or elaboration. JUDGE McDADE: fluke or it's an outlier. They're not saying it's a They're saying that based And then The same message and no JUDGE McDADE: But they're not saying
on the way that they test it it shows up.
they can test it further and identify whether or not that original reading is correct and demonstrates an absence of pipe thickness or whether or not it is through this lamination which is an artifact where there is in fact the appropriate pipe thickness. you -DR. HOPENFELD: It is reported as a It's wall Do
That's what the report says.
The question is that I would ask how you
determine whether it will take the pressure or not. One way of doing it is very simple. pressure test on it. But I don't want to waste people's time. This is just one. I didn't see any other notes But if you Just run a
lamination that was that significant.
have a problem with the lamination I can find another grid. In fact, I brought you the other figure.
Page 1570 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? The next figure shows you also going from 0.59 what it was -- My whole point here was to show you that that ratio if you take that ratio and compare it to CDF calculations showing you that this is not a flow-accelerated corrosion as they defined it. was my whole message here. JUDGE KENNEDY: But isn't that the That
Is there really evidence of a nonlinear wall My understanding of what this data
thinning here?
shows is that there is not any evidence of an nonlinear or geometric effect wall thinning? missing the point? Am I
And all of you can speak up. Yes, Your Honor. This is
MR. AZEVEDO:
Nelson Azevedo for Entergy. couple quick points if I may.
Let me just make a This lamination it's It's
an original fabrication defect or inclusion. not something that propagates with time.
The other point I'd like to make is just to be positive that we were sure that this was lamination and not flow-accelerated corrosion induced thinning we went back the following outage and verified that nothing had changed. JUDGE WARDWELL: any comments in this area? remain silent? Dr. Hiser, do you have Or do you just want to
Page 1571 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 two. that occurs. in. MR. HISER: issues discussed. JUDGE WARDWELL: I'll fold some things There have been a lot of
Have you heard of this lamination before and is
it something that you commonly run across with other plants? And is this a plausible reason for these
lower readings? MR. HISER: Laminations are a phenomena
I wouldn't call it necessarily -It is a metallurgical
Well, it is reality.
artifact, but it also is reality where the material has -JUDGE WARDWELL: MR. HISER: Has a discontinuity.
-- a discontinuity between
And that's why in reality when you take
thickness measurements when the sound beam hits that interface it reflects FAC. That's how the thickness If you have a
measurements are made overall.
portion of pipe without a lamination, it goes from the outer surface to the inner surface when it hits that interface and it reflects back. That appears to be a plausible explanation for this data. We have not
independently reviewed this data set. JUDGE WARDWELL: Okay. Maybe I should
Page 1572 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
go back to Entergy then with the next question. Entergy, Mr. Azevedo, how are you sure that this discontinuity hasn't weakened the strength characteristics of this elbow regardless of the fact that this wall thickness may still be 1.5? It ain't
as good as 1.5 without that discontinuity, is it? MR. AZEVEDO: look at it really. Well, it depends how you
Naturally, you could argue that Again,
it can make the pipe stronger if you will. just give me a second. First, let me comment. it's not weakened the pipe?
How do I know
And the way I know that
is because whether you look at the hoop stress or the axial stresses. Both of those stresses are So if you have a
perpendicular to the lamination.
sheet of paper and you were to rip it down the middle and then pull the ends, the fact that the sheet of paper is ripped down the middle doesn't really weaken the sheet of paper. And to the other point you can actually argue what makes it stronger is if you were to have a flaw crack on the top of the paper that flaw could grow to where the inclusion is and then stop. don't take credit for it. the pipe stronger. So we
I'm not saying it makes
But you could argue that it
Page 1573 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
comments? DR. HOPENFELD: Yes, I had two comments. does. But what I can say is because the directions of the stresses the laminations don't have a significant effect on the structure capability of the pipe. JUDGE WARDWELL: Dr. Hiser, have you
ever run across this at other situations at Indian Point or at other situations at other plants? MR. HISER: familiar with. JUDGE WARDWELL: MR. HISER: Thank you. Not that I'm specifically
But I know ASME code takes And this
into account things like laminations.
would I expect it would likely be acceptable by ASME code perspective because the lamination is located in the middle of the pipe. And as the Entergy
witnesses testified, the loadings here would not enable that lamination to open up in a way that could propagate the lamination or cause a structural problem. The orientation of it would be such that
it would not have a significant impact on structural integrity. JUDGE WARDWELL: Dr. Hopenfeld, final
Page 1574 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 reasons. One, if I was a pipe manufacturer or salesman and came and sold you this pipe and told you it's laminated -JUDGE WARDWELL: Please talk to me for
One, you should talk to me and, two,
that's where your mike is. DR. HOPENFELD: I'm terribly sorry. If
I were a salesman and came to you and said, "Why don't you buy that? I'll give you it at a discount.
It's got some lamination in it," would you buy it? That's question number one. Question number two -- and I haven't done it, but I just looked at it here -- is I bet you if I didn't go to these -- First of all, I looked -- If you see my notes on the bottom there, I looked at two points. But I believe if I looked at
other points between like 1.6 and 1.4, if I made those calculations, I would still show the same answer. I would still come up with the same. So I
don't know where the laminations are.
There were no
pictures to show me where they are or where they are not. Maybe I would have picked it up. But the bottom line is would you buy a pipe like that. Would the ASME account for that? This is not unique to only the
Do you want to know?
Page 1575 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
long is it. nuclear industry. In fact, the API had a lot of
problems with that and a lot of problems primarily in offshore oil facilities where you have a lot of pitting. So you miss it. In fact, in Trojan, there was a big pit that was missed on a much smaller grid. There was a
four inch grid on a 30 inch pipe and they missed big indications. angle. So they are there from a different
You know this is a wrong grid. But going back to the thing, in order to
meet code for this particular case, the first thing you look at and say "Well, the report is 0.513." That's either close or lower than the allowed thickness. The next thing you can say "Do I have somewhere in the code that allows you to look at the next step?" And the same thing the API did. They This
said, "If you have a little pit, who cares? would not affect the strength.
Maybe a leak, but
it's not going to affect the strength of the hoop stress of this thing." So what you do is you take a look at how Then you go and do calculations and see And I don't know
whether it will take it or not. how long.
You see you could look at this report.
Page 1576 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 a vendor gave you something. what it is. You don't know
You don't know how many points he took. The gentleman is right. You can get
reflection from the back wall and you get a different reading. wouldn't buy this. really. But look at this report. I
It doesn't tell you anything You don't know that it
It tells you 0.513.
really is the smallest point within that grid. That's not what you want to know is the smallest. You want to know if you meet the code. I don't know how you can tell from this that you meet the code. JUDGE KENNEDY: Dr. Hopenfeld, even with
the additional explanation that Mr. Azevedo has provided of additional testing that was done on the pipe? I mean it seems clear to me that this data is
an anomaly and not reflective of a minimum wall thickness. But I gather from your testimony that This to you, This 0.513 is
you see it exactly the opposite way. this minimum wall thickness, is real. a real number to you.
And I'm thinking that what we've heard from Entergy's testimony is that they took the data. It was an anomalous reading that they pursued with other testing methods and that they don't believe
Page 1577 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 wall thickness is of that magnitude. And I'm
struggling with how you have drawn a completely different conclusion. DR. HOPENFELD: this one as an example. looked at many others. First of all, I did use And as I said before I My point that the ratio is
above 1.6 which you see on the bottom there is not unique to this particular case. And I look at other
points and they all show that this is not a straightforward mass transfer FAC control phenomenon the way they said. So you can look at many other elbows forgetting about this particular one with the lamination. I don't want to discount the lamination
because you can say -- You basically say "I don't know what I'm running with." That's basically what it says. We heard testimony that it is safe, but it hasn't been shown that it is safe. All I know is it's a low point. I don't know.
It's reported as Is that
0.513 and there's a little note lamination. enough to tell you that's okay?
But I'm willing to completely disregard this because it's not the only one. was that that ratio was not 1.6. My main point
And you probably
Page 1578 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
any. DR. HOPENFELD: JUDGE KENNEDY: your hand up. Can I show it? Dr. Hopenfeld, you have two. can go to some other places here and you'll find that it is not. JUDGE KENNEDY: follow-up for Entergy. I guess I have two
Is it your testimony that
the lamination explains the low readings there? MR. AZEVEDO: JUDGE KENNEDY: Yes, Your Honor. So let's go to question
To maybe head off the possibility that Dr.
Hopenfeld is going to go review his data again and come up with a second example, from your perspective, from Entergy's perspective and Indian Point data, has there been any evidence that you've seen of nonlinear wear in an elbow? how is the plant dealing with this? MR. AZEVEDO: Well, I can say I'm the And, if so,
supervisor of the group responsible for the FAC Program. I can tell you from my experience I have
not seen it. JUDGE KENNEDY: So there is no evidence
of a nonlinear wear rate in an elbow. MR. AZEVEDO: I'm certainly not aware of
Are you going to point us to a set of
Page 1579 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
just looked. data that we can discuss here? DR. HOPENFELD: JUDGE KENNEDY: Sorry. Are you going to point
us to a set of data that we could look at? DR. HOPENFELD: It's not in evidence. I
Others and I have it in my notes here. I
I have another elbow, but it's not in evidence. don't know. number. I can come back and show you another
I took it 2.0 points and the ratio came 6.0 It's a different elbow. And you're reviewing
as opposed to 1.6.
JUDGE KENNEDY: Indian Point data.
Is that what you're telling us? Yes. It's from Indian I can give you the -
DR. HOPENFELD:
Point, but I don't know which.
- It's 3R15 IP3 and this particular one was I have the drawing number and I have the grid number for it, too. So I looked at others. This is just one
and I still don't want to discount the lamination anyway because I don't understand it. would you buy a pipe like that. JUDGE McDADE: Okay. You gave some The answer is
numbers there that I wasn't quick enough to write down. Could you repeat them? DR. HOPENFELD: The numbers right now
that I gave you from different --
Page 1580 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 find out. Hopenfeld? DR. HOPENFELD: Yes, I looked at another Applicant. evidence. JUDGE McDADE: -- We're not sure. DR. HOPENFELD: JUDGE McDADE: It's not in evidence. And then we can decide Well, I'm just trying to JUDGE McDADE: DR. HOPENFELD: Yes. I gave you a number like
6.0 I believe where I took two points on an elbow and the ratio was 6.0. MS. SUTTON: Kathryn Sutton for the
Your Honor, I understand this is not in
whether it's in evidence or not. MS. SUTTON: And if we could get some
more information as to what the witness is referring to that would be very helpful. JUDGE McDADE: what he's referring to. MS. SUTTON: JUDGE McDADE: Same here, Your Honor. So that's what I'm trying I didn't have any idea
So could you just repeat it, Dr.
elbow and I have a number here showing a ratio of 6.0. JUDGE McDADE: Right. But where is
Page 1581 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
right. JUDGE McDADE: DR. HOPENFELD: You gave some specifics. The grid is labeled as that? DR. HOPENFELD: Well, I can -- All
FWO31B08E UTM whatever that means. MS. BRANCATO: Your Honor, this is I believe Dr.
Deborah Brancato for Riverkeeper.
Hopenfeld is referring to a document that Riverkeeper received in discovery. It should have
an Entergy Bates stamp on the bottom. JUDGE McDADE: we just move on from this. Okay. Perhaps why don't
We're going to break for And at that point in
lunch in about a half an hour.
time if we can try to identify the specific document that Dr. Hopenfeld is referring to and we can make determinations based on that. Dr. Hopenfeld. DR. HOPENFELD: evidence right here. I do have one in
It's the next one, the one
that came up following this grid that is in evidence or it's not evidence in the presentation. in evidence, too. please? Oh, it is
Could you give me the next one
The next figure with the one inch pipe.
The next figure, the following.
Page 1582 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
No, that's the prior one. Yes, that's the one. The next one.
That one the ratio on this That's a one inch pipe. What does this -- I
particular pipe is 2.83.
JUDGE WARDWELL:
don't even know what this ratio is that you're calculating. DR. HOPENFELD: the presentation. JUDGE WARDWELL: yet and it needs to -DR. HOPENFELD: presentation. JUDGE WARDWELL: Before we get into It's in the This is not in evidence Okay. I defined it in
that, let's drop back and see whether or not you can provide something and come back to us after lunch. DR. HOPENFELD: JUDGE WARDWELL: Sure. And then we'll decide
whether or not these types of things are in there would be my suggestion, Mr. Chair. JUDGE McDADE: Yes, and just so the
record is clear since we have taken a quick look at this this is an excerpt from what has so far been marked as Board Exhibit 000002 for identification. And I'm not really certain. of that, Mr. Wilkie. It's about page seven
Page 1583 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: It's ten. Ten. So we at least know
what was shown on the screen here and then we'll come back and revisit this after the break. MS. SUTTON: Your Honor, may I ask that
Ms. Brancato just repeat the Entergy disclosure Bates number on the bottom of the page that was referred to earlier? JUDGE McDADE: She can do that and get
back to you when we have the break. MS. SUTTON: Thank you, Your Honor. MR. MUSEGAAS: after the break. We'll take care of that That would be appreciated.
Thank you. Your Honor, this is
MS. BRANCATO: Deborah Brancato.
Just to clarify, Dr. Hopenfeld is That
referring to what's on the screen now.
excerpted graph is from an exhibit Riverkeeper 000049 that is in evidence just to clarification. MR. FAGG: Just to further clarify, it That was the
was admitted for a limited purpose. order of yesterday. MS. BRANCATO:
Your Honor, just to
respond to that, the PowerPoint presentation was admitted for limited purpose. But Riverkeeper
Page 1584 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
000049 is just an exhibit that Riverkeeper submitted. JUDGE McDADE: What I'm understanding
you to say is Dr. Hopenfeld used that particular graph, put it in his PowerPoint presentation which at this point hasn't been received. been identified for identification. But it's only That graph
itself was taken from Riverkeeper Exhibit 000029 which -MR. MUSEGAAS: Exhibit 000049. JUDGE McDADE: MR. MUSEGAAS: 000049. It was excerpted from Sorry, Your Honor. It's
that exhibit for the PowerPoint. JUDGE McDADE: MR. ALEKSICK: for interrupting. Okay. Thank you.
Your Honor, I apologize
This is Rob Aleksick for the
Applicant over here. JUDGE McDADE: MR. ALEKSICK: the Court a bit of time. Okay. I'm sorry. This may save
I'd just like to point out
that Riverkeeper 000049 that we're discussing here is of a small bore component and we're discussing it in the context of CHECWORKS when, in fact, this component is not modeled in CHECWORKS. So I would
Page 1585 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
just like to point that out. I don't know how
useful this example will be in discussing the adequacy of CHECWORKS because it's not a CHECWORKS modeled component because it's a small bore component. JUDGE WARDWELL: I'm not sure where we It's just part of But we'll
started this discussion earlier.
FAC overall or whether it was CHECWORKS. take that. Thank you. JUDGE McDADE:
And part of this, Dr. We're
Hopenfeld, we don't mean to cut you off.
going to break for lunch in about a half an hour or a little bit less and during that period of time if there's another example. And I realize that it's There are 1400
difficult for you as well as for us. exhibits in evidence here.
To go to a specific But if there is
exhibit at a moment's notice.
another exhibit that you want to refer us to to help explain your position we can do that after lunch. You don't need to do that right now. DR. HOPENFELD: Can I just make a It doesn't
comment in regards to this exhibit?
matter whether it's modeled or not modeled FAC. That wasn't my point here at all. My point here on this particular one is
Page 1586 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
confused. that the ratio -- Whether it's modeled or not, it doesn't really matter. The ratio indicates that
this is not a mass transfer-controlled phenomenon and that's what that F1 relies on. issue. That is my
Whether they modeled it or not has nothing
to do with that. JUDGE McDADE: DR. HOPENFELD: You said mass transfer. Mass transfer, correct.
Mass transfer-controlled phenomenon is something that is directly related to the corrosion rate to what you see in the wall thinning. If it's a
diffusional type of a control the oxide layer is there. control. It's a slow process. It's a mass transfer I have no
We know how to calculate it.
problem with that. JUDGE KENNEDY: DR. HOPENFELD: Now you've -But I'm trying to tell
you is that this component, the other component, other components, all show that it is not and that's the only point. Whether they modeled it or not
modeled it has nothing to do with my point. JUDGE McDADE: JUDGE KENNEDY: Thank you. Now you've got me As soon
I was tracking you pretty good.
as you bring up the F factors, are we not talking
Page 1587 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: DR. HOPENFELD: What's the issue? -- independent of my about the modeling in CHECWORKS? DR. HOPENFELD: JUDGE KENNEDY: Yes. And didn't Mr. Aleksick
just say they don't use CHECWORKS to predict the wear rate for this component? DR. HOPENFELD: Yes. And all I'm saying
point, forgetting about CHECWORKS or anything else. This shows that the process is not controlled, whether they control it or not, because the diameter is small that maybe they can't fit it in. doesn't matter. My point here is that the process itself or the whole concept that CHECWORKS is built on is not necessarily mass transfer-controlled under complex geometries. That's my point. Whether they But it
use this particular component in the line or not is not really my point. JUDGE KENNEDY: Is the concern that
Entergy would not select an inspection location in sufficient time to prevent loss of intended function? DR. HOPENFELD: That's the bottom line.
Page 1588 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
bit, too. JUDGE KENNEDY: So I guess, Mr.
Aleksick, you've now termed this particular set of components as a non-modeled line. Help us
understand how the inspection location would be selected for these types of locations if that's the right way to phrase it. Do you understand Dr.
Hopenfeld's concern about the wear rate and whether you're going to be able to inspect it in sufficient time? MR. ALEKSICK: picture concern. entire argument. JUDGE KENNEDY: I'm struggling a little I understand the big
I confess I don't follow the
And I viewed it as a CHECWORKS argument But
and then we would address it down that path. it's clear that this is not in that arena.
Maybe you could help us understand a little bit how locations are selected for inspection in the non-modeled regions. And I think we've And I was just
addressed this a little earlier.
going to bring up the inspection location selection discussion. So if we'd rather do it then, then
we'll start down that path. MR. ALEKSICK: Perhaps I could give a
brief answer and if Your Honor would like to go
Page 1589 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
deeper now or later we can do that. First, I would
just like to point out that the title of this slide is -- the first word of this title is "CHECWORKS." So that's the basis for my belief that this figure relates to the adequacy of CHECWORKS. With respect to the method used to select susceptible non-modeled components, again these are susceptible to FAC but not modeled within CHECWORKS. We have the SNM ranking analysis which essentially provides a ranking from most concerned to lowest concerned. And as part of the every cycle
selection process for identifying the FAC inspections, that document is reviewed using guidance originally from NSAC-202L as implemented through EN-DC-315 to select a representative set of components from that ranking. And if we wanted to get into more detail, I suggest that perhaps another member of the panel could give you more information on that. JUDGE KENNEDY: And I think a couple In terms
questions came to mind as you said that.
of this non-modeled ranking process, how long has that been in place at Indian Point? How long has
this process or selection technique been used?
Page 1590 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
failures. Azevedo. MR. ALEKSICK: I guess it's fair to say
that the idea of selecting non-modeled components for inspection has been around for a long time. But
it became more formalized I think it was in 2005 or so, give or take a year, when these ranking analyses were first prepared in a very formalized and detailed manner. I might point out for the record
that the criteria and guidance on preparing those non-modeled rankings is contained in Appendix A of NSAC-202L. JUDGE KENNEDY: And I guess the other
question that came to mind is were there any failures in the non-modeled piping that occurred say since the inception of this ranking process. MR. ALEKSICK: I think a different
member of the panel would be better equipped to answer that question. JUDGE KENNEDY: MR. AZEVEDO: And that's fine. Your Honor, this is Nelson
Are you talking about Indian Point or? JUDGE KENNEDY: I'm sorry. I'm talking
about Indian Point specifically. MR. AZEVEDO: We have not had any
We've had leaks as has been mentioned
before but not --
Page 1591 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
sorry. MR. AZEVEDO: structural failures. We had leaks, but not JUDGE KENNEDY: You had what? I'm
Not failures of the pipe. And again this
JUDGE KENNEDY:
distinction is whether you have lost the intended function. Is that it? MR. AZEVEDO: JUDGE KENNEDY: Yes, that's correct. I guess before I got off
on this tangent I wanted to come back to Dr. Hopenfeld's rebuttal testimony and this is going to take us back to CHECWORKS. I noted in your
testimony that you had indicated that you believed that CHECWORKS was the primary tool for selection of inspection locations. And (a) I would like to
confirm that and (b) get a little bit of your perspective on why you feel that way. DR. HOPENFELD: Well, because they
testified that 25 percent of the time or 15 percent of the time they use it to select locations. what they said. JUDGE KENNEDY: or 15 percent? DR. HOPENFELD: Well, there is a 25 or But then they split Did you say 25 percent That's
22-25 number in those figures.
Page 1592 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
quick. DR. HOPENFELD: Very quick. You see my it and they say half of it is for frequency and half of it is for identified location. couldn't make it out what is what. And I really But I assume
that 22 percent that's all they use CHECWORKS in there. If I may just digest for a second if it's okay with you because just before I forget about that it's about that non-modeling comment Can I make a
that we just talked a minute ago. comment on that? JUDGE KENNEDY:
If you're going to be
point here that no matter what it is that and I kept repeating it that if it's a mass transfer-control you can figure out whether it's a linear time or what happened or whatever. But it's not mass
transfer-controlled if it's not a dissolution type. But if it's an erosion type all bets are off because you don't know how long it's going to be. And whether it's model or non-model you cannot tell by trending alone which is how they do it. You cannot tell whether it's linear or nonThat is my
linear and what's going to happen to it. point. Locally. That was my point.
Page 1593 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: I don't know. Maybe you
should comment on Mr. Azevedo's statement that at least since 2005 they used an inspection process selection that has not resulted in a loss of any intended function. DR. HOPENFELD: comment on that? Yes. Can I make a
The code doesn't say whether you
have to wait until that thing blows up or leaks or whatever. The code says you meet those requirements
to prevent that thing from happening. JUDGE KENNEDY: Wait. Whoa. Let's go -
- We're in licensing renewal. DR. HOPENFELD: JUDGE KENNEDY: renewal issue. Sorry. This is a license
And the issue as I understand it
would be loss of intended function which they have testified that since at least 2005 there have been no incidents where the intended function has been lost in this non-modeled piping. DR. HOPENFELD: How would you know? How do you know You
You've got thousands of components.
what the thickness is of those non-modeled? don't know. You didn't sample it. JUDGE KENNEDY: DR. HOPENFELD: I'll let Mr. --
That's a statement
Page 1594 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
structure. DR. HOPENFELD: JUDGE McDADE: Correct. And we've heard testimony that's not backed up. JUDGE KENNEDY: I think and I'm going to
let Mr. Azevedo clarify this, as I understood it, this is based on operating experience of leaks at Indian Point that were detected, didn't result in a loss of intended function. saying? MR. AZEVEDO: a question in there? Yes, Your Honor. Is there Is that what you're
I couldn't -I guess to confirm that.
JUDGE KENNEDY:
That's the way I understood your testimony. MR. AZEVEDO: JUDGE McDADE: Yes, that's correct. Excuse me one second.
Dr. Hopenfeld, just again to make sure I understand your testimony. looking at -DR. HOPENFELD: JUDGE McDADE: This one. -- is a non-modeled The particular exhibit we've been
that it's a non-modeled structure because of the diameter of the pipe. modeling criteria. Your use of it as an example is because It doesn't fit within their
Page 1595 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 view the phenomenon of flow-accelerated corrosion would operate the same regardless of the diameter of the pipe. So therefore -- More or less.
So therefore this is a good example that you're saying it is not just corrosion. It is corrosion
plus erosion and that you think that this demonstrates that the view of Entergy that it's either or is not supported by the evidence in the field. This is evidence that you can have both at
the same time because as you view this exhibit it demonstrates the existence of both at the same time. And then you would interpret that if it exists here it would exist in the other system. DR. HOPENFELD: JUDGE McDADE: summary of your testimony? DR. HOPENFELD: Your Honor, I would like I couldn't Yes. Is that an accurate
to say there's a defect in my education. say it better. JUDGE McDADE:
It's not a question
whether you could say it better. DR. HOPENFELD: answer is yes. JUDGE McDADE: Okay. I just want to I just say yes. The
make sure I understand what your testimony is.
Page 1596 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. JUDGE WARDWELL: To fix a point we just DR. HOPENFELD: You perfectly understand
got off of a little bit, I'd like to back up just a bit to get back to it and that is the statement that -- Well, it's on page 10 of your rebuttal testimony. So I can be specific because I would like to explore that just a little bit more while we're there. If
we could pull up that and it's Riverkeeper 000108, page 10. While that's being pulled up, I'll mention -- let me know when it's up. Okay. If you
notice at the bottom of the first full paragraph, the second paragraph there and the sentence there, the very last sentence it says "It appears that the total CHECWORKS contribution to the FAC Program is about 25 percent with less than half of that amount being attributed to actual wear predictions and inspection schedules with the balance providing relative ranking." That's your testimony.
So when we take half of that 25 percent, that brings us down to about 12.5 percent are really associated with any wear prediction or inspection schedules. We'll talk about this statement a little
bit more later on today.
Page 1597 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 you also make a statement several times in your testimony that it's non-conservative 50 percent of the time. That means it's
conservative the other 50 percent of the time. DR. HOPENFELD: JUDGE WARDWELL: Yes. So if we take 50
percent of that 12.5 percent, that's 6.25 percent of what's left over. DR. HOPENFELD: JUDGE WARDWELL: Yes. And so are you saying
therefore that the 6.25 percent of the aging management effort will be attributed to the nonconservative estimates of CHECWORKS is a significant parameter? DR. HOPENFELD: The reason I brought it
up is because we were focusing on CHECWORKS where it's really a small part of the whole program instead of focusing on other parts. JUDGE WARDWELL: Right. And you
conclude that the 6.25 percent is a significant percent of Entergy's program. DR. HOPENFELD: CHECWORKS, yes. Assume with respect to The
Well, not only that.
Regulation 1801 said no very clearly, the last revision. You cannot be non-conservative. It has
Page 1598 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 be conservative. JUDGE WARDWELL: convolute things. Please let's not
If we keep them a single issue
items, we may get through some of this before the end of next week. DR. HOPENFELD: JUDGE WARDWELL: DR. HOPENFELD: JUDGE WARDWELL: do it up here. same thing. DR. HOPENFELD: JUDGE WARDWELL: I'm glad you said that. Somehow we're going to Okay. Maybe not though. All right. I apologize. No, it's too easy. We do the We
So it's not just you.
have to get our arms around getting through some of this. You then go on to say in the next line down Scroll
that -- Go a little bit further down, Andy. to the very bottom.
And I'm starting with the second line, a couple of things in it. It says, "The relative
guidelines in GALL and NSAC clearly emphasize that the use of quantitative predictions of a computer code such as CHECWORKS is a main tool to predict wall thinning." And my question to you is where do
you believe that those documents say they clearly emphasize that CHECWORKS is the main tool to manage
Page 1599 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. Right? DR. HOPENFELD: JUDGE WARDWELL: DR. HOPENFELD: mention other tools. JUDGE WARDWELL: But I then said and I Yes. You are agreeing? Agreed. They did through -JUDGE WARDWELL: Wait. Did you say yes? other tools. flow-accelerated corrosion. DR. HOPENFELD: One, if you go to 1801,
it mentions check points in different places, I guess, acceptance criteria, a trending and -- So you get the flavor that that's what's being used. JUDGE WARDWELL: other tools in that document? DR. HOPENFELD: There is no -JUDGE WARDWELL: So it doesn't clearly Yes, it did mention Does it mention any
emphasize that CHECWORKS is a main tool, does it? DR. HOPENFELD: Right. Then you read
don't think you heard so those documents don't clearly emphasize that CHECWORKS is the main tool. DR. HOPENFELD: JUDGE WARDWELL: Yes, yes. You agree with that
Page 1600 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: GALL and NSAC. So are DR. HOPENFELD: JUDGE WARDWELL: DR. HOPENFELD: the others -JUDGE WARDWELL: DR. HOPENFELD: JUDGE WARDWELL: DR. HOPENFELD: Go ahead then. There are the 202. Yes. If you read it in Yes, yes. Okay. Thank you. But
Those documents.
context, okay, it doesn't say 50 percent here, 10 percent here, 30 percent here. In the context, it
says that the flavor of it is that you rely on CHECWORKS as a predictive tool. everything around it. If you read the LRA, they -JUDGE WARDWELL: We're focusing right on The grid,
this statement here in your testimony. DR. HOPENFELD: Okay. That's what I'm -
you saying now that it's better to use the word it has the "flavor" that CHECWORKS is the main tool rather than "clearly emphasized"? This is a pretty
strong statement is why I'm saying this. DR. HOPENFELD: JUDGE WARDWELL: Yes, CHECWORKS -It says "clearly
Page 1601 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
testimony. testimony. from it. JUDGE WARDWELL: JUDGE KENNEDY: Okay. Thank you. that. DR. HOPENFELD: That's what I concluded emphasized." DR. HOPENFELD: There was no clear
definition in NUREG-1801 that says CHECWORKS is the main tool. There is none in 202. JUDGE WARDWELL: But there's a flavor of
I guess at this point
the path I was going to go down is to call up an Entergy exhibit about how they select inspection locations. And, Andy, I'm thinking of Entergy Try PDF page 53. Right.
000029, page 53 and 54. That's it, Andy.
JUDGE WARDWELL:
Judge Kennedy, could
you repeat what this document is? JUDGE KENNEDY: JUDGE WARDWELL: JUDGE KENNEDY: is on PDF page 53. JUDGE WARDWELL: Is that correct? JUDGE KENNEDY: This is the direct So this is the direct This is Entergy 000029. Okay. And it's Figure 1 which
And I guess I would ask that someone
Page 1602 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. JUDGE WARDWELL: it goes up the bar. And we go to the right from the Entergy side could walk us through this graphic and what it's import is. MR. ALEKSICK: the Applicant. Honor. JUDGE KENNEDY: little bit with the colors. go through this. And I am struggling a That's why I wanted to This is Rob Aleksick for
I would be happy to do that, Your
The blues I'm not sure I got --
And maybe I'm evidencing some color blindness. MR. ALEKSICK: difficult to distinguish. a slightly lighter blue. JUDGE KENNEDY: Yes. I guess if you I agree that it's There's a light blue and
could somehow point this when we discuss CHECWORKS which component here is CHECWORKS. JUDGE WARDWELL: And can I just clarify If we start
so we can answer it for me at least?
from the left on the bottom code it says CHECWORKS. That's also the lowest thing on the charts. correct? On each bar? MR. ALEKSICK: That is correct, Your Is that
Is that correct? That is correct.
MR. ALEKSICK:
Page 1603 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
then. JUDGE KENNEDY: Thank you. MR. ALEKSICK: JUDGE KENNEDY: Sure. And then maybe from that That will work for me
point let's talk about this figure. MR. ALEKSICK: Certainly. This figure
represents for Unit 2 the last five outages and for each one of those five outages we had a set of inspections approximately 100 components per outage, although sometimes it may be more and sometimes it may be slightly less. The bottom, the darker blue, of each of those bars, each of the five bars, represents the number of new CHECWORKS components. That is
components in the plant modeled in CHECWORKS that have not been inspected before. And you ca see that
it varies, but it's generally between one-quarter and one-third of the total. JUDGE WARDWELL: And refresh my memory.
Why would have CHECWORKS come up with these as being critical to be inspected again? MR. ALEKSICK: I don't know that I would
call them necessarily critical to be inspected. JUDGE WARDWELL: MR. ALEKSICK: Okay. Not in the sense of an
Page 1604 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
imminent pipe wall failure. JUDGE WARDWELL: MR. ALEKSICK: But we selected -Points of interest. Points of interest, I We select
agree with that characterization.
components from CHECWORKS primarily for two purposes. One is if we believe that there may be If there is
degradation present in that component.
actually flow-accelerated corrosion going on, those would be from analysis lines in CHECWORKS that are well-calibrated typically. Another reason that we might select a component to inspect from CHECWORKS is to improve the calibration. One of the guidelines from NSAC-
202L and from the CHECWORKS users guide and various other documents there's guidance out there that discusses the criteria one must meet in order to calibrate a CHECWORKS line. And one of those
criteria is to have a minimum number of inspections, three, four, five, six, ten, depending on the circumstances. Another criterion is we need to have a variety of geometry types. So if we have 100
component analysis line but we've only inspected elbows, even if we've inspected all of the elbows, we would not consider that line calibrated until we
Page 1605 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
one. Thank you. MR. ALEKSICK: stacked bars. The second bar, these are also looked at other geometries. Does that answer Your Honor's question? JUDGE WARDWELL: That was very good.
So the bottom section represents the The red section of the And so Indian
new CHECWORKS inspections.
bar represents operating experience.
Point has a formal process of collecting operating experience from a large variety of sources including NRC information notices and other regulatory documents, INPO documents, participation in the CHUG users group and on and on. And there is a formal process by which that information is collected, reviewed, dispositioned. And the disposition may include a
decision to not inspect if there's no good reason to do so. Or often it will include the disposition
will be "Oh, we should inspect this" regardless of anything else. area. Someone else had a problem in this And that's
So we're going to look at it.
what the red bar constitutes here. The next bar above that is the green That is the set of components that have been It may have been inspected
previously inspected.
Page 1606 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
No, I'm not. two years ago and it may have been inspected 25 years ago. Well, 20 years ago. And at the time of the last inspection, an evaluation was done. And one of the inputs of
that evaluation was the re-inspection frequency. And Your Honors can see that that's generally about half of the inspection scope. JUDGE WARDWELL: And all of those were
generated, all those locations were generated, because that calculation said it needed to be reinspected at this time. MR. ALEKSICK: JUDGE WARDWELL: MR. ALEKSICK: Yes, Your Honor. Thank you. Every single inspection
goes through that evaluation process regardless of whether it's CHECWORKS or not. The purple bar second from the top are the susceptible non-modeled components. bore. Not always small bore. Often small
And those you can see
constitute between 15 and 25 percent on average. Sometimes a little bit less. And then the last bar, the -JUDGE WARDWELL: Sorry to interrupt. Does that mean
Let me interrupt.
there are no non-modeled ones in the re-inspections?
Page 1607 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
Exactly. JUDGE McDADE: And the one at the things. That doesn't include ones that might be in the reinspections. Is that correct? MR. ALEKSICK: That is correct. The re-
inspection category includes susceptible non-modeled as well as everything else. JUDGE WARDWELL: And engineering
judgment, operating experience, CHECWORKS things. MR. ALEKSICK: JUDGE WARDWELL: No CHECWORKS things. MR. ALEKSICK: let me back up. Yes, that's right. Well, Yes. In other words --
No, not CHECWORKS
Once a component has been
inspected, regardless of the original reason for the inspection, it could have been CHECWORKS or anything else. Then it's outside of those silos and -- I see I understand. JUDGE McDADE: non-modeled components. MR. ALEKSICK: Yes, Your Honor. So the purple is new,
your point.
bottom, the blue, is the new CHECWORKS identified. MR. ALEKSICK: JUDGE McDADE: Yes, Your Honor. And in between the green
are re-inspections both that had originally occurred
Page 1608 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? JUDGE KENNEDY: It does. Thank you. as the result of CHECWORKS and those that had occurred in non-modeled components. MR. ALEKSICK: JUDGE McDADE: Exactly, Your Honor. Okay. And then the
operating experience could be either modeled or unmodeled. JUDGE WARDWELL: MR. ALEKSICK: Yeah, but will be new. Right. Occasionally, a
component may be in multiple categories. JUDGE McDADE: are new inspections. But in any event those
The operating experience are
new inspections but they could be either modeled or non-modeled. MR. ALEKSICK: That is correct. And the
top bar is the engineering judgment bar.
And those
are components that may be added to the scope for reasons other than what we've already outlined. So
the FAC Program owner has the discretion to expand his scope of its inspections based on judgment. Does that answer the question, Your
I guess, Dr. Hopenfeld, in the context of the primary tool being CHECWORKS and this inspection location percentage, do you have any
Page 1609 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
particular comments you'd like to address to the Board? DR. HOPENFELD: I do not. Evidently,
CHECWORKS is used -- It's not the primary tool for inspection. JUDGE KENNEDY: JUDGE McDADE: Okay. Thank you.
Actually, Mr. Aleksick,
I've got a question and approximately half as you go through it are these previously inspected components. And they can be identified either
through CHECWORKS or through prior operating experience or prior engineering judgment or could be non-modeled. Is there any way of estimating what
percentage of those were initially identified for inspection through CHECWORKS? MR. ALEKSICK: are two ways. Yes, Your Honor. There
One is I could give you a rough The other if the
estimate right now if you'd like.
Court would like a more precise answer, each one of these components has a very detailed, traceable history and we can go back and answer that question very precisely if you'd like. JUDGE McDADE: Based on your experience,
can you give us an approximate percentage? MR. ALEKSICK: Roughly half.
Page 1610 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: MR. ALEKSICK: Half of the half. Yes, exactly. Maybe as a
point of clarification, if one goes earlier in the plant inspection history, that percentage would be larger. JUDGE WARDWELL: But the reason it's in The reason it's
there isn't because of CHECWORKS.
being re-inspected isn't necessarily because it's a CHECWORKS-derived initial inspection point. MR. ALEKSICK: Yes, Your Honor. The re-
inspection time is independent of CHECWORKS or anything else and relies only on the wear evaluation that we discussed earlier. JUDGE WARDWELL: So is there any
significance that you can think of in regards to the breakdown of those different initial origins of how a location was selected falling into the reinspected category? Did I convolute that question
as I tried to word it? MR. ALEKSICK: I think I understand what
Your Honor is asking and I would say that there's nothing magical about the breakdown. What we do is
we use a variety of techniques in a combined and complementary manner that in accordance with NSAC202L and GALL that gives the best coverage, the best
Page 1611 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. JUDGE KENNEDY: And does it assume a I mean, going inspection coverage, of all of the systems. We use
the right tool within the program for the right job to provide reasonable assurance. JUDGE KENNEDY: As far as the re-
inspection, did I understand you to say the wear rate is based on measured data and it's not a predicted value? MR. ALEKSICK: Yes, Your Honor. That's
linear over time relationship?
forward, is it linear, the wear rate? MR. ALEKSICK: Yes, Your Honor. JUDGE KENNEDY: MR. ALEKSICK: Generally? It may not be true in the That is true in general.
case where we know there was a change in operating conditions. JUDGE KENNEDY: I see.
(Off the record comment.) JUDGE KENNEDY: Probably is. May I ask
one more question before we break? not.
No, I'd probably We can
It will probably open a can of worms.
save it for later. JUDGE McDADE: It's now about 12:15 p.m.
Page 1612 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
Sipos. Honor. JUDGE McDADE: take the lunch break? MR. SIPOS: Your Honor, this is John Anything else before we It may be a good time to break for lunch until 1:15 p.m. MS. SUTTON: for the Applicant. to predict. Your Honor, Kathryn Sutton
I realize this may be difficult
Any guesstimate, estimate, on the SAMA We have them here today. Should we
panel members?
be retaining them here? with SAMAs today? JUDGE McDADE: answer right after lunch. MS. SUTTON: JUDGE McDADE:
Do you think we will begin
We will give you an
Thank you. Based on the time that
it's taken so far I have sort of a gut reaction. But I'd like to talk to my colleagues about it and we'll let you know right after the lunch break on that. MS. SUTTON: Much appreciated, Your
You asked at the outset of this morning's
proceedings about the State's positions on NRC Exhibits 000165 and 000166. opportunity to review them. We've had a brief And at this time, the
Page 1613 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
State does not object to NRC offering and introducing those exhibits. I would suggest that the description reflect that they are actually excerpts of larger documents. JUDGE McDADE: Okay. And there being no
other objections to the admission of NRC Staff Exhibits 000165 and 000166. MS. SUTTON: JUDGE McDADE: admitted then. (Whereupon, the above-referred to documents marked for identification as NRC Staff Exhibits 000165 and 000166 were received into evidence.) And we will also then admit the revised exhibit list of the staff with the notation that these are not the entire documents, but are excerpts from the documents, both 000165 and 000166. (Whereupon, the above-referred to document revised and marked for identification as NRC Staff Exhibit 000001 was received into evidence.) No objection, Your Honor. That they will be
Page 1614 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
order. And with that we will break for lunch and we will be back. It's now about 12:20 p.m. So We
why don't we come back at 1:20 p.m. from lunch. are in recess. Off the record.
(Whereupon, the above-entitled matter was recessed at 12:18 p.m. to return at 1:20 p.m. the same day.) JUDGE McDADE: The hearing will come to
There are a couple of preliminaries before The first has to do with the
we get started on it.
proposed settlement agreement with regard to Riverkeeper Environmental Contention 3. The Board will approve the settlement agreement, with the addition of the paragraph that we discussed earlier today, that Entergy and the parties agreed to with regard to subject matter jurisdiction. We will get a written order out on that later in the week. But for the purposes of the
parties, they can anticipate that we will not be hearing Riverkeeper Exhibit, Environmental Contention 3, that that is no longer on the schedule. The next question had to do with our current schedule, and to advise witnesses. We can
Page 1615 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
Dean. MS. DEAN: You're welcome, thank you. the State. anticipate that Riverkeeper Technical Contention 2 will take us at least the remainder of the day. So
therefore, if there are witnesses here with regard to New York Contention 12, those witnesses can be released for today. We are hopeful that we will be able to start with them first thing in the morning, hopeful but not necessarily over-confident. In any event,
we believe that we will not get beyond New York Contention 12 tomorrow. So therefore, those witnesses who would begin testifying on New York Contention 16 need not be here tomorrow. They can be here on Thursday
morning, because we're confident that we won't get beyond New York State 12 tomorrow. MS. DEAN: Your Honor, Janice Dean from I just want
Mine doesn't have a light.
to let you know and let the parties know that momentarily they will be seeing my motion to correct the testimony on Contention 5 come across the EIE. It's nothing more than a clarifying motion to strike our earlier exhibit and file a corrected exhibit. JUDGE McDADE: Okay. Thank you, Ms.
Page 1616 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. TURK: Your Honor, one more question Sherwin Turk.
about the schedule, if I may. JUDGE McDADE: MR. TURK: Yes.
We have witnesses who will be
flying in from Washington on buried piping, New York 5, which comes up after New York 17 and 37, property values and no action alternative. Is it safe to
assume that we won't reach buried piping this week, and I can tell them to come next week? JUDGE McDADE: than safe assumption. tomorrow, I think that is a more
If we get through New York 12
New York 16, 17 and 37, I don't think any
of those three are going to take the amount of time that we have spent on Riverkeeper Technical Contention 2. But at the same time, I think between, among those three, 16, 17 and 37, if we get started on those on Thursday morning, if we get done with all three of them. It will certainly be late in the
day, and therefore given the fact that it will be a travel over the weekend and coming back, I think it would be advisable to tell the individuals who will testify on New York State 5 that they should be available and ready to go nine o'clock Monday morning.
Page 1617 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 the schedule changes, and I don't think the schedule will appreciably speed up; but if the schedule slows down any, we will advise you of that as soon as possible. MR. TURK: Thank you. I appreciate
Thank you, Your Honor. JUDGE McDADE: (No response.) JUDGE McDADE: JUDGE KENNEDY: Judge Kennedy. This is Judge Kennedy. Anything further?
I guess I'd like to start with an exhibit, and if we could have Riverkeeper 111. All right, thank you.
Dr. Hopenfeld, this is an exhibit that you've provided for Riverkeeper. Indian Point data here. There appears to be Was this just extracted?
I mean I'm trying to avoid putting an Entergy exhibit up here. I want to confirm that
this is Indian Point-specific data, which is what it appears to be. DR. HOPENFELD: JUDGE KENNEDY: opinion from Entergy? Yes. Is there any different
Can you tell? This is Rob Aleksick for
MR. ALEKSICK: the applicant.
Yes, Your Honor, that looks -- this
is Indian Point-specific CHECWORKS output.
Page 1618 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: All right. I would like
to spend some time going through this figure, and I think it would be best to start with someone from Entergy, to walk us through this, and talk about the highlights of what is the plus 50 percent line, the minus 50 percent line? factor? What is a line correction How is it calculated?
How is it computed?
If there's any outlier data on here that we heard, that was described yesterday in the testimony, maybe we could talk a little bit about that. So maybe if someone from Entergy would like
to walk through this, and then we'll have a number of additional questions about this figure. MR. ALEKSICK: Certainly, Your Honor. I'd be
This is Rob Aleksick for the applicant. happy to discuss that with you.
If Your Honor would
give me just a moment to pull up the documentation. JUDGE KENNEDY: (Pause.) MR. ALEKSICK: patience, Your Honor. Thank you for your That's fine.
The exhibit that we're
looking at is what we call a scatterplot, which is one of the outputs that CHECWORKS provides for each of the analysis lines. JUDGE KENNEDY: Is this further
Page 1619 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
representative of the -- I mean as I understand it, there's a number of these plots all through the exhibits. Is this a good example to walk through,
to be typical of a scatterplot? MR. ALEKSICK: Well, this would be a
good example of a scatterplot that shows not particularly good agreement between predictions and observations. So if that is what you all would
like to walk through, then yes, this would be a good example for that. JUDGE KENNEDY: Part of the motivation
for selecting this is on the next page, I have Dr. Hopenfeld's redo of this data. So we're going to
have an opportunity to go back and forth, using a similar set of data. you know. This would explain to us what is involved in the scatterplot, and what important information is gleaned from it. MR. ALEKSICK: I think this would be a So if this at least typical,
good exhibit of that discussion, yes Your Honor. This is, as we mentioned earlier, there are approximately 40, four-zero, analysis lines per unit. This is one of those for Unit 2. This happens to be for the third point
Page 1620 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
extraction steam analysis line. phase lines. So these are two
A mixture of steam and water is being The first thing I
transported through these pipes.
would like to call your attention to is that the graph is a plot of predicted wear on the vertical axis, versus measured wear on the horizontal axis. So for example, if we take the point, the most upper left-hand point just for discussion, that looks as though the predicted wear is on the order of 220 mils, and the measured wear for that component is on the order of 20 to 30 mils. JUDGE WARDWELL: And just to highlight,
to make sure we're all on the same page also, that the scales for the vertical and the horizontal are different; is that correct? We're measuring the One's
same thing, i.e., mils, mils of wear. predictive, one's measured. wear.
But it's still mils of
You chose not to keep the same scale, but in fact changed the scale for the vertical and the horizontal. MR. ALEKSICK: It is correct, that the
vertical and horizontal scales are different measurements. This is a stretchable graph in the
CHECWORKS output, and one can grab and size it and
Page 1621 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 that way. on the page. JUDGE WARDWELL: There would be some make it square or rectangular. be rectangular, yes. But there's no particular reason to do It's just, that's just the way it fit This one happens to
reasons to keep them square in regards to visually seeing something like the middle line. proceed. MR. ALEKSICK: I agree. A square might But let's
-- if we were making judgments visually, a square would be preferable. However, we have quantitative
methods to assess the calibration status. So we have vertical and horizontal axes for the measured wear. Each point plotted So again, take the upper
represents an inspection.
left-hand corner as an example, that represents a single component, probably one to two hundred actual wall thickness measurements were taken on that component. The data from that grid was reduced to a single representative value of measured wear, and that was compared to the CHECWORKS predicted wear for the component, and then the plot, I'm sorry, the point was then plotted.
Page 1622 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. JUDGE WARDWELL: And there's no
duplicates of measurements at that particular point; is that correct? MR. ALEKSICK: That is correct. Each
point on the graph represents a single component, and in fact represents the most recent inspection of that component. One other thing I would point out
is that the diamond-shaped points represent components that are physically installed and operational, as of the time of analysis. The square-shaped points represent components that were replaced at some point in the past. So they were presumably, they were physically
replaced, presumably because they were degraded by FAC, severely enough to require replacement. JUDGE McDADE: I'm not sure that I
The square, does that component, is it For example,
removed at the time you're looking at? the one in the lower right.
You have predicted wear
of about 75 mils, actual wear of 200 mils. You're saying that at the time it was tested and found to have 200 mils of wear, that component was already out of the facility, or was it taken out of the facility? Or was it taken out
because it had 200 mils of wear?
Page 1623 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: Presumably, it was taken
out because of that wear, and that may have been 10 or 15 years ago. The data on this plot goes back to
1992 or thereabouts. JUDGE WARDWELL: wear up to this point? MR. ALEKSICK: JUDGE WARDWELL: That is correct. And do you carry forth So this is cumulative
that wear once it's been replaced, and still keep it to that component? MR. ALEKSICK: Yes. Once a component is
physically removed from the system, its historical data is retained, because that's good calibration data. But of course there is a new physical
component in its place that is typically subject to inspection, although it may have been replaced with upgraded material that is immune to FAC and perhaps not inspected there, because of that. MR. COX: Cox for Entergy. I'd like to -- this is Alan When we say
I'd like to clarify.
"cumulative wear," I think Rob means cumulative up to the point of when that measurement point was taken? We may have points that were measured 10, 15 That was the wear at the point of the
years ago.
measurement, the time of the measurement.
Page 1624 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. -(Simultaneous speaking.) JUDGE WARDWELL: it, you confused me. JUDGE McDADE: The wear at the time of --the way you clarified MR. ALEKSICK: JUDGE WARDWELL: That is correct. I'm sorry. I'm afraid
the most recent measurement. JUDGE WARDWELL: And the prediction is
what would be predicted at that time as well? MR. ALEKSICK: At that time, yes. Yes,
The CHECWORKS model is a function of
time, and so some of these inspections might have been from 1992, and the wear measured at that time would be compared to the wear predicted at that time and plotted. JUDGE McDADE: And then for one of the
components that are marked with the squares, as opposed to the diamonds, once that part were removed, you would then start again with predicted wear would be zero, actual wear would be zero, and then you would track that the same way that you had tracked that component before? MR. ALEKSICK: JUDGE McDADE: Exactly, Your Honor. And if it shows up in a
Page 1625 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: these replaced components? So how do you know on Does a replaced chart like this later on, it would be the wear, predicted wear from the time of replacement until the time of testing? MR. ALEKSICK: JUDGE WARDWELL: you said the opposite. JUDGE McDADE: Perhaps, well let's make Yes Your Honor, exactly. Oh really? I thought
component, a square, then turn into a triangle? MR. ALEKSICK: If the component is If the
replaced, that is represented as a square.
new component is subsequently inspected, then it turns into a diamond, yes. JUDGE WARDWELL: Okay. So that one
example that Judge McDade gave, that's fixed it. That will not change in the next scatter chart that's plotted. That will be there forever? That is correct.
MR. ALEKSICK:
However, if a diamond were subsequently inspected, it could change. JUDGE WARDWELL: MR. ALEKSICK: Sure, oh yeah. The next thing I'd like
to call Your Honor's attention to is the 45 degree
Page 1626 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 the line? MR. ALEKSICK: That is the middle line. It's drawn through degrees. MR. ALEKSICK: That is correct. We call line through the 00 point up to the 300, 300 point. JUDGE WARDWELL: Which is not 45
it that, but on this non-square graph, it is less than 45 degrees. That line represents the ideal. CHECWORKS predicted, that prediction is agreed precisely with field observations. points would be on that line. JUDGE WARDWELL: And that's the middle All of the If
best estimate line.
the scatter plot, right through the median value. JUDGE WARDWELL: And it is not related
whatsoever to a line correction factor that's at the end of that line. That just happens to be where
you've placed the value of the line correction factor. Is that correct? MR. ALEKSICK: Not exactly. The line
correction factor in this case is in the upper right-hand corner, where it says "LCF equals 1.060." That indicates that the median value is very close. The component that is the median -JUDGE WARDWELL: Don't start in on that
Page 1627 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
want to. sorry. (Simultaneous speaking.) MR. ALEKSICK: That's just in all plots, just yet. My question was that 45 degree line is
not an LCF line or it's -- you just placed the LCF equals 1.060 there. It's placed on that part of the It is a
graph, because that's where it was placed.
place there, because the 45 line happens to be close to it? MR. ALEKSICK: Yes, Your Honor. I'm
regardless of the details -JUDGE WARDWELL: That's where that value
will reside when you're looking for it. MR. ALEKSICK: JUDGE WARDWELL: explain LCF if you want to. MR. ALEKSICK: Yes, exactly. Now you can go on and I didn't want to -Well if Your Honor would
like me to, I'd be happy to. JUDGE WARDWELL: I want you to, yes. MR. ALEKSICK: would be a good time then. JUDGE WARDWELL: MR. ALEKSICK: Go ahead then. Again, the LCF is the -Okay. Well, I think now Well, at some point I
of the number of points here, I haven't counted
Page 1628 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
them, but it looks, maybe there are 40 of them, 41. There's an odd number of points. If one takes the ratio for each of those, let's pretend it's 41 points; the ratio of the predicted, I'm sorry, the measured to predicted values of wear, you'll end up with 41 ratios. In the upper left-hand corner, the ratio will be 30 mils of measured wear to 220 mils of predicted wear. We create 41 ratios like that, and
the median value of those ratios is by definition the line correction factor. So another way to say that is the median value, the median ratio was of a component that was 1.060, that value times the predicted wear equaled the measured wear for that component. see that point. We don't really have a facility for a laser pointer, but if you look in the middle of that pseudo 45-degree angle line, there is one point that lies precisely in the middle of it, and it's right about at 120, both predicted and measured. And you see that that, the middle line goes right through that middle point. So that And you can
point, that one component of all the inspected components of this line is the middle value, and is
Page 1629 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. CHECWORKS. therefore the line correction factor, and therefore all of the predictions of components for this line, the past one predictions, are multiplied by that value to obtain the past two predictions. This graph, by the way, is produced by There's no, this is a direct output from So there's no manual calculation of the
LCF going on here. JUDGE WARDWELL: What are the plus and
minus 50 lines, and what does 50 percent, plus or minus 50 percent mean? MR. ALEKSICK: Those lines are there,
not for a strict quantitative purpose, but more to guide the I. They're also there to define outliers.
Any of the points that fall outside of those two lines we call outliers, and pay more attention to them and try to understand why they are there. In this particular case, we don't have a very tight cluster of data around that center line. So we have, in the document that controls and documents the CHECWORKS model, we have a detailed write-up of this line, and that discusses the outliers and draws a conclusion of whether the line is calibrated or not calibrated, and what the basis for that conclusion is.
Page 1630 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 to that. If Your Honors would like, I can point It's in one of the Entergy exhibits.
We can bring that up, if you'd like. JUDGE WARDWELL: how is it drawn? Looking at this -- and
Is that a 50 percent less slope
and a 50 percent more slope, or what does the plus or minus 50 percent mean? MR. ALEKSICK: It's -- the minus 50
percent line is 50 percent less of the ideal 45 degree, pseudo 45 degree line. JUDGE WARDWELL: MR. ALEKSICK: JUDGE WARDWELL: A less slope? Less -Each value -- yeah, I
mean we can say 50 percent less slope; it's also 50 percent less value around a given vertical axis, I guess, vertical line. MR. ALEKSICK: Right. If we look at say
the 100, 100 coordinate, okay, a 45 degree line passes right through that. JUDGE WARDWELL: MR. ALEKSICK: passes through -JUDGE WARDWELL: MR. ALEKSICK: 50 percent less. The 50. The 50/100ths. So it's Yeah. The minus 50 percent line
Now I'd like to point out that the
Page 1631 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
one thing? upper bound, that is labeled "plus 50 percent," is perhaps a slightly confusing label. percent. JUDGE WARDWELL: MR. ALEKSICK: It's very confusing. But those are the lines It's really 100
that are there, to sort of indicate graphically and visually that we desire a cluster around that 45 degree line. JUDGE WARDWELL: 50 percent line? there. But what is that plus
I mean it's just disappeared It's double. It probably
It's 100 percent different. MR. ALEKSICK: It is.
should be labeled "plus 100 percent," and I can't speak to that, Your Honor. the case. MR. COX: This is Alan Cox. Could I add I don't know why that is
I think that was realized that that was
perhaps the wrong, incorrect label, and the latest versions of CHECWORKS have a graph that uses -- the plus 50 percent line is running through the 100, 100 point. So it is actually a plus or minus 50 percent
of the measured wear. JUDGE WARDWELL: plus and minus 50's? Of what use are these
Just to, I guess you said, I You just said to
guess I just should ask that.
Page 1632 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
highlight outliers? MR. ALEKSICK: Well frankly speaking, They're not -- I don't They help guide the
they're not essential lines. want to say they're useless. eye towards that line.
But as we disposition and evaluate the results of this, we don't really use those lines. They come out of the program and they're nice to have, but they're not essential in our -JUDGE WARDWELL: How do you identify
outliers, and what's the definition of an outlier, mathematically or I don't mean in regards to oh gee, it's something that's, you know, beyond the norm or something. How do you -- what's the definition of and deem a particular point to be
how you designate an outlier?
MR. ALEKSICK:
It would be if the point
were outside that plus, the line labeled plus or minus 50 percent. JUDGE WARDWELL: So if you've changed
the line, then there's going to be more outliers now. If you now truly bring that back down to what
a normal person might consider to be a plus 50, you would have more outliers? MR. ALEKSICK: That is true, Your Honor,
Page 1633 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: outliers when you see them? And what do you do with Do you automatically Do you reinspect
throw them out of your database? them? Any activities?
What excitement do you give
around these points? MR. ALEKSICK: throw them out. Well, we certainly don't
With respect to reinspection, any
of this CHECWORKS business that we're discussing now doesn't come into play in that decision. The sole criterion for determining whether a component and when a component is to be reinspected is the set of wall thickness measurements and the minimal allowable thickness. The way that we do use the outliers is in understanding the model. If there are for a
given analysis line, if there are a large number of outliers, that's telling us something very important. It's telling us that the model is not matching up well with the field, and that's why it's very important, and why Entergy follows the guidance in NSAC-202L, to review each one of these scatterplots, and determine if it is well-calibrated or not.
Page 1634 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 large number of outliers would indicate generally, almost always, a poor calibration, or a not good one. JUDGE McDADE: I could, just briefly. The way this is set -- if
They way this is set up, if
you go, for example, to 100 on the horizontal line, 50 on the vertical line, you have a data point there. That would indicate that that particular
component, there was twice as much wear as was anticipated under CHECWORKS; correct? MR. ALEKSICK: JUDGE McDADE: Yes, Your Honor. Do you make any kind of
analysis to determine whether there was any commonality among those components, where there is more actual wear than predicted wear, so that you will be able to then input that and change the program, to be able to predict greater wear for certain kinds of components, or under certain kinds of conditions? MR. ALEKSICK: Yes, Your Honor. We look
at the outliers, not just the outliers.
We look at
all the points and seek to understand what is the data telling us about the model, and the level of confidence that we can place in the model for this particular line.
Page 1635 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 quite often we will find a common or generic reason. Chemistry is a global variable that
affects all of the components' wear rates, and that might be sometimes a reason for the entire data set to be higher or lower than anticipated. But sometimes, the effects are more specific to that particular component. So there
might have been a manufactured wall thickness variations, for example, that were not indicative of FAC wear, but are indicative of conditions in the pipe when it left the factory. Or there might be other variations in the wall thickness that are not due to FAC, and that therefore CHECWORKS would not predict, that might explain. But there are many, many reasons that a
given point might be an outlier. JUDGE McDADE: So what you're saying
there, for example, and I just want to make sure I've got this correct, that particular data point, 50 on the vertical or 100 on the horizontal, if it is generated by CHECWORKS, it means that's the first inspection. And you're telling me, I think, that the reason there could be a narrowed wall there, is because of a manufacturer defect, because this would
Page 1636 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
have been the first time you would have inspected it, and this would be the first time that you would have become aware that the thickness is not what it should be; is that correct? MR. ALEKSICK: No, Your Honor. I
wouldn't put it quite that way.
These aren't
necessarily the first time that we've inspected something. In fact, these points are the last, most
recent time that we've inspected them. If a given component were inspected five times over the period from 1992 to today, only that fifth most recent inspection would appear on this graph. JUDGE McDADE: Okay. So the chart that
we had immediately before the lunch break, which indicated what kind of an inspection was going on, whether it was CHECWORKS-generated, whether or not it was a reinspection based on prior inspection results, this particular chart would not differentiate between those different precipitants of the inspection. In other words, on this chart, there could be some that are based on it, engineering judgment; some that are based on experience at other facilities; some that are based on CHECWORKS; and
Page 1637 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
some that are based on prior inspection? MR. ALEKSICK: The points on the graph They may have
are all CHECWORKS-modeled components.
been selected for inspection for other reasons, the ones Your Honor just outlined, for example. they are all CHECWORKS-modeled components. So the purpose of this graph is to help us understand and interpret and imply and improve the model. The purpose of this -- it is not the But
purpose of this graph to assess the structural integrity of any given component. This is about improving the model, and so regardless of the original reason for the first inspection selection, the data is useful in qualifying the model and calibrating the model. JUDGE McDADE: Okay, and again, I just
want to make sure I don't have a misapprehension, because you have first inspections and then subsequent inspections. If the CHECWORKS model
works out perfectly, in other words, you've done a CHECWORKS inspection; CHECWORKS is what precipitated it, you predict with CHECWORKS that there should be 50 mils of wear, and you check it and it is actually 50 mils of wear, and that's well within the acceptable range for that particular component.
Page 1638 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
Wouldn't that then either have a low priority or no priority for subsequent inspections? Wouldn't it only be those where the predictive and the actual are inconsistent, that you would have a higher priority for reinspection? MR. ALEKSICK: not entirely the case. To a point, but that's
The priority for inspection
is not based solely on the degree of agreement between CHECWORKS predictions and field measurements. The priority of inspection is
primarily determined by the wear rates and the remaining margin of that component. So if we had, for example, perfect agreement, as Your Honor hypothesized, if the agreement were perfect and it was one mil of predicted wear and one mil of observed wear, then yes, that would be a low priority inspection. But if it were predicted at 250 mils of wear and observed at 250 mils of wear, then that would be a high priority inspection or perhaps even a replacement. JUDGE WARDWELL: Getting back to the
mechanics of this plot, just before getting back to the real mechanics, as I hear you describe this, it also says to me that this plot might be useful to
Page 1639 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
give an indication of how good CHECWORKS is working. So I might critique a plot such as this, to point out that CHECWORKS isn't worth much, because it's got such scatter, and that's not a bad use of this particular plot. assessment? Is that a fair
And there might be a witness here
amongst us right now that has done such a thing, that we'll question about it. MR. ALEKSICK: It is certainly the case,
Your Honor, that some of the CHECWORKS plots agree well with observations, and some of them do not agree well with observations. That is the entire
basis for our practice of examining every single line, to determine where that agreement exists and where it does not exist. JUDGE WARDWELL: Let's talk about that a
little bit more indepth here looking at this plot, with some observations that could be made from this plot. First, if someone was trying to assess the
abilities of CHECWORKS to provide conservative estimates, if one was to have some scatter, one would like all the scatter to be, and I'm pausing here to make sure I say this right. pausing, to be above the line. Points above the line have -- of that That's why I'm
Page 1640 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
up. MR. ALEKSICK: That would be the case if correctly. JUDGE McDADE: JUDGE WARDWELL: You're just wrong. You're just wrong. No, middle line have predicted wear that is greater than the measured wear. So if there was scatter and it
was all above the line, at least one could comfort themselves that they would be notified of more wear than actually occurs. Someone might judge that to be a much better situation that if the model predicted wear that was less than what the measured wear was. fair assessment? MR. ALEKSICK: I disagree with that A
assessment for the following reason. JUDGE WARDWELL: backwards, though. did I? MR. ALEKSICK: No. You described it I didn't get it
I didn't flip-flop it though,
you're not wrong; you just screwed up. JUDGE McDADE: It's right but screwed
we relied on CHECWORKS as our sole tool. JUDGE WARDWELL: And let's assume that,
because we've been through that; we've explored
Page 1641 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. But exclusive of that, I understand all that
and Horowitz, we've already got testimony on how you're estimating the time for criticality and all that other stuff earlier this morning. So let's just assume we're trying to just use CHECWORKS and exclusive of that. ahead, then. But go
Because again, this is -- I'm saying We're judging CHECWORKS as a
this is on a premise. model.
Not your Flow Acceleration Corrosion
Program; just CHECWORKS part of it. MR. ALEKSICK: Okay. CHECWORKS, as
we've stated numerous times in our pre-filed testimony, is a best estimate code, and what Your Honor is describing is a bounding code. It's not,
I'm not here to argue that a bounding code is a bad thing or somehow inappropriate to use. Instead, my contention is that CHECWORKS, as a best estimate code, is a useful tool, and in particular it's useful to have it as a best estimate code because one of the good consequences of that, is we can look at a scatter plot like this and tell pretty easily if the model agrees with reality or not. That is the context in which we use CHECWORKS in the FAC program. We use it to predict
Page 1642 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 going on in uninspected components, and in order to use those results effectively, we need to know where the model is -- where we can treat the model with high confidence and where we can't. In those areas where we can't, and this may be one of those cases; this does not look like a particularly tight cluster to me. We would
typically inspect a significantly larger number of components. JUDGE WARDWELL: JUDGE McDADE: Thank you. Now when you say
components, where it would be and wouldn't be, are you talking about identifying it as, you know, pipes of more than two inches in diameter, with more than a 45 degree angle, with more than so many pounds per square inch of pressure. Is that the kind of thing
you're trying to describe, as to where it would be a good predictor and where it wouldn't be? MR. ALEKSICK: way, Your Honor. I wouldn't phrase it that
This result that we're looking at
now is from one of the 40 lines in CHECWORKS, and this particular line, third point extraction steam, probably has 100 to 150 components, elbows, straight pipes, nozzles. There may be some reducers in this
line, maybe a valve, check valve.
Page 1643 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
So within that subset of the plant, we're looking at the CHECWORKS results and concluding only for that subset of the plant, do we have confidence in the model's predictions or do we not. If we do not, then for that subset of the
plant, we would increase our inspection coverage. JUDGE McDADE: But wouldn't there be
commonalities in different subsections of the plant, that wouldn't exist internally within that subsection? Certain characteristics of particular
areas of the plant that would be repeated over and over in different sections of the plant, that would be -- have commonality, whereas in a particular section, you know, and I believe Dr. Hopenfeld testified, without contradiction, that in a straight piece of pipe, you were, in his view, your CHECWORKS would be a very good predictor? In any one subsection of the plant, you would have sections that would be straight pipes. You would have a good predictor with CHECWORKS, but that if Dr. Hopenfeld is correct, that in other places within that same subsection, where you have different geometry, you would have a totally different ability to predict where, using your program. Is that accurate, or how would you respond
Page 1644 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 to that? MR. ALEKSICK: What I would say to that,
Your Honor, is that the method that we use to create these analysis lines, this analysis line, the third point extraction, was identified in CHECWORKS, of the thousands and thousands of components in CHECWORKS. We grouped these several hundred together into this one line, because they share common operating and chemistry parameters. So the
only difference between the components within this line really is the geometry. isolated the variables. JUDGE WARDWELL: There are errors in So we've in effect
CHECWORKS' abilities to predict the measured wear. There's also errors in taking the measurement of the measured wear. If we make the assumption, for the
purposes of this discussion, that the measure wear is an absolute value, that is truth. error in measuring that. Then is not this scatter an indication the precision by which CHECWORKS is able to There's no
replicate the measure wear, and I'm using the term precision very specifically, and I'm using it different than the term "accuracy." By precision, I
Page 1645 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. DR. HOROWITZ: Your statement is true. applicant. mean the abilities to replicate the value over and over again. DR. HOROWITZ: Okay. Jeff Horowitz for
Well first of all, assuming that
measured wear is correct and precise. JUDGE WARDWELL: We have to do that for
The difference, one of the differences you would see are -- you'd see probably differences for two, three, four reasons. One would be trace chrome. If we're not
measuring trace chrome, as is current practice here, for example, the components at 30 mils of measured wear. Those two guys probably have some chrome in
it, and that's why they're so far to the left. Another difference would be, and that could make a big difference. mentioned that. Dr. Hopenfeld Another
I agree with that.
difference would be, that will be probably the biggest difference you will see. Other differences
would be minor geometric goal, differences such as weld grounds sticking into the pipe. But we're talking probably ten percent difference in wear and stuff like that. So those
Page 1646 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 probably the main two reasons. The other would Another
be a 90 degree elbows, really 85 degrees.
reason would be the weld grip being different from one elbow to another because the elbow was out of ground, you had it ground to be round, things like that. But those would all be fairly small. But getting back to your assumption, in point of fact, the measured wear is probably less precise than the predictions, and this is true because the NDE isn't precise; it's just that the amount of wear you measure is small compares to the propagation of error. I did some work for EPRI a few years ago, and I was shocked about how that occurs. think that's a good part of the reason for the scatter you see. JUDGE WARDWELL: So we see the I
scatteredness because there is imprecision with both the model being able to predict truth, and the imprecision with our measuring technique being able to predict truth? DR. HOROWITZ: Yes, thank you. Let me
also mention to a comment that Judge McDade made. Your pointing here is not the wear rate, not the wear; it is the amount of margin available. So you
Page 1647 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
assessment? DR. HOROWITZ: JUDGE WARDWELL: Yes, I think so. And if in fact these could have one of the components here that has a lot of wear, but it has a lot of margin available. that's another thing to keep in mind. JUDGE WARDWELL: True. But I'm trying So
to keep just with understanding the plot itself, and what the various data points represent, such that scatter around -- the amount of scatter doesn't necessarily say that the -- strike that. In this instance, we are fortunate because we happen to know what truth is with this plot, which is not true with lots of other plots that we have of data. degree line, is it not? that's truth. So the closeness with which the sum of all those points attempt to be able to predict that truth is of some measure of our abilities to have an accurate predictor capability associated with that model, and the measurements feeding into the input of that model. DR. HOROWITZ: JUDGE WARDWELL: Okay. I agree with that. Because truth is that 45 I mean just box that up;
Is that a fair
Page 1648 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
certainly. JUDGE WARDWELL: percent over prediction. In this case, it is six data points predicted truth exactly on the average with all those, would not the line correction factor be 1.0? DR. HOROWITZ: Yes, assuming things like
all your global data was correct. JUDGE WARDWELL: DR. HOROWITZ: That's -If everything's correct,
It's not a 45 degree line;
it's a six percent steeper line, that being the 1.06 or the line correction factor being six percent greater than 1. DR. HOROWITZ: JUDGE WARDWELL: Sure. So if one, and that was
the heart of my original question, was using this to get just a feeling for how well CHECWORKS works, would say that he were probably six percent on the side we really wouldn't want to be on if we had our choice. It's much nicer to be a line correction
factor of .94? DR. HOROWITZ: Right. Well, and again,
getting back to your question to Mr. Aleksick, about bounding a best estimate, I don't think the decision is that clear-cut. We started this best estimate 20
Page 1649 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
code. years ago, partly because we knew when we came out and showed the graph like this, people were going to make this graph, whether we provided it or not. The BRT-CICERO is the best estimate The German code KOMMSIE is -- no excuse me. The KOMMSIE code It bounds, I
The BRT-CICERO is a bounding code. written by AREVA is almost bounding.
think, all but one standard deviation, something like that with the data. So it's close to that.
When the found that out, and they found it out fairly recently, I talked at length with the EPRI program manager about do we want to change CHECWORKS to be bounding, which would take adding
one code, one line of FORTRAN, that's all, and a code of this. We decided no, mostly because we had
20-something years of experience, where people looked at this plot, and I think that's where we are, unless somebody tells us otherwise. JUDGE WARDWELL: With any best estimate
model, isn't it fair to say that 50 percent of the time you'll be above that and 50 percent you'll be below on any one point? DR. HOROWITZ: JUDGE WARDWELL: of best estimate, isn't it? Certainly. That's the definition I mean statistically
Page 1650 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 will be half the time you'll over and half the time you'll under-predict it. JUDGE McDADE: JUDGE WARDWELL: JUDGE McDADE: Okay. If I could --
Give you model results. If I could interject, and
let me try to paraphrase at least what I took away from what Dr. Hopenfeld said, make sure I've paraphrased it correctly, and then ask you to respond, that as you've designed the CHECWORKS program, you looked to the median and you looked to the standard deviation. But that in Dr. Hopenfeld's view, the standard deviation really isn't operative. It's the
absolute deviation, where you have these significant outliers that are unexplained, that those pose a significant risk, and that therefore CHECWORKS is unable to pick them up, and without another predictor, that adversely impacts the ability of the Flow-Accelerated Corrosion Program to ensure that the intended use is maintained. paraphrasing you, Dr. Hopenfeld? DR. HOPENFELD: Well, my main point was Am I correctly
that it's non-conservative by more than a -- as much as a factor of ten. That was my point. Okay. But the operative
JUDGE McDADE:
Page 1651 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
thing isn't whether it's conservative or nonconservative, meaning whether it's above or below prediction; it's the fact that it's significantly above or below prediction, and even though the standard -JUDGE WARDWELL: the mic, Dr. Hopenfeld. JUDGE McDADE: And even though the Could you speak into
standard deviation is relatively minor, as expressed here with the line correction factor, the fact that you have certain outliers that are so far beyond, that that makes it a not valuable tool for
predicting Flow-Accelerated Corrosion? DR. HOPENFELD: Let me just say, if I I didn't
may, I'll just say, add one word here.
come from the moon in making that kind of statement. I made some back, some calculation. I think I even
referred to them, to see well look, if I am off by 50 percent for that kind of a wall, what's going to happen if I didn't detect it? So I did this. I used these numbers,
although these are not really good numbers to use, because they're averages. They represent, you see
like the gentleman said, he's using average volumes. If you're really interested in the maximum, local
Page 1652 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
Hopenfeld. DR. HOPENFELD: But if you operate, you maximum, you really shouldn't use them. But nevertheless, even using averages, you can see, because in a plant, the actual thickness varies, something like between one or half a mil to ten mils per year. So it depends on the
particular component you're looking at. But you can sort of do sensitivity studies, which I did, and that's why I said well look. When you're off by as much as -- most of the But
time you're off, but it's not ten or outliers.
most of the time, oh on probably a lot of them, is marred by a factor of ten. A factor of ten for some
components which, you know, if you have a very thick wall and you operate at very low turbulence, that's okay. JUDGE McDADE: JUDGE WARDWELL: I'm sorry. Okay. Thank you, Dr.
have a thinner wall, you operate with a lot of turbulence, that kind of -- and you realize, and you say well, in the pre-inspection, I've got three years and four years and five years, you're not there. That's my point. JUDGE McDADE: Okay. Dr. Horowitz, if
Page 1653 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 could, could you basically respond to my question about the value of CHECWORKS, when in addition to the median and the standard deviation, you also have some significant outliers, and is there a way that that can be adjusted for within the CHECWORKS program? DR. HOROWITZ: Okay. First of all, I
don't think it's a matter inside the CHECWORKS program. As Mr. Aleksick pointed out, any outlier,
and you're interested obviously in the outliers that are wearing more than you think they should be, or have been inspected, if they're too thin at this point they'll be replaced. return them. So for whatever reason, if there is a reason that CHECWORKS is predicting that component wrong, you're not basing future inspections on CHECWORKS. JUDGE McDADE: No, but I understand, and If they aren't, they'll
it's been explained this morning in some detail, what happens when you have an outlier and what is then done. What I'm trying to get at and trying to understand is when you have an outlier, it means that CHECWORKS didn't predict the actual wear. Is
Page 1654 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
things. there any way that that is then plugged back into the CHECWORKS program, so that same kind of deviation won't occur again? Again here, you've identified a place where the wall thickness is below what you think it should be. You fixed it. But there are a lot of
areas that haven't been inspected, and the question is how do you have assurance that those other areas that haven't been identified for inspection by CHECWORKS don't have this same problem, where the wear is significantly higher than what you would predict? DR. HOROWITZ: Okay. There are two
Number one, as I just pointed out to Judge
Wardwell, the measured wear is hardly a precise number. It's probably less precise than the That's true for a number of
CHECWORKS predictions.
reasons that I pointed out. I think the more important reason is programmatically, if we see a lot of outliers, that line is not calibrated and more inspections are done. And I think -- I suggest that's your defense
against what you outlined. One more thing. Dr. Hopenfeld just now,
and in his presentation, said that CHECWORKS
Page 1655 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
predicts an average rate of thinning. incorrect. That's
It uses the maximum rate of thinning on
the components. JUDGE McDADE: JUDGE KENNEDY: Okay. Thank you, Doctor.
How does that relate to I'm Dr.
the best estimate nature of the program?
misunderstanding what Dr. Horowitz just said. Horowitz, you -DR. HOPENFELD: I think what he's
talking about maximum and what I talk about maximum are two different things. Going back to the elbow,
you see the average -- he's talking about maximum, what in that F3 as a geometrical factor. that's what he's talking about. average. about. JUDGE KENNEDY: Let's ask Dr. Horowitz. I believe
It's still the
It's not the local thing that I'm talking
Did you just say it predicts the maximum wear rate? DR. HOROWITZ: JUDGE KENNEDY: That is correct. In the context of a best
estimate tool or computer program, what does that -DR. HOROWITZ: It's just saying it
doesn't matter best estimate or not. JUDGE KENNEDY: maximum wear rate? So the best estimate
Page 1656 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. HOROWITZ: JUDGE WARDWELL: That's correct. And how do you know
that is the maximum wear rate? DR. HOROWITZ: Okay. This gets into Now what we call the
something we've been skirting.
geometry factors with what the Wang paper that Dr. Hopenfeld -- he has an exhibit called something else, is the ratio of the maximum wear on a given component, to the maximum -- to the wear in a straight pipe with the same conditions. That's how Dr. Paulson defined it in his paper; that's how Dr. Wang defined it in his paper, using different words. JUDGE WARDWELL: One other question I
had, backing up a bit to where I was, that I just wanted to fix, to make sure I understand this correctly. Back to the statement saying it was a
best estimate, and half the time it would be above and half the time it would be below. That half time it would be above and half time being below, has nothing to do with the plus or minus 50 percent we have on this graph. that correct if I understand it? DR. HOROWITZ: JUDGE WARDWELL: Yes it is, Judge. Yeah, that's -- okay. Is
Page 1657 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? that? DR. HOROWITZ: JUDGE WARDWELL: JUDGE KENNEDY: can we go to the next page? MR. TURK: May I ask a clarifying Your Honors, when I look Yes, please. Okay. Ready to turn to -- now Horowitz? (Off record comment.) JUDGE WARDWELL: You want to strike get that? thing. These plus and minus 50's are just purely plot lines for visual aids; is that a fair assessment? DR. HOROWITZ: Excuse me. One more
Just looking here -JUDGE WARDWELL: Sorry. Could I just
Is that a fair assessment, that -DR. HOROWITZ: Yes it is, but looking at
your comment that the one line was mislabeled. Looking at more recent output of CHECWORKS, that's been corrected. JUDGE WARDWELL: Say that again, Dr.
Sherwin Turk.
at that chart and I see the 50 percent value, perhaps my understanding is incorrect, but I understand that the central line is 50 percent lower than the upper line, and that the lowest line is 50
Page 1658 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
percent less than the middle line. something that -JUDGE WARDWELL: understanding. JUDGE McDADE: I don't know that was a That's not my Is that
clarifying question, but I believe Mr. Cox indicated that it's actually 100 percent, and that on the more recent graphs that are produced, indicates that it is 100 percent. JUDGE WARDWELL: will be 100 percent above. DR. HOROWITZ: JUDGE WARDWELL: Yes. Just to ask. I mean Well, 50 percent below
the point is the lines are just lines. MR. TURK: Sorry for the interruption. Let's, could we --
JUDGE WARDWELL:
before we go to the next line, and then I'll let you take over, I think now might be -- Dr. Hopenfeld, you make the statement that these values are off by an order of magnitude of ten. DR. HOPENFELD: JUDGE WARDWELL: Uh-huh. Where do you get that
from this plot, or did you get it from some other plot, or some other analysis? DR. HOPENFELD: I was very careful in my
Page 1659 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
be 200, what that be? others. JUDGE WARDWELL: So the most extreme language. I said I've looked at close to 7,000
points, and based on those, and I'm not sure if it's in here, but here you can see that it's off by -this is, there are others which are more than ten. But I said, to be as much as ten. conservative, I said
I don't know whether it's in here, This is 220 versus 100, so
but we can check that.
that would be by a factor of -- on the outlier. Let's see, the outlier. So there would be 300 -All right. Which point
JUDGE WARDWELL: are you pointing out?
I'm sorry.
Which one?
DR. HOPENFELD:
If you look at the two
points here, you'll see there will be 200. JUDGE WARDWELL: DR. HOPENFELD: In the upper left? On the upper left would So what would
20, 220, divided by 20.
Just as a point.
But there are many
outliers would be an order of magnitude -DR. HOPENFELD: I'm talking about. either way. Yeah, yeah. That's what It's
I didn't say either way.
In this particular instance, it doesn't
matter which way it is. JUDGE WARDWELL: But in this particular
Page 1660 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? one, yeah. chart, if you look to the lower right, the furthest outlier is measured wear about 225, predicted wear 75. So it's a factor of 3. DR. HOPENFELD: I said as. Right. That's a small
I would recommend, so not to
get carried away with the outliers, I can go back to it. But we just looked at the extremes, within the
plus or minus 50 lines, so they won't get any confusion. Make it simpler. JUDGE McDADE: JUDGE KENNEDY: Go the next chart. Could you say that
I'm not sure I understand. DR. HOPENFELD: I'm saying that we can
talk about the outliers, and in my presentation, I said as much as a factor of ten. But most of them,
and I have a table showing how many are those far out. So I have a table. You have the data in front
of you somewhere in evidence. But let, we can easier not just talk about what's within the bounding lines. easier to talk about it. JUDGE KENNEDY: Okay, and we've had an It's just
explanation from Entergy of how they deal with the outliers, and you're suggesting we just stay out of that arena?
Page 1661 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: Just for this
conversation, this discussion of this, what I'm trying to demonstrate with what I said, optical illusion. JUDGE KENNEDY: to the next page? JUDGE McDADE: JUDGE KENNEDY: Yes. Now Dr. Hopenfeld, I Is that Okay. Should we go on
think this is an exhibit that you prepared? true? DR. HOPENFELD: JUDGE KENNEDY: Yes. Could you walk us
through your explanation of what is important on this graph and what is presented here? DR. HOPENFELD: Yes. You see if you
look at the original graph, the one which you previously showed us, you look at it and you say hey, everything is perfect here. good. It looks pretty
It's within this plus or minus 50 percent.
Actually, you're really interested in the lower number, because we're interested in the nonconservative. That's what we're interest in and that's what 1801 talks about. So you're interested in the
data below the LCF towards the non-conservative
Page 1662 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
make sure. LCF line? DR. HOPENFELD: LCF is the one that they predictions. If you look at it, you say well, it
doesn't look that bad. JUDGE WARDWELL: What do you mean by an
had over there, which was labeled 106? JUDGE WARDWELL: That's the point. It wasn't labeled.
It wasn't labeled 106. Well, on the top. But
DR. HOPENFELD: it's that line. JUDGE WARDWELL: DR. HOPENFELD:
So 45 degree line? Yeah. I just copied.
All I did, sir, was just take their -JUDGE WARDWELL: Okay. Just wanted to
That's the 45 degree line. DR. HOPENFELD: Yeah, yeah. All I did
is just went to one of those programs in the computer, and just flipped that, and I used X = Y, Y = X and I changed the coordinates. So I took the
same data point and to the best of view, I don't know which program I used. But I put the points and started replotting it, okay? The reason I'm replotting it If you take a
because it's third grade mathematics.
number and divide by a small number, you get a
Page 1663 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
larger number. That's what happened here.
Now if you look at this then, you'll see now suddenly a lot of numbers that were bounded before, okay. okay. Now they're not bounded anymore, No, no, no. I'm sorry.
That was my point.
This is the wrong number here.
This is the next --
oh, I thought that you were -- I'm terribly sorry. I thought you were showing the figures from yesterday's presentation. Okay. Let's go to the third one. I
confused -- I thought that we were, I didn't include that draft in my presentation yesterday. JUDGE WARDWELL: you prepared? DR. HOPENFELD: Yeah, right, right. I This is an exhibit that
just, that was the next step, to show you look, if you just look at the LCF line and the numbers below that, that's what you see, okay. predicted. Measured and
The next one, I flipped it over.
Yesterday, I didn't even show this one. JUDGE WARDWELL: Okay, and you're
showing this, mostly to make that same qualitative discussion that I was bringing up, that points below the line have measured rates that are higher than the predicted rates.
Page 1664 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
much. copy. JUDGE WARDWELL: says that it's a best guess. But their testimony Not best guess, best So if one could call that, as you have, non-conservative, meaning that it's more desirable to be above the line. All this is saying is it's the line. Right. This is just a
more desirable to be above DR. HOPENFELD:
estimate model, and so you would expect to have points below the line, as well as above the line, wouldn't you? DR. HOPENFELD: JUDGE WARDWELL: DR. HOPENFELD: Sure. Right, okay. The question is how
That's the question, by how much. JUDGE WARDWELL: But it's not -- is it Non-
appropriate to call it non-conservative? conservative in regards to what? DR. HOPENFELD: Yes.
No matter what it
is, it's still non-conservative below that line. JUDGE WARDWELL: DR. HOPENFELD: would predict. Why? Why? For what?
It's below what you If it was 1 to 1 --
It's below one.
JUDGE WARDWELL: conservative?
But why is that
It's just below.
Page 1665 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: No. 1 to 1 is correct;
but anything below that would be non-conservative. JUDGE WARDWELL: above it would be So why -- so the one
ultra non -No. The higher, the one
DR. HOPENFELD:
below would be that you predicted something less than what you measured. JUDGE WARDWELL: Okay, but so it's less
than, but it's not necessarily conservative or not conservative? DR. HOPENFELD: Well, if it's less than,
than it would be non-conservative. JUDGE WARDWELL: It would be, if in fact
you were only -- if you were using this to dictate when in fact you were going to replace a component or repair it. But they aren't using this for that;
is that correct? DR. HOPENFELD: JUDGE WARDWELL: I think they do. We had testimony this
morning that said they used measured values and calculations for most measured values, to determine how they're going to handle those components. not that correct? DR. HOPENFELD: There was still 50 Is
percent of the time it's being used to screen
Page 1666 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
who are -(Simultaneous speaking.) DR. HOPENFELD: Yeah, okay. They say components and predict frequency. JUDGE WARDWELL: But they weren't using
them in regards to replacing or repairing a component, to meet its intended function, were they? They were using measured values and calculations from them in regards to the service life? DR. HOPENFELD: the component with this. JUDGE WARDWELL: But it's not a nonAfter they identified
conservative or non-conservative in regards to being below the line, and they don't use this for all their even selections. DR. HOPENFELD: No. I don't understand
it that way, because if you say that they don't use CHECWORKS, period. JUDGE WARDWELL: I don't say. It's they
they don't use CHECWORKS, period, which now they say they use it very little. Then we can just go and But right now, the
focus on what they are using.
conversation is about CHECWORKS, and what is predicted and what is conservative and what's not conservative, and that's what I'm talking about
Page 1667 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
here. JUDGE WARDWELL: But that's why I don't
understand the definition of conservatism, when you're talking about what's just talking about model. You're putting a qualitative adjective,
conservative and non-conservative, on to being above and below this line. DR. HOPENFELD: JUDGE WARDWELL: Yes. And did the same thing.
The testimony I heard from Entergy in regards to well, it isn't really, and I, you know, accepted that testimony and am now questioning you in regards to that same testimony, the fact that they're not using it in any actual implementation of corrective measures associated with their management program, that convinced me that maybe I shouldn't have used that term, more desirable, less desirable. In the same way, I'm asking you, should you be using the term "non-conservative" or not? DR. HOPENFELD: From reading all the
testimony they provided us, it's my understanding that they are using it to some extent. They're not
using it to the extent that I originally thought they were when I read the LRA. mostly using it. I thought they were
Page 1668 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 as time was going on, we found they're using it -- until they gave us this chart with those colors that you had, I didn't know how much they were using it. When they gave us the
color, the color chart, it became obvious they were using it for like total 25 percent. But I couldn't figure out half of it is used or half of it is for frequency. confusing. JUDGE WARDWELL: Yeah, and that chart It was very
was to predict, to determine the measurement locations. It didn't even -- they are still several
steps from the activity. (Simultaneous speaking.) JUDGE McDADE: Can I go back, because
I'm getting more confused, and let me just interrupt here for a second, Dr. Hopenfeld. As I understand
it, you're not using the term conservative/nonconservative as either good or bad. When you use
the term "conservative," that means that the actual wear is less than the predicted wear. When you use
the term "non-conservative," it means that the actual wear is more. DR. HOPENFELD: JUDGE McDADE: Correct. Not good or bad; it's
Page 1669 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
defining. believe. JUDGE McDADE: And then when you get to just that's the way you're defining the two terms. DR. HOPENFELD: That's the way I'm
That's the way it was defined in 1801, I
the next part, they replace, based on -- and repair, based on actual measurements. But your concern, as
you expressed it this morning, at least as I interpret it, is that they identify those areas to be inspected, new inspections through CHECWORKS, for a significant portion of those. DR. HOPENFELD: JUDGE McDADE: Correct. If in fact they identify
it and there is excessive wear, they then can take corrective action. DR. HOPENFELD: JUDGE McDADE: That's correct. But that your concern is
using CHECWORKS, given what you perceive as its deficiencies, that are components that will never be inspected, but nevertheless are going to have significant wear that had they been inspected -DR. HOPENFELD: JUDGE McDADE: far more than predicted. Right. The wear would have been They're not inspected,
because the predicted wear is low, and that that
Page 1670 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
comment? JUDGE McDADE: Sure. meant. JUDGE McDADE: MR. AZEVEDO: Okay. Your Honor, may I make a poses, in your view, an unacceptable risk that the component will fail and not perform its intended function. DR. HOPENFELD: JUDGE McDADE: Absolutely. Okay. I just want to
make sure I understand your position. (Simultaneous speaking.) DR. HOPENFELD: You understood what I
(Simultaneous speaking.) JUDGE McDADE: I mean this is -- again,
we're just trying to make sure I understand his position and I understand that that position is not necessarily shared by Entergy. MR. AZEVEDO: make a couple of comments. Yes. I'd just like to
Number one, we've been This specific
talking about this specific line. line was not calibrated.
So we're not making the This
argument this is a good line that we rely on. is a non-calibrated line, so we recognize the scatter on this line.
Page 1671 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
out, The second comment is, as you pointed the determination whether that component's fit
to be placed in service or not is not -- we don't rely on CHECWORKS wear. We rely on measured wear.
I just want to make sure that that's clear. The third point I would like to make is that the judgment as to whether CHECWORKS is an effective program or not should be based, in my view, primarily on the ranking mechanism, because that's how we use it. We don't necessarily use the wear rate alone; we look at it, but the benefit of CHECWORKS is the ranking tool, and the highest ranking locations. Those are the ones that we inspect. So the judgment as to whether the program is effective or not should be based on the ranking, not just on the wear rate. JUDGE WARDWELL: But isn't it true that
if in fact because of the results of CHECWORKS, there might be a situation where a component has predicted wear very low, and actually has a lot of measured wear, but you'll never get to that point, because you never will have taken a measurement of that point? MR. AZEVEDO: Well in this particular
Page 1672 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
case, because the line is not calibrated, what this will tell us is that we have to do more -JUDGE WARDWELL: And don't focus on --
we're not focusing on this as a target of what a different decision should be on this. really care what this is. We don't
This could be a
hypothetical line, as far as we're concerned. Just understand the concepts that are trying to be portrayed here, and as I understand what Dr. Hopenfeld says, is there -- by looking at this data, he says there's a chance some of these outliers may never be identified for inspection. If that's true, then in fact we'll never get to the point that it's even considered in some of your other criteria, and certainly wouldn't even come up with the calculation to be derived for it, to see whether or not it needs to be repaired or replaced. Isn't that correct? MR. AZEVEDO: If that was the only tool
that we'd use, that we use, I would agree with that. But that is not the only tool. MR. COX: I guess one of the things we One of the
mentioned, this is Alan Cox for Entergy. things we mentioned was whether a line was calibrated.
In the scenario that you described,
Page 1673 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, you're saying we haven't done an inspection because we show up as low wear on the prediction. If we haven't done any inspections, we don't consider the line calibrated. So we're not
going to not inspect that line, based solely on CHECWORKS. We're going to have to have inspections
before we can rely on CHECWORKS to say whether you need to do more inspections or not. So I don't think you're ever going to get to that scenario, where we're never going to look at a line, because we have a CHECWORKS model that says we have low wear. JUDGE KENNEDY: This discussion of
conservative, non-conservative makes me, takes me back to some points that Dr. Hopenfeld was making about NUREG-1801. There's a comment in there that
if the CHECWORKS model is not conservative, it needs to be calibrated. And now I think I've lost my path, as to where the term conservative comes in here. think Dr. Hiser is just itching to help us understand what GALL means by if the CHECWORKS model is non-conservative, it needs to be calibrated. MR. YODER: I'll address that. Matthew So I
Page 1674 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
Yoder from the NRC staff. I think one thing that
the staff and Dr. Hopenfeld agree on is that the entire program must rely on your ability to inspect prior to reaching a critical thickness for a component. I think that is the intent of what's written in the GALL. For the specific section that
discusses CHECWORKS and the FAC program being bounding for FAC, that is the intent of that. The language stating that the analysis is bounding, because in general, the predicted wear rates and component thicknesses are conservative when compared to actual field measurements, was added as part of Rev 2 to the goal. We recognized that that is confusing language, and we have actually put in an interim staff guidance which, among other things, removes that language from the document. exhibit. That is an
I can provide the number. JUDGE WARDWELL: So you're now not
saying that CHECWORKS is a bounding analysis? MR. YODER: Well I guess what I'm saying
is that was never the intent, and I won't, I don't know how this specific sentence wound up in Rev 2 of the goal. But going back to Rev 1, that was not
Page 1675 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
adds -JUDGE WARDWELL: anything in this context? things that it does. No, but does it replace I don't need the other present. What was present was the statement that
CHECWORKS is acceptable because it provides a bounding analysis for FAC. What we mean by that is you're going to identify and inspect the component prior to challenging that minimum component thickness. bounds the wear associated with FAC, before you challenge the component integrity. been the intent of this document. JUDGE WARDWELL: But the phrase that the That has always So it
model is a bounding model is a different phrase then, is what you're saying? estimate model. MR. YODER: That's right. The staff In contrast to a best
recognizes that CHECWORKS is a best estimate model, and this phrase would imply that you could interpret this phrase to mean that it is. bounding model. We see it as a
We do not agree with that. And so your proposed
JUDGE WARDWELL:
interim staff guidance merely strikes that sentence? MR. YODER: Among other things. It also
Page 1676 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
language. DR. HISER: Yeah, I think if you -- this If you look at the MR. YODER: No. It strikes that
is Allen Hiser of the staff.
following sentence, it says "It is recognized that CHECWORKS is not always conservative in predicting component thickness. Therefore, when measurements
show the predictions should be non-conservative, the model must be recalibrated using the latest field data." That's the Pass 2, the line correction factor approach that is within the CHECWORKS code. That's what we were trying to get to there. In
terms of the fact that we don't, did not expect that every data point would be bounding. So we wanted to
ensure that there was some feedback of the measured inspection data to the CHECWORKS program, so that future predictions would be informed by that inspection data. So the wording is confusing. The way
that we believe that it was intended was to be bounding, in terms of predicting component performance, and ensuring that inspections and corrective actions would be taken as necessary, before the acceptance criteria would be exceeded for
Page 1677 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
those components. So it's not data point by data point bounding, but it's component bounding is what we believe the intent is. JUDGE KENNEDY: A compounding bounding
in the sense that inspection would occur, or -DR. HISER: Right, that inspection would
occur, and if acceptance criteria are not met, then corrective actions would be taken. JUDGE KENNEDY: Said a different way, is
the caution that Judge Wardwell was trying to give us on making qualitative statements about conservative, non-conservative, is that all wrapped into this discussion? I mean we're starting to walk
down a path that if a lot of data was below the line, we've got issues. I was envisioning a long discussion about recalibrating the model. But it's sounding
like to me that this discussion is moving in a different direction. DR. HISER: Well, I think the wording
that is within the GALL report has been misconstrued and is not clear, in terms of what's intended by CHECWORKS, by the statement of CHECWORKS as a bounding code.
Page 1678 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: guidance clears that up? DR. HISER: There is a draft interim And the interim staff
staff guidance document that makes corrections to that, to ensure that the meaning is much clearer. JUDGE KENNEDY: within this proceeding? DR. HISER: Entergy exhibits. I believe it's one of the Is that an exhibit
I don't have the exhibit number. Your Honor -David Roth for the staff.
MR. YODER: MR. ROTH: It's Entergy 573.
JUDGE KENNEDY: MR. ROTH:
ENT 573?
That is correct, Your Honor. And does that go out for
JUDGE KENNEDY:
comment or what happens to it? DR. HISER: public comment. I believe that it is out for
I'm not sure of the exact status.
It has not been finalized yet. JUDGE KENNEDY: Dr. Hiser, again looking
at where we are within the licensing proceeding, the availability or the implementation of this interim staff guidance, would that change the condition or the staff's view of Entergy's Flow-Accelerated Corrosion Program at this time?
Page 1679 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
leave this. DR. HISER: Well, it really would have The
no impact on the acceptability of the program. way that we see the program, CHECWORKS is a tool used within the program to provide assurance of
integrity of the components that are susceptible to FAC. JUDGE KENNEDY: And so this draft
guidance, in your mind, really provides clarification, so that people clearly understand what was intended by the statements? DR. HISER: That's correct, with the
impact to the ISG on this portion of the GALL AMP. That would, that is correct. clarification. JUDGE KENNEDY: MR. YODER: Thank you. It's for
Just one more, before we The
Matthew Yoder from the staff.
statement that we've been discussing is not present in GALL Rev 1, which is the guidance document that was in place when renewal. JUDGE KENNEDY: And was it the GALL Because I Indian Point applied for license
version that the SER was written to?
thought we heard testimony yesterday to the contrary, that GALL Rev 2 was.
Page 1680 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. MR. YODER: Well, let me try to explain
The changes to GALL Rev 2 in this area
would have been operating experience-based in particular. That's what would have been important
for plants to or applicants such as Indian Point to consider. There were no changes to operating experience for FAC. So because the wording of Rev 1
and Rev 2 are very similar, other than this one sentence that was added and the update of NSAC. Now
NSAC 202-L Rev 2 and Rev 3 are accepted in Revision 2. With those being the only changes, I think one would say that -- I think I would say that Indian Point's application, the FAC AMP, is consistent with both Rev 1 and Rev 2. JUDGE KENNEDY: I guess maybe I
misunderstood Mr. Yoder's comment, about what's in Rev 1. MR. YODER: All right. So if we look at
the specific passages that we've been discussing. The statement regarding -- okay. So under
monitoring and trending, should we pull this up? JUDGE KENNEDY: the exhibit number? We could. Do you have
Page 1681 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
interrupt. many pages. then? DR. HISER: I believe so. Entergy. MR. KUYLER: Your Honor, Ray Kuyler for
It's New York State 147D. JUDGE KENNEDY: Would this be GALL Rev 2
(Off record comment.) DR. HISER: Probably need to go down
We're looking for page number XI.M17-1. (Pause.) MR. TURK: Your Honor, I'm sorry to
Sherwin Turk. JUDGE KENNEDY: MR. TURK: Yes sir.
I might be able to give you The staff's SER is dated
some quick clarification. November 2009. JUDGE KENNEDY: MR. TURK:
So before Rev 2?
The SER considered Rev 1.
GALL Rev 2 was issued December 2010, one year after the SER came out, and there was, of course, the SER supplement that came out more recently, on limited issues. But the evaluation was against Rev 1, and
later we were guided, we had information from operating experience that we considered. JUDGE KENNEDY: you were trying to say? And maybe, is that what
I'm confused where this
Page 1682 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 staff. bounding comment is, if it's in GALL Rev 1 or GALL Rev 2. MR. YODER: This is Matthew Yoder from
The comment regarding whether the model
is bounding is in Rev 2 of the GALL. JUDGE KENNEDY: MR. YODER: And not in Rev 1?
That is correct, and the SER
was written prior to the issuance of Rev 2 of the GALL. JUDGE KENNEDY: Okay. Now we have
clarification to the GALL Rev 2, which is in the draft ISG. MR. YODER: the question? JUDGE KENNEDY: Is the draft interim I'm sorry. Could you repeat
staff guidance, is that to clarify GALL Rev 2? MR. YODER: That's correct. It modifies
GALL Rev 2 and it's -- this specific passage we're talking about, as well as a lot of other areas, that get into erosion and droplet impingement and some of the other topics which we have discussed during this hearing. But we have the exhibit up now, if you want to look at that exact language. Rev 2. This is GALL
It would be under the Monitoring and
Page 1683 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
through. my way back. Trending, Element 5. on the fourth line. bounding." JUDGE KENNEDY: got myself into this. MR. YODER: Right. So that was not in Okay. So that's how I So the specific phrase starts It starts with "The analysis is
Rev 1 of the GALL, and it is not in the staff's proposed guidance going forward. JUDGE KENNEDY: Okay. I think I found
So I appreciate that. JUDGE McDADE: But sort of cutting to
the chase on this, that this particular exhibit, New York 147D, is the GALL as of December 2010. was based on the previous version. It came out in November of 2009, and that in any event, this language from Revision 2 was being modified and if we're looking for the modification, we go to Entergy Exhibit 573, the draft interim staff guidance. MR. YODER: That's correct. And that sort of walks us The SER
JUDGE McDADE:
So when we go back and start reading the
record in one place, that's sort of the path we follow? MR. YODER: That's correct.
Page 1684 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: And it's the position of
the staff, the NRC at this point, that the draft interim staff guidance, Exhibit Entergy 573, states the current NRC staff position on this? MR. YODER: That is correct, except I
would caveat that, that that is a draft interim staff guidance. It has not gone through its full
public comment period, and it has not become official document yet. proposed position. DR. HISER: from the staff. This is Allen Hiser again But yes, that is the staff's
But I think it would -- we can say
it would be the staff's intent to correct the misinterpretations that can occur, because of the way this is worded. JUDGE McDADE: DR. HISER: that's in Entergy 573 Thank you, Dr. Hiser.
Whether it's the wording or some alternative that we
come out with, we need to make these corrections. JUDGE McDADE: Because you think the
language in the Revision 2 to the GALL, which is in our evidence is New York 147D, is misleading? DR. HISER: I think that's correct. I
think that's caused a lot of the confusion here this afternoon.
Page 1685 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
Riverkeeper. confused now. JUDGE McDADE: Well, at least we can Thank you.
justify our confusion on something. PM
Your Honor, Philip Musegaas for If I may, I think unfortunately I'm If I can request some clarification.
Just between what Dr. Hiser and Mr. Yoder said, and what Sherwin Turk from the NRC staff counsel said. So is the NRC -- my question would be is the NRC staff's evaluation of the FAC based on GALL Rev 1, or is it -- how does this language that we're discussing, how is that integrated into their assessment of whether this, the AMP is sufficient? JUDGE McDADE: Well I think ultimately,
the three of us in the short term are going to have to figure that our ourselves, just sort of following the bidding here, which I think is like a 2 no trump at this point, is it was GALL Revision 1 that was the NRC guidance when the SER, or excuse me, when the license application was submitted. When the original SER was prepared, we then had a modification in GALL Revision 2 that was in place when the supplement to the SER was issued, that upon review, the NRC staff believes that there is confusion generated by Revision 2, which they hope to correct, that started that process with the
Page 1686 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. JUDGE McDADE: Okay, and then we have to draft guidance that they have issued, that is now out for public comment. I don't know that I jotted down the date of the draft interim staff guidance, but it's Exhibit 573, and that's where we are today. Ultimately, we're going to have to decide with all of that, and Dr. Hiser, have I -- since I can't testify, you can. Did I just sort of accurately
describe the evolution of this within the NRC staff? DR. HISER: Yeah. I think that's
decide whether or not, as it currently exists, things demonstrate that the effects of aging will be managed during the period of extended operation. But can we proceed? JUDGE KENNEDY: we want to keep going? I think that's good. Do
I have just one additional In your, I think it's
question for Dr. Hopenfeld.
your initial testimony on page 39, you challenge the effectiveness of Entergy's Aging Management Program for Flow-Accelerated Corrosion, and you state it's based on leaks and excessive wall thinning. DR. HOPENFELD: JUDGE KENNEDY: Yes. I think we've heard some
Page 1687 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
thing. initial. JUDGE WARDWELL: initial goes to page 39. JUDGE KENNEDY: let's check the rebuttal. DR. HOPENFELD: Would I have an I don't think the rebuttal. JUDGE KENNEDY: DR. HOPENFELD: JUDGE KENNEDY: Is it in the rebuttal? It's somewhere -I think it's in the that? JUDGE KENNEDY: JUDGE WARDWELL: I think it's page 39. That must be in the testimony today. If you could sort of point us to
what information you used to come to that conclusion, and maybe walk us through your thought process, to get to what appears to be a very extensive program not being effective. JUDGE WARDWELL: What page number is
It doesn't. Okay. Then it must --
opportunity to correct the record, as to what the NRC stated now, what was done in connection with the revision of GALL? JUDGE KENNEDY: Let me first do one
It is the rebuttal testimony, page 39. DR. HOPENFELD: Okay.
Page 1688 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
strike it. Entergy. now? DR. HOPENFELD: before I forget. Yes, that would be fine, JUDGE KENNEDY: question, Dr. Hopenfeld? DR. HOPENFELD: JUDGE KENNEDY: DR. HOPENFELD: I'm sorry? You asked a question? No. I was asking would And did you ask a
I have an opportunity to comment on what was said by the NRC later on? Whatever you want. Would you like to do so
JUDGE KENNEDY:
One thing, I well realize about
Revision 1, and let me tell you the history, a little bit about the history. But first, it's a
moot point because Entergy stated in their statement that they accepted in their compliance with Revision 2. It's in there. So everything about 1801 They
and before is not really applicable there. accepted it; they agreed to it. compliance with it. Secondly -MS. SUTTON: They are in
That's what they said.
Your Honor, Kathryn Sutton,
We object to that statement. JUDGE McDADE: Well, we're not going to
I mean the situation is the witness is
Page 1689 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
testifying. The witness well could be wrong. MS. SUTTON: And just mark our
objection, that he is not testifying on our behalf. We do object to that. JUDGE McDADE: I think it's quite
evident to the Board that he's not testifying on your behalf, and Dr. Hopenfeld is stating what his opinion is, and you certainly will have an opportunity to disavow it. can do it one of two ways. We'll probably be asking follow-up questions of your witnesses, and I would anticipate they would disavow it, and before we're all done with this, you'll have an opportunity to state from a lawyer's standpoint, and disavow it yet again. MS. SUTTON: JUDGE McDADE: DR. HOPENFELD: Thank you, Your Honor. Dr. Hopenfeld, continue. With respect to Revision But right now, and we
1, the original definition was confusing, because bounding, what does it mean? It wasn't defined. So
I believe somewhere there, and you know how the government works. comments. And evidently, that document for Revision 2 probably internally was circulating, and You get it out, you get a lot of
Page 1690 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
some of the initial circulation didn't indicate that there were comments with regarding to the conservatism. There were some other changes, but
there was not -Just before I think it went out for public comments, or maybe after it became public, that thing was added, about that it has to be conservative, or it has to be recalibrated. don't know who added complete. Now I
it, because I think it was not
But it was in the right direction. I believe it is better than it was
previously, because it was open-ended. defined. It's still not close.
It's more
It still needs some
fine-tuning, but I don't -- I don't think that they should just scratch it. decision. JUDGE McDADE: MS. BRANCATO: Okay. Your Honor, this is I'd just like to But you know, it's their
Deborah Brancato from Riverkeeper.
clarify, for the record, that in relation to Dr. Hopenfeld's characterization of whether Entergy was in compliance with GALL Revision 2, that is contained in A35 in Entergy's testimony. So his
understanding is based upon his review of Entergy's testimony.
Page 1691 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. Let me just sort I mean
of move on from here at the moment, okay.
first of all, these individuals are testifying as experts. They're testifying. For Dr. Hopenfeld, he
is recognized as an expert in Mechanical Engineering. As far as what Entergy is required to
do and what they aren't required to do, that's our job to figure it out. Ms. Sutton's comment, I think, was welltaken, in that Dr. Hopenfeld was going beyond his area of expertise. You as attorneys, before this is
over, will have an opportunity to comment, and ask us to draw conclusions from the testimony that's been presented by these experts, and what is presented in the record by Entergy. But you know, it's taken us enough time, you know, trying to get through this, where we're trying to limit the experts to engineering and technical issues. If we allow them to opine on
legal issues as well, we'll be here way longer. While we need them and rely on them as experts in Mechanical Engineering and Nuclear Engineering and Computer Science, you know, we can't rely on them for compliance and legal issues. We
have to make up our own mind on that, and that's not
Page 1692 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
wrong. fatigue. JUDGE WARDWELL: That's fatigue. That's exhibit. sorry. about? JUDGE KENNEDY: Scroll, roll it up. JUDGE WARDWELL: It's 108. Roll it up a bit. Page 39, please. Yeah, that's the wrong I'm little bit. JUDGE WARDWELL: interested in? DR. HOPENFELD: Which one are we talking Which question are you little bit. DR. HOPENFELD: Yeah, blow it up a subject to testimony. That said, Judge Kennedy. I guess I'd like to take If we
JUDGE KENNEDY:
us back to page 39 of the rebuttal testimony. could bring that up.
And again, my understanding in
reading that page of that testimony, you are challenging the effectiveness of Entergy's Aging Management Program for Flow-Accelerated Corrosion. DR. HOPENFELD: a little bit? Could you please amplify
I can't read it. Can we blow it up a
JUDGE KENNEDY:
We're looking for 108. Which looks like it's
DR. HOPENFELD:
Page 1693 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
Okay. DR. HOPENFELD: That's the wrong one. JUDGE McDADE: Exhibit 108, page 39. DR. HOPENFELD: Okay. I've got it now. It's exhibit, Riverkeeper This is metal fatigue.
The question is with regard to the comments I
made, that they don't have an effective program because there are leaks. JUDGE KENNEDY: There's no indication. And I guess what I'm I'm
wondering, there's no citation here to data.
just wondering how you formulated this opinion, and if the excessive wall thinning goes to your testimony about the model deficiencies of CHECWORKS, I don't think we need to revisit that. So I guess what I'm asking is, do you have anecdotal evidence of leaks that were not managed effectively before the loss of intended function, and do you have any evidence to put forward of excessive wall thinning, beyond the theoretical argument over the models. DR. HOPENFELD: They have testified that
they had observed like 15 leaks over a certain period of time. I don't remember what it was. Then
they also, and that really what got me there, when they explained how they are trying to prevent those
Page 1694 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
leaks from occurring, they said well, we located components and are monitoring based on -- when we observe a leak, then this is the database. My point was in here, and that was the main thing that I was thinking, you don't wait until you have a leak to tell you that you've got to monitor it. That was my thinking. Now again, the
bottom line is why they don't have an effective AMP was one, as I said before, there are numerous numbers. If you go to the data, and you see where they exceeded the critical --. on it. There are comments
I don't have it in front of me, but you go
through the data, and the data numbers you'll see, because they have a number that is critical, observed, and not observed. You'll see that many of them were observed, were exceeded. So I don't know what, what
part, the number of those components that are measured versus the total number of components, because they never told us. But I assume, if it's based on the philosophy that it is all corrosion control, and you don't take into account the local effect, going back to that, then there is a lot of unknown. You're
Page 1695 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
running the plants in unknowable condition. This one case that was brought in, it could be an outlier. But the fact that you don't
know and you can't even measure it, because of lamination, you still don't know what it is. So
it's all these unknowables put together, it gives you the fact that you don't have a program. JUDGE KENNEDY: So you would measure
effectiveness based on the components of the program, either not predicting the right wear rate or -DR. HOPENFELD: JUDGE KENNEDY: Frequency. And some leaking pipes
would be an effectiveness measure in your book? DR. HOPENFELD: Leaking pipes would be
one of those, yeah, would be an indication that you wait until a leak in the pipe. But, more important
than that, there was a statement made, and I can't remember where it was, when it was clearly stated we have thinning, wall thinning. Then we're going to assess whether that is adequate, as far as Part 50, which I mean as far as local loads or earthquake loads --. You don't
wait until the thinning is, reaches that point, and decide well, let's do some evaluation for that
Page 1696 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
times. JUDGE KENNEDY: I guess maybe I'll turn particular component. before you get there. You should have criteria So that is an indication
there is no AMP program. JUDGE KENNEDY: wall thinning. DR. HOPENFELD: JUDGE KENNEDY: thinning before failure? DR. HOPENFELD: Oh yes, yes. Many I'm sorry? They detected the wall But they did detect the
to the staff, just for some discussion about how they would view the effectiveness. How would you
measure the effectiveness of a Flow-Accelerated Corrosion Aging Management Program? If there's a
qualitative way you could describe what you would believe to be the attributes of an effective program. DR. HISER: The attributes of an
effective program, I believe, are outlined in the GALL report. In terms of assessing the
effectiveness of it, I think principally it would be based on operating experience. JUDGE KENNEDY: So it would be the
attributes of GALL, supported by operating
Page 1697 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? DR. HISER: Right, that indicates that If they
they would have an acceptance criteria.
approach or exceed acceptance criteria, then they take corrective actions such repair, replacement or reanalysis, as suitable. JUDGE KENNEDY: I mean I know it's
difficult, because we're not in the period of extended operation. But there has been a Flow-
Accelerated Corrosion Program currently in place at Indian Point, and does the staff view that program, under its current licensing basis, as effective? DR. HISER: Oh I think even in the
safety evaluation report for license renewal, the audit, I think we concluded that the program is effective, yes. JUDGE KENNEDY: MR. YODER: All right, thank you.
Also, the staff -- this is The staff had previously
Matthew Yoder, NRC staff.
reviewed the Indian Point Flow-Accelerated Corrosion Program as part of the power uprates. So we
provided a safety evaluation at that time, stating that we were satisfied with the Flow-Accelerated Corrosion Program. JUDGE McDADE: In his testimony, and
Page 1698 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
also in his expert report that he submitted, which is now Riverkeeper Exhibit 105, Dr. Hopenfeld referred to instances at Indian Point, and also instances at other facilities around the country, in which inspections uncovered component wall thicknesses below minimum allowable limits, including leaks from components that resulted from undetected flow accelerated corrosion. In light of that, has that caused the NRC staff to reconsider at all what its requirements should be, as far as inspections and evaluation of the impact of flow-accelerated corrosion? MR. YODER: First, I would state that
I'm not sure that we have seen any evidence, the NRC staff, that any leaks that have been identified by the licensee were indeed attributed to flowaccelerated corrosion. In other words, you know, these leaks that have been discussed may have been caused by another corrosion mechanism, which would not necessarily be reflected in the FAC program. JUDGE McDADE: Okay. Dr. Hopenfeld, going back to your report and beginning -- your discussion of this begins on page 17 of your report which is Riverkeeper Exhibit 105, what is your basis there
Page 1699 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 saying that these failures, leaks, and unacceptable thinning were the result of flow accelerated corrosion? DR. HOPENFELD: Well, first of all I define flow accelerated corrosion different than they do. I define it as erosion/corrosion, whatever it is, it is. The wall thinning is going to not
listen to what NRC thinks it should be. The erosion/corrosion is going to happen. Okay? that's what I'm talking about. Now, when I say FAC I don't make a distinction between this and the wall thinning. And I think -- so, let me start there. Again, there were 15 leaks over a certain period of time. They were reported. The explanation was given that -- one explanation was given when a leak occurs we're using as an indication where we should be looking for it. And I'm saying that is not how you manage a program. You try to avoid leaks, and you don't use a definition, an arbitrary definition to tell you what you should be looking -- having this part of your program, and that part of the program. And I'd like to congratulate the NRC. They have a document out there for public comments. I don't know if it -- it's in evidence I believe And
Page 1700 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
somewhere, where they said this whole issue of FAC and wall thinning has been very confusing. It's not consistent with what we have seen in the field. And they redefined the thing that FAC covers everything, the wall thinning -- actually, Part 54 controls it. And Part 54 is not talking about FAC, how EPRI decided to define it. It talks about wall thinning. And I think NRC has gone in the right direction doing that. It's out for public -- I believe it's out for public comment. And when that has come out it'll clarify some of what we're talking about here. JUDGE McDADE: Okay. But, Dr. Hopenfeld, then in your report where you characterize it as undetected flow accelerating corrosion, you then have several -- you have a citation then to several reports. Is it your testimony now that those reports don't necessarily use the same language that you do, flow accelerated corrosion, that they maybe refer to it as wall thinning from different phenomenon, including -DR. HOPENFELD: I would have to go look at the specific reports that you're talking about. But in general you are correct. My thinking, I'm not making a distinction. FAC as far as I'm concerned is
Page 1701 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 erosion. erosion/corrosion. They can call it any way you want to. I like to prefer calling erosion/corrosion, because as I said before FAC, cavitation, droplet impingement, they're all affected by flow. They are all accelerated by flow, so the terminology is poor. But forget about the terminology, it's not important. What is important is that we don't get ourselves confused. And what's confusing here, very confusing, the fact we say oh, we put that thing in a box. Well, this is FAC and I don't care, I don't look at anything else. And I think NRC is trying to correct that now. JUDGE McDADE: Dr. Hiser, let me go to you and ask, from your standpoint when you're talking about flow accelerated corrosion from speaking for the NRC, are we talking about corrosion alone, are we talking about erosion, a combination of the two, are we looking at wall thinning from any phenomena, any source? DR. HISER: Flow accelerated corrosion we consider to be the chemical dissolution process, the corrosion part that has been discussed the last two days. JUDGE McDADE: Not the mechanical forces
Page 1702 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. HISER: The FAC is not the erosion forces. It's not mechanical wall thinning. The License Renewal Interim Staff Guidance document, just to correct a little bit of what Dr. Hopenfeld said, the ISG does not broaden the definition of FAC to include the mechanical wall thinning mechanisms. But what it says is the FAC Program, the Aging Management Program addresses wall thinning due to FAC, but also due to the mechanical erosion sorts of processes. So, the definition of FAC is still what FAC has been, but the program, we agree, can address some of the other wall thinning mechanisms. JUDGE McDADE: Okay. Thank you, doctor. JUDGE WARDWELL: How much has erosion
created problems in your experience at nuclear power plants, and specifically Indian Point? DR. HISER: I'm not aware of specific operating experience at Indian Point, but the reason that the ISG was developed was that in general we expect that the mechanical erosion sorts of mechanisms will be treated as a design concern and will be addressed through changes in design. What we found was that in some instances plants have chosen to do aging management, so they're aware that, for example, cavitation is
Page 1703 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
in erosion? DR. HISER: Cavitation creates wall thinning from an erosion mechanism, yes. JUDGE WARDWELL: So, it would be lumped in with erosion? I always envision erosion as being a mechanical shearing, if you will, of the wall, and now we have cavitation, we have impingement, and we have dissolution, classical corrosion. DR. HISER: I guess what I would probably say is if we separate chemical wall thinning from mechanical wall thinning, and lump in the mechanical as erosion, cavitation, droplet impingement, et cetera, those kinds of things, within the ISG we have determined that because the FAC program is based on inspections of the wall thickness, the wall thickness measurements don't know that any wall thinning has been due to chemical or mechanical processes, so it measures everything. The one distinction that I think we make the Interim Staff Guidance is that the modeling, occurring, but they've chosen instead of making design changes, they monitor, do inspections, and then replace components based on the inspection results. JUDGE WARDWELL: But is cavitation
Page 1704 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: But not absolutely because it does have this line correction factor in. Doesn't that account for whatever wearing is occurring, just as you state? DR. HISER: I think that's another way -one could interpret the LCF that way, that it does -- clearly, since it's based on the inspection measurements of wall thinning, and they cannot differentiate chemical wall thinning from mechanical, then it is somewhat embedded. But I think in terms of the base predictive methodology, the predictive modeling is only for the chemical wall thinning, because CHECWORKS only models the chemical dissolution sort of process. It does not --
the equation with the F factors that does not clearly predict cavitation or the mechanical wall thinning -JUDGE WARDWELL: Is there an Aging Management Program for the mechanical wall thinning on its own? DR. HISER: I would -- I guess I would address that a couple of different ways. One is that if things like cavitation are identified, and I think they are noticeable beyond doing inspection
Page 1705 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
just due to the noise and things like that, then normally design changes are made, maybe different materials, some change is made to eliminate the mechanism. So, from that perspective it tends not to be a License Renewal and Aging problem, because it's remedied upon detection. ASME Code inspections and things like that would also serve to identify wall thinning due to erosion. But, in general, I think there are design changes that are made to eliminate the mechanism. JUDGE McDADE: But, Dr. Hiser, as I understand what you just said, that for wall thinning that is caused by mechanical phenomenon it can be from the NRC's standpoint adequately addressed either through design changes, or it can be addressed through an AMP. DR. HISER: The ISG to modify the FAC AMP does allow license, or applicants to incorporate the mechanical wall thinning mechanisms. JUDGE McDADE: Now, as part of that AMP would they need to have a mechanism in place for identifying the potential areas of mechanical -- of wall thinning through mechanical phenomenon? DR. HISER: The answer to that is yes. If
Page 1706 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 look at the description even of the current FAC program, it has three essential elements. One is performing an analysis to determine critical locations. Now, for FAC, CHECWORKS is normally used to do that along with the other tools that Entergy has described. The second element of the FAC program is limited baseline inspections to determine the extent of thinning at these locations, so that's inspection-based again. And then third is follow-up inspections to confirm the predictions, or repair or replacing components is necessary. So, there's three elements. Two of them would apply to any wall thinning mechanism. The first one of identifying locations would require some sort of an engineering evaluation for cavitation, for example, for the mechanical wall thinning mechanisms so that one could identify those areas that should be inspected. JUDGE WARDWELL: How would you suggest handling localized turbulence that may cause erosion that is hypothesized by Riverkeeper? DR. HISER: I really don't have an answer for that. But I think in general, I think the expectations is that with highly localized phenomena like that, that the leaks that would occur would not
Page 1707 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
challenge the functionality of the components. Conversely, FAC tends to be a broader surface area that's affected, and as the failures as Surry and Mihama indicated, they have catastrophic
consequences. Small leaks that may occur from highly localized degradation are a concern, but the safety implications are much less. JUDGE WARDWELL: When you said you're not sure how to answer that, that implies to me, and correct me if I'm wrong, that someone might interpret that to mean you aren't concerned with localized failure -- potential wall thinning, and that -- nor that you have either a design element that would address that as part of current licensing basis, and those activities, or an Aging Management Program system established to address that issue. Why am I wrong in that interpretation? MR. YODER: If I could help, this is Matthew Yoder from the Staff. I think that the Staff's position is similar to what you heard from the Applicant's witnesses, in that we don't believe that you have flow-accelerated corrosion as well as these what we termed local effects such as erosion or droplet impingement occurring in the same location.
Page 1708 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
written in What we've said in the Interim Staff Guidance is, and I'll quote directly from that, "For erosion mechanisms, the program includes the identification of susceptible locations based on plant-specific or industry operating experience. If wall thinning due to an erosion mechanism, e.g. cavitation, flashing droplet impingement, or solid particle impingement is identified, then the Applicant performs an extensive condition review to identify other components that are comparably susceptible to the same mechanism." So, I believe that sums up the NRC Staff's position on all of those localized effects. And I think as we heard from the Applicant's witnesses I believe yesterday, that's a separate program from what is dealt with in CHECWORKS, and it relies solely on operating experience and engineering judgment as the means to identify those locations. JUDGE WARDWELL: And are those part of the FAC AMP, or are those -MR. YODER: As the AMP is currently GALL Rev 2, it is not included in that.
Many licensees have chosen to include in their flowaccelerated corrosion AMP those mechanisms. Other
Page 1709 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
licensees have chosen to have those as a separate plant-specific program to monitor and trend those degradation mechanisms. JUDGE WARDWELL: Refresh my memory, what has Entergy done for Indian Point? And if you don't know, then I'll ask them. MR. YODER: I think we'd kick that one to the Applicant, if you don't mind. JUDGE WARDWELL: Anyone on the Applicant's set of witnesses would like to address that question? MR. COX: Well, I think the examples in our experience have been very few where you've had these other mechanisms acting. I think feedwater heater shells are one example where you have potential droplet impingement. There may also be some flow-accelerated corrosion going on there, but that is an example of operating experience where we've added things to the Flow-Accelerated Corrosion Program to address a mechanism that may not be 100 percent flow-accelerated corrosion. So, I think as the Staff indicated, operating experience, and the review of that operating experience is the primary analysis method that we would use to pick up any examples of
Page 1710 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
erosion, local erosion due to other effects other than FAC. DR. HOROWITZ: Jeff Horowitz. Two things about that. Number one, EPRI has put out some recent publications dealing with erosion and where to look, so I think that the industry will be fairly well covered by those publications. Secondly, the operating experience has been, as confirmed by one foreign utility, told us that erosion is an availability issue much more in the site. You get small holes, you shut the plant down. That's a problem. There has not been to my knowledge any significant erosion failures such as Surry, such as Mihama, such as whatever, as long as I've gone back and looked. MR. COX: And this is Alan Cox, again. I would agree with that. I'd like to add one thing, and Dr. Hiser mentioned this, that the whole issue of flow-accelerated corrosion has become what it is because of the catastrophic failures. And it's, as he explained, it could considered local corrosion to a component, but it's fairly widespread within the component. So, you wind up with a large area that sometimes gets very thin until it reaches a point where it ruptures in a fish mount or a double-ended
Page 1711 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
shear. It's a catastrophic failure. The erosion mechanisms that we're talking about here particularly much more localized, and you're not going to fail the entire component. You're going to have a leak. You're going to be able to detect that, take corrective action, but you're not going to have the kind of failures that you would get from a FAC failure of a large component that has widespread thinning in an elbow, for example. JUDGE WARDWELL: But in regards to my question, as it currently stands you don't have any extensive program associated with localized erosion types of failures in either your FAC or in your design basis approach to managing that? MR. AZEVEDO: Your Honor, this is Nelson Azevedo for Entergy. We do have cases where we have mechanical erosion going on when it's the auxiliary feedwater system. We do perform inspections and we track that in the FAC Program. And the location is selected just like FAC locations. The only exception is we obviously don't have CHECWORKS so we don't have a predictive model, but we use operating experience, we using engineering judgment, and we select those locations and we inspect them and we
Page 1712 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
121. JUDGE KENNEDY: Thank you. Yes, 121, page done. JUDGE McDADE: It's almost 3:30 right now, 3:25. It may be appropriate for us to take about a 10-minute break. Please try to be back in 10 minutes, and we will start up again at 3:35. Thank you. (Whereupon, the proceedings went off the record at 3:26 p.m., and went back on the record at 3:40 p.m.) JUDGE McDADE: The hearing will come to order. We're back on the record. Judge Kennedy. JUDGE KENNEDY: I have a question on the Staff's pre-filed testimony. I believe it's page 7, if you could put that exhibit up. I don't have the exhibit number. JUDGE McDADE: NRC-120. We're still getting to NRC-120. MR. TURK: Your Honor, I believe it's track them in the FAC Program. That's the one example where there's mechanical erosion going on, not FAC. And we do keep track of it in the FAC program. JUDGE WARDWELL: Thank you. I'm good. I'm
Page 1713 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
7. What I'm looking for and I don't see it -- oh, here it is. In the middle paragraph there's a -yes, thanks. The third sentence that begins, "The FAC Program." "The FAC Program and the implementation of CHECWORKS at Indian Point were important parts of the NRC approval of power uprate and associated change to the licensing basis for IP2 and IP3, but were not re-reviewed as part of the license renewal review." I guess I'm curious what that means, and what the import is relative to this proceeding, if any. MR. YODER: This is Matthew Yoder from the Staff. I think that what we're trying to say with that statement is that we did not review the current licensing basis as part of this license renewal application. We did go back and familiarize ourselves with previous reviews related to the technical programs that were associated with this license renewal application, but we did not base any decisions on license renewal on the current licensing basis, including those uprate reviews. JUDGE KENNEDY: So, the Staff did rereview the CHECWORKS implementation as part of license -MR. YODER: The Staff did go back and
Page 1714 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. MR. YODER: As part of our review of the License Renewal Application. JUDGE KENNEDY: All right, thank you.: JUDGE McDADE: Wall thinning as a phenomenon would necessarily be a ongoing process; therefore, when the plant was originally licensed, the original current operating basis was established at licensing. All of the pipes in the facility were new. At the time of the extended operation, if granted, all of the pipes that have not been replaced would already have had 40 years of wear. You indicated that their FAC Program was not reviewed as part of the license renewal, but wouldn't it be necessary to review a Aging Management Program for FAC specifically because all of the piping already had up to 40 years of age in it? Is this saying you didn't look at the Aging Management aspects of it? MR. YODER: No, I think what I'm trying read all of those previous flow-accelerated corrosion-related applications and subsequent safety evaluations. JUDGE KENNEDY: Under the license renewal
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to say is that we went into the License Renewal Application and gave that a clean look independent of what had previously been approved under the current licensing basis. That's not to say that we discounted any wear that had occurred prior to this application. So, the fact that these pipes have been in service was certainly taken into account as part of our review for license renewal. JUDGE McDADE: Okay. But I think the thing that had confused me, and I thought it had confused Judge Kennedy, is the language in here "were not reviewed as part of the license renewal review." And it would seem like the Aging Management Plan necessarily would be part of that review. Was it? DR. HISER: This is Allen Hiser of the Staff. I think the AMP we did review. There was -- I think there was a presumption that because the program is a continuing existing program without modifications, then we did not go back and review in gory detail the FAC Program itself. Now, during the AMP audit we did go back and review some of the underlying documents, such as the EN-DC-315, and some of the other procedures just to provide us with, if you will, additional
Page 1716 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
assurance that the program would continue to be effective during the PEO. So, I think that is what that wording is trying to indicate, that we did not go through and do a rigorous from the bottom up review of the program because it has been a longstanding program that has received review initially with the Generic Letter responses up through the power uprate reviews that were performed. JUDGE McDADE: Okay. Because on the face of it, it would appear inconsistent with what you had described earlier as part of the AMP audit that was conducted. And you're indicating that it's perhaps misleading saying not re-reviewed. You're saying it wasn't reviewed in the same way it would have been reviewed in a new license situation. DR. HISER: I think that's correct, yes. That's the way the wording -- that's the way we interpreted it, but I can easily see how the wording is not that clear. JUDGE McDADE: Okay. But there was a full AMP audit from your standpoint, and the Staff satisfied itself as part of that review that given the age of the facility and that the piping would be going from 40 to 60 years, that the program would be
Page 1717 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
Hiser. JUDGE WARDWELL: In that regard, I'd like to reflect back to yesterday, and you made the statement that you've performed an audit of Indian Point or something like that. And you quickly said something about either it was an 1170 audit, or that it wasn't an 1170, or maybe that isn't even the right number. But you were alluding to some sort of more detailed audit that other staff members may have been performing. And I wanted some clarification on what have you done at Indian Point to audit their AMP for flow-accelerated corrosion, and how does it compare to what you kind of alleged was some more detailed review, as I interpreted what you were saying yesterday? DR. HISER: Okay. Neither myself, nor I believe Mr. Yoder performed the AMP audit, but the NRC Staff did an AMP audit that went into a high with that. JUDGE McDADE: Okay. Thank you, Dr. adequate to maintain the reasonable assurance that they would operate appropriately and serve their intended purpose during that extended period of operation. DR. HISER: That's correct. I would agree
Page 1718 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
level of detail on the program. And that's reflected in our testimony through the reference to the AMP audit report, and then also in the SER. There are many parts of that report that are extracted and used in the SER to demonstrate acceptability of the program. What I may have mentioned is Inspection Program or IP71003 Inspection, and that will be implemented prior to PEO. Generally, it's implemented prior to PEO just to insure that the implementation of the AMPs, that the Applicant/Licensee is ready to implement those during the PEO. JUDGE WARDWELL: And is that a more extensive inspection than what the Staff has current done just to audit the AMP? That's what's kind -- I got the -DR. HISER: It really is different. The AMP audit is looking at is the program a program that's consistent with GALL. If implemented appropriately, will the program be effective? IP71003 Inspection takes it past philosophical, if you will, to do they have the right procedures in place for an existing program? They would take a look at operating experience, things like that to
Page 1719 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
41. MR. TURK: Your Honor, we need to verify. Sherwin Turk. Give us a moment, we'll see if that's correct. JUDGE McDADE: I'm sorry, Mr. Turk. I didn't hear what you said. JUDGE WARDWELL: In the process he -well, there it is. It's up before you so now you can -- the full page on that, please. Yes. So, is that correct, Dr. Hiser? DR. HISER: Yes, that's correct. exhibit? DR. HISER: Yes, it is one of the exhibits. That should be I believe Entergy 00041. JUDGE WARDWELL: Have you got that, ENverify the fact that the AMP has been, or is ready to be implemented for the PEO. So, there's different -- they're really shooting at different targets in this case. JUDGE WARDWELL: The AMP audit that the Staff performs as part of license renewal is documented where? DR. HISER: The AMP audit is documented in the Audit Report. JUDGE WARDWELL: Do we have that as an
Page 1720 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
pages long. JUDGE McDADE: Are you taking that just on Judge Wardwell's word? JUDGE WARDWELL: I know, because it says 99 next to the arrow there. Let's drop down to the Table of Contents, just for interest. No, keep it a full page. We don't want to get the detail. Just scroll down another page. Okay. I'm back to -- and I'm trying to tie the loop and complete the stuff I didn't get done yesterday, I guess. And I didn't have a chance to ask you the same thing I asked Entergy, and that is how many plants have you been participating in in regards to flow-accelerated corrosion AMPs? DR. HISER: Myself, personally, maybe eight or ten. JUDGE WARDWELL: Okay. How do the AMPs differ from the one that Indian Point has submitted? DR. HISER: In general, they're very consistent. Actually, let me clarify one thing. I was the Branch Chief of the Engineering Branch that reviewed the FAC Program at Indian Point, so I did not do the review myself, but I reviewed -JUDGE WARDWELL: You're familiar with it. JUDGE WARDWELL: And that document is 99
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yes. JUDGE WARDWELL: Because they're just -DR. HISER: 90 percent -- right. JUDGE WARDWELL: Yes, they're really repeating GALL back. DR. HISER: They're repeating GALL back, and GALL describes the programs that came out of the Generic Letters, and other generic correspondences from the late 1980s. plants? JUDGE WARDWELL: Yes. DR. HISER: I think -JUDGE WARDWELL: Close, would it be fair to say they're close to identical? DR. HISER: They're very, very similar, That's all I'm after. DR. HISER: Yes. It's very consistent. Again, this is -- the FAC Program is an existing program established across the industry in the late `80s, so it's a longstanding program, and has had really a lot of stability overall. JUDGE WARDWELL: On a scale of gee, it's very similar to almost identical where would you place all those AMPs? DR. HISER: You mean from the various
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you JUDGE WARDWELL: As a for instance, could convey to me why it is unfeasible to summarize
a part of this audit report and put it into an AMP to make it a little more site-specific, or infeasible, depending upon what is the correct English, or not feasible. DR. HISER: As an NRC Staff member, I guess my only -JUDGE WARDWELL: No, as a technical person involved with this, and as one who is experienced based on your demeanor and your expertise conveyed here, it's clear you are, you clearly are experienced, expert who might want to see some of this if it was in an area you weren't involved with. Would it not be feasible to do that? DR. HISER: I guess what -- if I can answer in two parts. The first part would be the AMP audit report is publicly available, and it really does provide a lot more information than likely would ever be in the application. The Safety Evaluation Report provides a lot of detail beyond what is in the application, so with those as caveats I would say there is a lot of information that is available. Would it be possible to provide more information in the application? Yes, I think it
Page 1723 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
clearly would be possible to do that. JUDGE WARDWELL: And one would be just summarizing aspects of the audit report. I've taken the whole 99 pages because that would be unreasonable in my mind. DR. HISER: Right. JUDGE WARDWELL: Thank you. MS. SUTTON: Your Honor, Kathryn Sutton on behalf of the Applicant. Just one point of clarification. The AMP audit report comes after in time, after the application is submitted and prior to issuance of the FSER. JUDGE WARDWELL: And recognizing that these don't come out at the same time, but still these types of information is feasible to put in to make it more site-specific, because you're aware of what's going on there because you've had a program in existence there that is merely being carried forward. So, in fact, you probably didn't discover much in your audit report that wasn't already known based on your previous experience base that you had for over a decade at the plant. DR. HISER: Although much of the information would have been available to the Staff based on prior interactions, reviewing Generic
Page 1724 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
Letter responses and things like that, the AMP audit is still -- is a fairly thorough review of what the -- how the Aging Management Program is implemented at the plant. JUDGE WARDWELL: I was merely using that as an example of some information that's available that again not you have to put in the AMP, but that you would ask the Applicant to do so that that would be information available to people to understand better how it is applied specifically to Indian Point. It's feasible to do that from a technical basis. DR. HISER: Yes. From the Staff perspective, because we do the AMP audit under a presumption that the program is consistent with GALL, we have access to that information. JUDGE WARDWELL: Thank you. Entergy, I guess I'll let whoever wants to answer this question answer it, but it came up yesterday and we really got busy with this topic, and I wanted to get back to it again. And that was the grid size that we showed over an elbow. There was a -- we looked at one figure that showed the grid size, and the size was predicated on the suggested values based on the pipe diameters or something like that.
Page 1725 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
Was any engineering judgment used in changing the grid size, or altering it, or do you often do that for components that aren't just straight line pipes? MR. AZEVEDO: Your Honor, this is Nelson Azevedo for Entergy. We use the grid size specified in NSAC-202L and in EN-DC-315. If we find signs of wear or signs of flow-accelerated corrosion going -wall thinning, we do go back and we either do grid scans or we do micro grids. In other words, we use the smaller grid size, but if all the inspections come back and they're consistent, then we just use the grid size that we started out with. JUDGE WARDWELL: Thank you. Dr. Hopenfeld, I wrote down things that you said that you were concerned about. And you said this is what I'm really concerned about, and later on today you say something else, and so I tried to jot those down. And here are some of the ones I've got. You mentioned concerns about turbulence, and that's localized erosion types of stuff caused by that turbulence. And that leads into the whole definition and whether erosion is part of corrosion was a concern of your's with this local phenomenon. The other one I heard you say is about
Page 1726 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 chromium content, and understand the chromium content. What I didn't hear you say, and I want to make sure that it isn't a concern, or if it is let's pursue it more, is something that was covered in your testimony. And this is the lack of benchmarking of CHECWORKS. Based on the direct testimony, has that started to drop down the ladder of your concerns? Is it not a concern any more, or is it still an issue? DR. HOPENFELD: Can I answer? JUDGE WARDWELL: Yes. DR. HOPENFELD: It originally was a concern. That's where the whole thing started. When I started -- after looking at 7,000 data points and after trying to get -- and I realized that some data points were going back to `92, we asked to see -let's see, compare the history of this. So, we asked Entergy to provide us data for prior to 2000, and they said we lost that. We don't have it, and it's misplaced, so we went and appealed to get the data. And they said it was denied. So then in the -- recently in their statement said well, we gave you all the data. It's somewhere among these points. I can't go -- no human being can go through these numbers and say yes, this
Page 1727 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: Is benchmarking still an issue, or have you been satisfied that it isn't any issue any more with -DR. HOPENFELD: I don't think it's an issue because it's impossible to benchmark it any came from 1991, December `91, Christmas `95. You can't say that. How I am supposed to go and tell you where this come from? And that's what the gentleman said, well, some of it was in `92. Can you tell which one? So, the issue came here after looking at all the data, and 40 to 60 percent of the time it was non-conservative. And I still believe the nonconservative thing is the right engineering approach, because all these things are not perspective. You have to have a non-conservative approach to this because there are so many assumptions, so many unknowns, so do the nonconservative thing. JUDGE WARDWELL: Can I just interrupt you quickly? I have no problem with what you're saying. What I would like you to do, though, is answer my question and then go on and elaborate. DR. HOPENFELD: Yes, I was just stating -
Page 1728 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
more. JUDGE WARDWELL: Why do you say that? DR. HOPENFELD: Because when you look at 7,000 points and all of them are not -- are scattered all over the place, and you look at the basic assumptions, there's no way to recalibrate it. If you don't know the chromium within a factor of 10, even with the same line, this component might have .05 and this one may have .02. How are you going to recalibrate something like that? JUDGE WARDWELL: Is there -- what's the difference between benchmarking and calibrating? I'm sorry. DR. HOPENFELD: I really don't know. I would -- my understanding is if you write F=AMX and then you say it's semi-empirical, I don't have empirical value to it. Then you run a whole bunch of tests and try to fit X with the data, and you call it calibrated. Now, benchmarking, I looked it up once but I don't know there's a major difference here. JUDGE WARDWELL: How would you benchmark this if you were going to do it? DR. HOPENFELD: I don't think -JUDGE WARDWELL: You're saying it's
Page 1729 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
impossible. How would you? DR. HOPENFELD: I wouldn't know how to do it. Oh, how? If I knew what the chromium content is, and forgetting -- assuming the measurements are okay, let's say they're all what I showed you, this lamination and -- not important. But assuming the measurements are okay, you have to know the chromium first. If you don't know the chromium, there's no way of doing. Secondly, you have to redefine what you're looking for. What is wall thinning? It's -the NRC defined it originally, didn't really define it but now they keep to the definition that FAC is only dissolution control. I showed you there's a factor of 50 there difference between a straight wall and an elbow. And it would be physically impossible, that kind of thing would be dissolution control. So, they don't separate the two. I think -I get my retirement from the NRC, let me give you - I would give them indirectly advice. Start from a clear definition. Don't patch up what you had before. Originally, the definition was incorrect. I think they are trying to patch it up now. I would go and redefine what really wall
Page 1730 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
thinning is. That's what you're interested. I don't care what caused that wall thinning. You want to come up with a program, call it any way you want to. This is wall thinning. Know what -- independently what the mechanism is. And what I was trying to show you with those numbers yesterday, that there's no way of distinguishing the two. Secondly, if you do mineralography on this, after you take and cut it out and look at it, you couldn't tell whether it was -- to some degree you could. You'd get some expert, and some degree you could, but not that easy whether it was erosion, corrosion, or whatever it was. It's the wall thinning that's important. That's why recalibration doesn't mean anything. JUDGE WARDWELL: So, this is really a challenge to CHECWORKS as a whole applied to all plants in the United States then. It's not unique to Indian Point, is it? Because it couldn't be done at Vermont Yankee or Indian Point, doesn't that say it probably can't be benchmarked anywhere? DR. HOPENFELD: I think it's an important question. I really should address that. And I focus on Indian Point, and Vermont -- although Vermont not that long. But I did focus on this particular plant
Page 1731 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 several reasons, because I got a lot -- they did give me a lot of data. After a lot of struggling we did get some data, so I did focus on that. But I have seen other data from other plants. In fact, they have been shown to the ACRS. And one of the ACRS members just threw his hand, said I don't believe, it doesn't make any sense. It's in the record. JUDGE WARDWELL: So, you have no reason to believe the same problem doesn't exist at other plants. DR. HOPENFELD: I do believe from what I've seen that basically the same problem exists in all of them. But, you see, the thing is, to a large degree these people applying it as some kind of a -mainly, it has been conceived for many years that it's primarily a cost problem, so it was kind of treated as a second cousin. It wasn't treated as a serious safety issue. I think there is a line here that we're getting into that 60-year life, that I am not sure that that cost issue is the only one. That's the point. I look into the sewers. I look in Rockville. We get blowing up pipes all over the place, and they've been there over -- I understand
Page 1732 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's not the same thing as a power plant. But the aging issue is the same thing. You go to power plants, non-conventional -- non-nuclear power plants. Their major deterioration -- one of the major cause is FAC. They call it wall thinning, I don't know, whatever you call it. But it is a cost problem primarily, but I -JUDGE WARDWELL: I guess I don't understand why it's a cost problem in regards to the calibration of CHECWORKS. DR. HOPENFELD: I'm sorry. You asked me what -- how does it affect other plants. JUDGE WARDWELL: Right. DR. HOPENFELD: What I'm saying -JUDGE WARDWELL: Let me be more specific then. I guess I wasn't clear enough. The problem that you've addressed here that you concluded that CHECWORKS can't be benchmarked so it's not a concern any more -DR. HOPENFELD: Correct. JUDGE WARDWELL: -- because you've
thrown up your hands and said it really can't be benchmarked. DR. HOPENFELD: Correct. JUDGE WARDWELL: Doesn't that apply -- do
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if problem. Entergy, whoever wishes to address this. JUDGE McDADE: Before you go to Entergy, I could just follow-up quickly with Dr. you have any evidence to show that that doesn't apply to every plant in the United States? DR. HOPENFELD: No, I do not. I do not. I haven't looked. JUDGE WARDWELL: So, there's every indication that, in fact, they're going to have the same situation. DR. HOPENFELD: I suspect that's the case, but I'm not going to say that. JUDGE WARDWELL: So, it is a global
Hopenfeld. Doctor, from your earlier testimony, direct testimony, sworn testimony, written report, it appeared that your concern or a concern you had on benchmarking was that there was insufficient data; that since the power uprates at Indian Point there have been insufficient data points from which an expert could conclude or could make a reasonable estimate as to the effectiveness of the program. Okay. And I thought you had testified yesterday with regard to discussing with Judge Wardwell about programs that are used elsewhere. And I think there
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was one -- a program, CICERO I believe it was referred to. DR. HOPENFELD: It was a different name, but close enough. JUDGE McDADE: That you thought was more effective not because it had more data points, but because it was more sophisticated. It had more input parameters into it. DR. HOPENFELD: Yes. JUDGE McDADE: And what I'm trying to understand right now is, is it your position now that CHECWORKS is deficient because there are not enough input parameters, or is it because there's not enough data input, or a combination of both? DR. HOPENFELD: I think the input uncertainty is a major uncertainty, a major contribution to this. If you have the input, let's
say for some reason they would measure the chromium content the way the French do, and use that in that F3, I mean, one of those, and use that, that would improve it. The second thing that I don't know how you improve is when you go through this very high turbulence, local thing in an orifice, an elbow, downstream, that is not fixable. That you cannot fix. So, you can recalibrate it. And the proof of
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that is they've been working on it for 20 years and you look before they operate and after they operate, there's absolutely no difference. JUDGE McDADE: Okay. When you say you can't fix it, are you saying that you can't fix it in the context of a computer code, or are you saying you can't fix it at all? In other words, I believe the testimony of the Entergy representatives were that for that kind of turbulence, those kinds of mechanical causes of wall thinning, they use different. They don't use CHECWORKS. They have several other engineering forms of analysis to identify those areas that would be subject to this wall thinning through a mechanical phenomenon. Why would that not be adequate for mechanical thinning in CHECWORKS if there were sufficient data for chemical wall thinning? DR. HOPENFELD: Because as I showed you yesterday on that elbow, in one place in this distance it's all chemical probably. It was very slow. Then you go into the high turbulence, it's all erosive. The mechanism changes locally. That's what the problem is. And when they're talking about what
you just said, they're talking about we have -- we are looking at where -- in area like a straight pipe
Page 1736 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
where we know it's dissolving equally, or they were looking at some places where we know there's a pressure drop and we have cavitation. We know we have wet steam and we have droplet -- that's what they're talking about. But you're still confusing this definition thing. When they say I don't see anywhere in this program whether trending or anywhere that you would take an elbow and look -- and do -- forget about the lamination, let's say you look at an elbow and you get one reading on the top, and then you go down and you say half an inch less. And then you ask yourself okay, how am I going to predict that from - when I should be looking at that elbow next time? And how am I going to do -- use this information on this elbow and go to the other room, or the next building, or whatever and determine that that elbow is going to behave the same way? I don't see anywhere in there. JUDGE McDADE: Okay. And, again, trying to divide this up so it's easier at least for me to grasp. As I understood the testimony of Entergy, they're saying CHECWORKS is only designed to identify those areas, those components that would be most susceptible, to rank according to
Page 1737 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
susceptibility those components subject to wall thinning through a chemical process. That's all it's designed to do. Now, is it your view that they have sufficient data points now to benchmark CHECWORKS for that limited purpose? DR. HOPENFELD: Sir, the reason I'm having trouble honestly is because I don't know how to separate the two. Because that data point that you showed here represent an average over that elbow. It's got the high local area where it was very turbulent. It's got the other area where it's fairly uniform. That's in there, so I don't know how I could really answer the question. That's my difficulty with the whole thing, because you cannot separate the two. And I showed you. That was my first thing yesterday showing you that look, I look at a whole bunch of points here, and it doesn't matter whether it's laminated or not, but I looked all over at enough components to show that the ratio is way above 1.6. If it was 1.6, that CHECWORKS is perfect. But it isn't, so you've got all these numbers here in between there, and I don't know how to do it. And I don't how to do it just even by trending. You see, even if I didn't have this, I
Page 1738 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 know how to do that. Maybe there's a way, some conservative way or some practical way of doing it. But I really didn't come sufficiently prepared to talk about it. It's not a trivial problem, because in the erosive kind of thing it -- by this kind of mechanism is not something we know how to predict. JUDGE McDADE: Okay. But you're -- what I'm hearing right now is you're testifying that additional data points, another year, another 10 years, another 20 years of data points wouldn't solve the problem that you perceive because it only addresses wall thinning by a chemical process, not a mechanical process. And the two are so intertwined that you can't separate them from a practical standpoint. DR. HOPENFELD: That is correct, if we pursue this program as you have done in the past. I'm not saying if you, as I said, start from scratch, a clean piece of paper, that you couldn't do more. You could come up with a little better -I'll tell you one thing that bothers me is, when I look at all the data, there's millions of dollars worth of good data in there, and I don't see anybody looking at it. Do you see what I mean? The thickness measurement guy writes a
Page 1739 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
report, it goes in there, and sometimes you see comments, sometimes you don't see it. Those are little comments of lamination, that's all it was. Believe me there's much more to this. JUDGE McDADE: Okay. But stepping back from CHECWORKS for a moment, because what Entergy, as I understand their testimony, is trying to explain is that CHECWORKS isn't their Aging Management Program, that CHECWORKS is used for a particular purpose which is to rank components for inspection priority. That's number one. Two, they recognize that there are components that can't be properly ranked for inspection priority using CHECWORKS and they've gone into great detail about the other mechanisms that they use to rank those. So, we now have two systems to rank components for inspection priority. They then do the inspections and then once the inspection is done, they then monitor those areas that have been inspected. If there has been significant wall erosion, they inspect them more frequently. If there has been not frequent, or not significant wall erosion, they inspect them less frequently. But that all that CHECWORKS does is just originally help them prioritize who -- which
Page 1740 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
just components they're going to inspect first. Now, as described the purpose of their Aging Management Program is to provide reasonable assurance that these components are going to operate as they are intended to operate during the period of extended operation. What else could an operator of a plant do to increase that insurance given what they have already done and the way they've described it, and the limitations of identifying mechanical erosion through a computer algorithm? I realize that's a somewhat complex question. DR. HOPENFELD: I think I understand the gist of it. I think the answer here is, for one, if you look at the data back to this thing, what you see, there was no scatter. It wasn't -- if it was only one one side. We've been through this this morning. But since it's all over the place, it's plus or minus, then you don't know whether you're selecting the right component or not. You may be selecting the wrong component, you see. So, using CHECWORKS as a guide, it doesn't -- the only guide would get you is if you have straight pipes. JUDGE McDADE: Okay. Let's go back and so I'm certain, from my standpoint you can't
inspect a wrong component. I mean, you can inspect
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it. The problem is if you fail to inspect a component that should have been inspected. DR. HOPENFELD: Right. JUDGE McDADE: That's what the issue is. (Simultaneous speech.) JUDGE McDADE: Not if you've done too many inspections, but if you have not identified a at-risk component which then can fail before you inspect it. But my question is can you suggest anything else that the operator of a plant could do in order to increase this level of assurance that hasn't been described by the experts from Entergy over the last couple of days? DR. HOPENFELD: Okay. I'd like to tell you what I -- from what I have seen. And, again, I'm at a disadvantage because I didn't speak to the French people, but what I saw in the paper that's in evidence, it looked pretty good. Hypothetically, let's say that all the data point that we saw this morning were on one side, conservative or not -- whatever it was. And there were thin scatter but, you know, like they had 40, 50 percent. Then I would say I probably could use the thing as a first level indicator what I should look further. It would be a good tool.
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Now, the difference is, what the French have there, first they measure the chromium. Secondly, they have some constants in there, and maybe some theoretical rationing in one of these F1 parameters for mechanical parameters, for droplets, or corrosion, or whatever they have. There was an erosion part of it in there. Now, how good this whole thing is is beyond me. I don't know. I haven't been there, and I really don't even want to go there. But to tell you, that would be the first thing that you would do. You have a first level looking at it, and say okay, well, you can look at this component. Then you look at experience, and look at elbows. But don't tell me I have something with lamination because that's really bad, because that tells you I have a component I don't know how to inspect. It's an uninspectable component. I wouldn't buy anything like -- and the question is how many more of those you have? So, if I have a Management Program, if I have components I don't even know to inspect, well, they're uninspectable, and I don't have a program. JUDGE McDADE: Okay, thank you. Let me follow-up. Mr. Aleksick or Dr. Horowitz, can you describe for us just very briefly what you view as
Page 1743 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 methodology for calibration, and how it is accomplished to calibrate the system? DR. HOROWITZ: Your Honor, if you could clarify what you mean. Dr. Hopenfeld was kind of varied all over the place about what you mean by calibration, benchmarking. JUDGE McDADE: Well, I'm concerned with what you mean by calibration, from the standpoint of Entergy when you're talking about calibrating the system, calibrating -DR. HOROWITZ: Okay, thank you. That's very clear. Calibration process is defined in NSAC202L, Rev 3, Section 4.1, I believe. And that gives the process for doing what we call calibration. The other processes which you folks have gone around is when we get -- we, EPRI, get user feedback, what do we do? Well, we investigate and if necessary fix the problem. We have roughly 100, 150 users, most of them go to meetings every six months, and if there's a problem we hear about it. If there's a problem, we hear about it and we deal with it. That's what we do. We have made -- we were talking last night about four or five significant changes since CHECWORKS has been about, about 20 years.
Page 1744 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, if you could go through it a little bit. You made reference to your guidance on it, and let me just sort of confess, I think you're going to be able to explain to me better than I will understand it from the document. So, can you just explain, sort of summarize for me DR. HOROWITZ: I think Mr. Aleksick probably does this more often than I do. JUDGE McDADE: Okay. MR. ALEKSICK: Thank you, Dr. Horowitz. I'm sorry, Your Honor. Could you restate the question for me, please? JUDGE McDADE: Can you just walk me through the calibration process? MR. ALEKSICK: Sure. Sure. Typically, immediately following the outage we have our data set of perhaps 100 components that have been inspected. We go through each one of those individually, look at the matrix of wall thickness measurements from each component. Go through a software process in CHECWORKS whereby we import that data, that grid of wall thicknesses into CHECWORKS, go through some manipulations in the program to eliminate a component -- eliminate -- I should say
Page 1745 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
disregard where measurements that might not be useful in calibration, and those measurements primarily consist of components where there is very little wear, or components where the wear is not caused by flow-accelerated corrosion. And then run a wear rate analysis inside of CHECWORKS, and what CHECWORKS does at that point is generates the scatter plots that we reviewed earlier, and also generates new sets of predicted wear rates, wall thicknesses, and times to Tcrit based on the new line correction factors that it derives from the new set of inspection data. JUDGE WARDWELL: Why is that a calibration? Isn't that just how you incorporate the measurements in, and proceed ahead with the program evaluation of the data? MR. ALEKSICK: It's a calibration because we are taking the CHECWORKS predictions and adjusting them upwards or downwards to match the field observations. So, in a sense, it's a continuous calibration. Every outage we calibrate and refine a little bit more. JUDGE WARDWELL: Using the line correction factors. MR. ALEKSICK: The line correction factor
Page 1746 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 -- yes, the short answer to your question is yes. JUDGE WARDWELL: And is there a difference between benchmarking and calibrating? MR. ALEKSICK: Not in the testimony that I have given. No, Your Honor. JUDGE WARDWELL: How many sets of measurements have you had since the power uprate? MR. ALEKSICK: Since the power uprate, I can do it roughly. The power uprate was in the 2004 time frame, I believe. We've had approximately on the order of 500 inspections since then, I believe. JUDGE WARDWELL: Now, over how many different outages? You only perform these when there's a power outage. Right? MR. ALEKSICK: Generally, yes. Occasionally, you might do an inspection at power, but the large majority are done doing refuel outages. For example, for Unit 2 the refuel -- the extended power uprate outage was refuel 16, and the most recent refuel in 2010 was 19, so that is a total of four refueling outages. And an average of 100 inspections per, that would be about 400 inspections. JUDGE WARDWELL: What did you notice in the wear rates between post and pre power uprates?
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MR. ALEKSICK: We looked at that from two perspectives. One, there was a power uprate revision to the CHECWORKS model at the time to revise the model to account for the new operating conditions
post power uprate. JUDGE WARDWELL: And by that you mean you incorporated the new operating parameters into the model? MR. ALEKSICK: Yes, the new temperatures, flow rates. There's some pH changes due to the temperatures changes, so the model now contains both pre uprate operating and chemistry conditions, as well as post uprate operating conditions. JUDGE WARDWELL: And it's able to use the pre ones for those data points that you had prior to the uprate and applies the new ones to the new points, I gather. MR. ALEKSICK: Yes, Your Honor. And we prepared -- and it's one of our exhibits, a document for each unit to document and draw conclusions from the CHECWORKS model after it had been revised to account for the power uprate. And depending on the level of detail you wish to go into, I can point you to tables comparing before and after, and the limiting examples. But the short answer is, we saw -
Page 1748 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
- in terms of CHECWORKS we saw very small predicted changes on the order of 1 to 4 mils per year at the high end; 1 to 4 or negative 1 to negative 4 both, sometimes the wear rates decrease. So, very small changes. JUDGE WARDWELL: Compared to what is the wear rate -- what was the wear rate before? MR. ALEKSICK: Maybe a better way to say it is in the most extreme cases of changes -- and remember there are 8,000 modeled components, and of those 8,000 modeled components if you look at the top 10 and sort them by the largest changes, the largest changes were on the order of 1, 2, 3, maybe as much as 4 mils per year, which is a very small number considering that the average predicted wear rates might be 10, 20, or 30 mils per year. JUDGE WARDWELL: I'm not sure who this should be addressed to at Entergy, but have you considered measuring chromium, and if you decided not to, why haven't you? MR. AZEVEDO: Yes, Your Honor. This is Nelson Azevedo for Entergy. We do have a metal analyzer. We do have the ability to measure chrome, and we do go out there and measure chrome when we feel that's appropriate. So, if there's some
Page 1749 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
indication that the chemical content of the component may have additional alloy material, in the case of chromium, we do have the ability to go out there and measure, but it's on a limited basis. JUDGE WARDWELL: When you've done that have you seen any reduction in the scatter of those scatter plots that CHECWORKS provides as output? MR. AZEVEDO: Well, we don't really do it to enough data points to impact the scatter. Again, as I said, we'll measure, if there's 1, 2, maybe 3 locations in a given outage that we feel it's appropriate, we'll go out there and measure. But it's a small number, so I wouldn't expect it to impact the scatter of the data. JUDGE WARDWELL: Is this a laborintensive measurement? Is it non-destructive? Give me some feeling for what type of -MR. AZEVEDO: It's not because it's labor-intensive. You have to keep in mind if you go out there and measure the chromium content, it's not necessarily uniform throughout the entire component, so it will give you kind of better than order of magnitude. It will tell you if you have significant chromium content or not, but it's not going to measure the chromium content at every location in
Page 1750 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 component because it varies. So, you know, if we assume a very low chromium content, you go out there and measure, say twice as high, we know what -- this explains where it was lower or vice versa. JUDGE WARDWELL: Switching topics -- does anyone else have anything on benchmarking or calibrating? Hang on just a second. I'll refer you, hopefully this is correct, to Entergy's testimony 029 on Answer 86, page 59. Now, after I stated that I'll look it up to see how wrong I was. Oh, I'm sorry, I was on page 86, looking for answer -- yes, and it's on the very bottom of that page, the last paragraph. No, we want to be on page 59, answer 86. Right there at the very bottom. The reviewer then classified Analysis Lines as either calibrated or non-calibrated. Can you go on and discuss how that's done, and why it's done, and then what impact it has on CHECWORKS? MR. ALEKSICK: Certainly, Your Honor. Rob Aleksick for the Applicant. If you'll indulge me, I just -- I want to grab one document. JUDGE WARDWELL: Sure. Dr. Hopenfeld is laughing that we need as much attention with our microphone as he does.
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Sorry. MR. ALEKSICK: To answer your question, Your Honor, following the process I described a moment ago about the importation and evaluation of the inspection data in CHECWORKS, we follow a process of reviewing the new CHECWORKS predictions to determine if -- to determine their calibration status. To do that, we follow the guidance in NSAC-202L, specifically on page 4-1 as referenced in our testimony. There are five criteria that we apply to determine if any given Analysis Line is or is not calibrated. In brief, those are first that the Analysis Line is defined properly, that is to say that the physical plant lines analyzed together are experiencing similar operational and chemistry DR. HOPENFELD: I'm sorry. I didn't hear. JUDGE WARDWELL: You're laughing at us that we need as much care taking by our IT with our microphones as you do. DR. HOPENFELD: Oh, I'm just not used to this kind of setup. I'm used to the old pointers. MR. ALEKSICK: This is Rob Aleksick, again, for the Applicant. JUDGE WARDWELL: Chalkboards, right?
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conditions. The second is that at least five inspections have been performed in that line. At this point in the life of the FAC Program, we've far exceeded that in essentially every inspection. We've done I believe approximately 3,700 FAC inspections over plant -- CHECWORKS FAC inspections over the plant life. Third, that the Line Correction Factor is between 0.5 and 2.5. Fourth, that a reasonably good correlation exists in that scatterplot, the same on that we reviewed before. And, finally, that the inspection coverage in the line under consideration considered a variety of geometry -component geometries. So, based on those factors we go through each line, determine whether or not it is -- whether it meets the criteria to be considered calibration. We document that analysis in Appendix B of the SFA reports that are provided as Exhibits 50 and 51, Entergy Exhibits 50 and 51. There's a table in there that lists a clear yes or no, is it calibrated, and a clear response to each of these criteria, as well as a verbal discussion of the reasoning behind the conclusion. JUDGE WARDWELL: And what is that used
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for, just to flag things as being calibrated or noncalibrated, or is there some other use that's made of that? MR. ALEKSICK: It's used partially to flag whether it's calibrated or not. It's also used when we proceed to the next refueling outage and we're identifying the set of components that we wish to inspect, the new inspections. Again, if a component has been previously inspected, the determination of when to reinspect it is based purely on the trending and the measured wall thicknesses. But for uninspected components, we use the uninspected modeled components. We use these determinations of calibration in selecting where and how many components to examine. So, for example, in a poorly calibrated line that has wear in it, we will examine a much larger number of components. I would like to point out that one of the, and perhaps the primary reason for lines to be not well calibrated is the instance where there's very low wear. And in that case, the measurement uncertainty of the UT process is larger than the wear, so it becomes essentially impossible to -- the wear is essentially undetectable, so those runs
Page 1754 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
remain uncalibrated. But the good part of that is that these are very low wear lines that we don't have a great deal of concern about. JUDGE WARDWELL: Where did you come up with, or where did NSAC come up with the values in 0.5 to 2.5? It seems like a strange set of numbers. DR. HOROWITZ: Jeff Horowitz, again. The -- those numbers date back to CHECMATE, when CHECMATE was released in `89. We put those numbers out as guidance based on the early data we saw in the beta test, and we waited for people to say these are too big or too little, and nobody has talked to us about them since. It just seems to match the process. JUDGE WARDWELL: Is there a reason why they're skewed one way or the other? I mean, from .5 below to 2.5 above the one line is what it means. Right? DR. HOROWITZ: I think that's a real good question, one I've never thought about. But I think the answer is because you tend to overstate the wear, the measured wear by nature of the process for calculating it. JUDGE WARDWELL: At Indian Point, do you have a rough idea of how many of the lines are
Page 1755 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
calibrated, how many are non-calibrated? Just to get a feeling for what's there. DR. HOROWITZ: I believe it's in testimony. I'd have to look for a second to find it. JUDGE WARDWELL: Does anyone know, approximately? We don't have -MR. ALEKSICK: I can answer. This is Rob Aleksick. Approximately two-thirds of the lines are calibrated. JUDGE WARDWELL: Dr. Hopenfeld, when you looked at the data did you observe any accelerated wear rates beyond the levels that were reported here by Entergy after the power uprate? DR. HOPENFELD: No, you couldn't tell the difference. There's no -- the scatter was the same. I'm sorry. That's what I'm saying, it's not -- it can't be recalibrated, first, because after 20 years it hasn't been calibrated, so -- and after the uprate -- first of all, there wasn't a huge uprate. I mean, the change in velocity weren't that huge, although the temperature could have affected it. However, you couldn't tell. There was no difference as far as the scatter. And if it was only 2 or 3 mils, that would be within a factor of 10 of their uncertainty. You couldn't tell.
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come from. JUDGE WARDWELL: How would you derive But my problem, my pain with this thing is, if I may, or I'm just straying off the farm again here. Can I say it? But we have been asking Entergy for four years, and asking them where is that .5 to 2.5 comes from, because it's a criteria. It's how -JUDGE WARDWELL: And who is "we" that's been asking them? DR. HOPENFELD: Through our attorney I've been asking. We asked Entergy to tell us where that comes from. We got a reply in their initial statement, or in reply to our questioning this, and they said we don't really know where it came from. And just as Dr. Horowitz said, it was there. Now, if I was starting from scratch, I would come up with a criteria that is controlled by safety. That's what I'm interested -- I'm not interested in anything else. Now, if it comes from cost consideration maybe there will be a different criteria. JUDGE WARDWELL: How would you derive those numbers for safety? DR. HOPENFELD: I don't know where they
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them from a safety standpoint? DR. HOPENFELD: Oh, I would say that it - I would -- I can't answer your question here right now. I would have to do a lot of thinking. My criteria, if something is acceptable or not would be based on safety. In fact, I probably wouldn't even consider a whole bunch of components that wouldn't fit into that because they're no major safety concern. So, I -- the criteria of acceptance of that kind of data should be based on safety. How to do it, I really don't know how to answer right now. But I just could never understand the .5 to 2.5. Secondly, if you look at the instructions that they have to their -- whether the data is acceptable or not is plus or minus 50 percent. That's reasonable, and it's an acceptable. If you go out to the data sheets that they have provided, where they have looked at, a lot of comments, and there's a lot of leeway, and there's a lot of judgment as to what they include in the calculation, and what's not included in the calculation. So, a person like me, all he can do is just look at the data they provide us. That's all I can do. I don't know how much was excluded. How much is not included in here.
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JUDGE WARDWELL: Thank you, Dr. Hopenfeld. Mr. Azevedo, I think maybe the best person, but if not, anyone from that back table is free to chime in. But about what is the precision of UT measurements? MR. AZEVEDO: I would say it's pretty precise. There's a -- the NDE inspector when he goes out to inspect his pipes he has a calibration block which is a step-wedge, and he calibrates his transducer from say 50 mils up to 400 mils, whatever the different steps are depending on how thick the pipe is. So, it's pretty accurate, pretty precise. Now, the roughness of the pipe does impact the accuracy a little bit, but I'd say it's very precise. JUDGE WARDWELL: So, do you disagree with Dr. Horowitz, who claimed that the scatter was reflected -- that the precision of the measured rates, the measured wear, wasn't rates in fact, the measure of wear was as much if not more than the scatter from anything else associated with those plots? MR. AZEVEDO: No, I wouldn't disagree with him. There is some uncertainty, it's not 100 percent, and especially if you're talking about wall
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wear. As Mr. Aleksick said, uncertainty in the measurement -- and there is uncertainty. I would say it's small, but it's not zero, it would impact the calculation of the wear. JUDGE WARDWELL: But doesn't that equipment have some indication of what its precision is, and if not, couldn't you determine it just by taking repetitive measurements to get a handle on how well that instrument can actually provide the data? MR. AZEVEDO: Well, the instrument is pretty accurate. I mean, not 100 percent, but pretty accurate. The factors that impact the accuracy of the actual number is the -- how smooth is the outside surface of the pipe, and how smooth is the inside surface of the pipe. That does have an impact, because keep in mind you're sending a sound wave through the pipe, and most of these pipes are a quarter to three-eights of an inch thick, so if the roughness -- you know, if it's not perfectly smooth it does have a little bit of impact, so it's not 100 percent. But the instrument itself, that's pretty accurate. JUDGE WARDWELL: So, you're saying the instrument is accurate when you actually get into
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the field and perform a measurement, if you could precisely replicate that in the field several times you're liable to get a variation on top of the imprecision associated with the instrument itself that would lead to a wider scatter of the measured rates in addition to the CHECWORKS predicted rates. Is that what you're saying? MR. AZEVEDO: Yes. DR. HOROWITZ: If I may, Jeff Horowitz again. It's not so much the accuracy of the measurement, it's the fact you're going to be subtracting about the same number from it. So, therefore your error propagate and go through the process of comparing matrices. It turns out it propagates a lot big number than you would think off hand. JUDGE WARDWELL: Dr. Horowitz, do you have any comments on what they just stated -DR. HOROWITZ: Are you asking me? JUDGE WARDWELL: Dr. Hopenfeld. DR. HOPENFELD: I'm sorry. Sure, absolutely do. First of all, I'm -- you know, terms like small, good, these are not engineering terms that I'm used to. I don't know what it means. But it's true, it depends on the coupling, it depends on
Page 1761 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 training of the operator, how many points does he take. All that is not described, so I really don't know to what degree, whether he takes one -when he says .5 free, is he taking the lowest point? Where did he take it? If your question was what's the accuracy and the main thing in the answer was the fact, take a look. The figure that I showed you on the first day there was a gradient over there, even though lamination, whatever, but there was a gradient there. There was a change in one inch over six inches. Okay? That's roughly like -- what was it, about 160 or 170 mils per inch. And that particular transducer has a thickness to it, so because of the
steep change that -- if it's -- if the transducer is -- it was like 320 mils. Okay? Sees a 50 mil
gradient, so you know right there it's not -- it must be less than -- because average -- there's a whole technique or statistical analysis to do, which they completely ignore, and it's not even included here. It should, but it's not, so at least 52. And then the operator doesn't tell you if you have a gradient like that going from 1.46 or the number I used going down to .513, you don't know where he measured. He could have -- I mean, maybe the --
Page 1762 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
there could have been a point there that was zero he completely missed, even if it wasn't a lamination. Now, this may be an extreme case that these are very high gradients, but there are other cases, not as much as an elbow. You really more -when you look at orifices because over a very short period of time you can have a lot of changes. And, also, the small piping, where you can very, very large gradients. So, this is an over-simplified explanation of UT measurements. There's much more to it. I would -- I don't know. I've looked all over, I didn't see any report as to what the probability of missing it, what's the probability of error? If you go into experience of steam generators, you always -- people specify what the probability of missing a crack in the tube. There's nothing here. That's not how you report ultrasonic testing. But when I said there's no AMP, that's one component of it. It's not there. JUDGE WARDWELL: Thank you. One last question for you, if I can find it now. Bear with me just a second while I search. On page 45 of your rebuttal testimony, that's Riverkeeper-108, if we
Page 1763 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
could get that up on the board. Page 45, and go down to the bottom line, 21-23, no, 20-26. DR. HOPENFELD: Can you blow it up for me, sir, please? JUDGE WARDWELL: Yes. DR. HOPENFELD: Okay. JUDGE WARDWELL: And it starts with the words, "First, in that statement I was not discussing balance of plant components but rather reactor vessel nozzles which are part of the reactor cooling system. Second, my comment about the stainless steel cladding was related to the fact that in their fatigue analysis, Entergy used a model for an unclad nozzle." Did you bring up anything in regards to these nozzles in your direct testimony? DR. HOPENFELD: In my direct testimony? No, this was a fallout of the fatigue thing, because this was related to the fatigue issue. JUDGE WARDWELL: And did Entergy comment in regards to these fatigue issues in their direct testimony in response to something Entergy said? DR. HOPENFELD: They said it has nothing to do with CLB, and if I may, I'll have to go to the physical problem here, what really I was talking about. It is related to that issue.
Page 1764 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: To the fatigue issue? DR. HOPENFELD: Yes, it is related to the fatigue issue, because in the fatigue table, in their results they indicated that the inlet nozzle - or using the fatigue calculation like it was carbon steel. JUDGE WARDWELL: Okay, excuse me for a minute. Let me make sure I understand this. DR. HOPENFELD: Yes. JUDGE WARDWELL: You're responding to a statement that Entergy made under the fatigue contention, or did they -DR. HOPENFELD: No. JUDGE WARDWELL: -- make in regards to
their direct testimony in response to your direct testimony? DR. HOPENFELD: Honestly, I don't know the response -- I think their response was in connection with the fatigue. But I raised the thing as a technical issue because if you don't consider the cladding or -- and it's -- because one of the NRC documents requires you to take environmental effects in consideration. And if there's a possibility that the cladding will corrode, or crack, or disappear then you have a bare metal, then
Page 1765 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 do have an FAC problem. But it's not -- and there has been analysis when you have a cracked nozzle what kind of corrosion do you have in the crack. It's not insignificant. So, that's how it comes in there. Now, whether it's legally related to this document, that document, I honestly don't know. I may be off on that. MS. BRANCATO: Your Honor, Deborah Brancato for Riverkeeper. If I could just clarify the record for you. Dr. Hopenfeld did raise this concern related to metal fatigue in his direct testimony, and what you are referring to now in his rebuttal is in response to Entergy's response to that initial testimony. And I believe if you go down to the footnotes, this testimony is in response to Entergy's testimony at Answer 144. JUDGE WARDWELL: 144, thank you. MR. FAGG: And just so the record is clear, we understand that's not testimony by counsel. Right? That was a clarifying statement. MS. BRANCATO: That's correct. MR. FAGG: I'm sorry. Brad Fagg for Entergy. It sounded a bit like testimony to me, but just so the record is clear, that's not testimony,
Page 1766 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 clarifying statement. Correct? MS. BRANCATO: That's correct. JUDGE WARDWELL: That's clear, yes. MR. FAGG: Thank you. JUDGE KENNEDY: I have a couple of just follow-up questions based on the discussion here. One point going back to yesterday, we were discussing the linearity of the wear rate, and I think Entergy testified that if we wanted to understand whether the wear rate was linear, we should look at Dr. Horowitz' book. And I guess now that we've heard there's been 3,700 inspections at Indian Point, I'm wondering if there's anything in the data that's been taken at Indian Point that would inform the linear assumption of wear rate. If anyone from Entergy is willing to comment. MR. ALEKSICK: Rob Aleksick for the Applicant. Yes, Your Honor, one could go back to the data set of 3,700 historical inspections. Some of the components in that data set have been inspected multiple times, two, three, four times over a period of many years. And plot those, and I think demonstrate the linear nature of FAC. We have not done that as far as I know, because there's no reason to do so, but I'm sure that would be --
Page 1767 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 a possibility. JUDGE KENNEDY: And is the fact that there's no reason to do so because after the first pass you're using measured wear rate? Why would you not think it would be useful to mine that data? MR. AZEVEDO: Your Honor, this is Nelson Azevedo for Entergy again. You could as a theoretical exercise. You have to keep in mind that because of the changes in chemistry since the plant first went on line, you have to adjust that wear rate for a given cycle for the operating conditions. That would be very difficult to do. It could potentially be done, but we don't really see any benefit of doing that. JUDGE KENNEDY: So, there may be insufficient quality data to make an informed -could you -- I'm understanding you could not make an informed decision based on the Indian Point data at this point. MR. AZEVEDO: Well, we haven't done that. We have, to be honest with you, haven't thought about it. But if we were to go back and do that, we have to, again, adjust the wear rates for each cycle based on the operating conditions for that cycle. And because the operating conditions, namely the
Page 1768 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
chemistry, have changed over time, we would have to adjust the data to account for that. JUDGE KENNEDY: Thank you. MS. BRANCATO: Your Honor, I apologize for the interruption, but -- this is Deborah Brancato from Riverkeeper. Given the subject matter, this may be an appropriate time, and if it's not, just advise me to revisit the earlier issue we had before lunch where Dr. Hopenfeld -- we were discussing non-linear corrosion, and Dr. Hopenfeld was citing to instances. And there was a problem identifying the document. And during the lunch hour, Riverkeeper did find the documents. They are not currently in evidence, but Dr. Hopenfeld has identified two examples that illustrate his point. And they are Entergy documents that were provided in discovery, sent via email, the particular documents to Entergy's counsel. And though they are not currently in evidence, I do believe it will be helpful and beneficial given the lengthy discussion that was had earlier to clarify the point that Dr. Hopenfeld was trying to make. JUDGE McDADE: Okay. They're documents you received through discovery. They have Entergy Bates stamp numbers but they have not been received
Page 1769 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
in evidence at this point? MS. BRANCATO: These particular documents do not have Bates stamps but they were received in discovery, and that is correct, they have not been received into evidence. MR. KUYLER: Your Honor? JUDGE McDADE: Just one second. What I'm going to suggest is this. We are -- and I realize you probably never thought you would hear this, we are nearing the end of our questioning on Riverkeeper-TC-2. One of the things that based on the nature of the testimony that we have that we were going to propose is to allow Entergy, Riverkeeper, and the NRC Staff if they wished to conduct a brief interrogation of the witnesses to incorporate both what could be considered redirect and also cross. If there is testimony of your witness that you believe perhaps has come out unclear, and that the Board could be misled as a result of it, you will be offered the opportunity to clarify that through your witness. And, also, if you wish to bring out something through one of the other parties' witnesses, allowed to do that briefly. Many years ago, I used to teach some trial practice at the Department of Justice, and one
Page 1770 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 things I used to say is that redirect, the value of redirect testimony tended to decrease exponentially after about 10 minutes. So, what we are going to do is allow a very brief period of time. But what we could do at this point is break. There is a possibility after we review our notes that we may have a few more questions of these particular witnesses. At that point, over the course of the evening, Ms. Brancato, if you could provide those documents to Entergy so that they would have an opportunity to review them and to comment as to whether or not they should be received into evidence before we get started tomorrow. And then when we get started tomorrow, as I said, there's a possibility we may have a few more questions in the morning based on a review of our notes, at that point ask you with regard to your desires to ask to interrogate the witnesses again very briefly. I would anticipate that the entire process for all
three of the parties involved in this contention would be under an hour. And, also, if there is anything that needs to be clarified with those documents, if they are received in evidence, Ms. Brancato, you will be able to ask Dr. Hopenfeld
Page 1771 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 them. I believe that if Judge Kennedy had a few more questions that he wanted to go through this evening before we break, but what I would propose to do is to have Judge Kennedy finish up those few questions, to then break for this evening, and then that would give you the opportunity, one, overnight to perhaps edit the several hours of questions that you've developed over the last couple of days down into what we view as a workable time frame. And, also, make the decision, first of all, whether or not you wish to avail yourself of that opportunity. So, to a degree I'm sort of making a motion for you to allow the interrogation of the witnesses, and then allowing you to comment on that first thing in the morning. Anyway, that's something to think about. Judge Kennedy, if you'd finish up with your questions for this evening. JUDGE KENNEDY: Thank you, Judge McDade. I have two questions. First is for Mr. Aleksick. This is Judge Kennedy. I want to clarify, you were referring to Entergy Exhibits 50 and 51. And I -- the way I understood it, they contain the summary of all the
Page 1772 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
appropriate data for CHECWORKS. Is that true? MR. ALEKSICK: Yes, Your Honor. JUDGE KENNEDY: So, all the relevant data, whether we're talking about calibration, benchmarking, but it is the relevant inspection data for Indian Point Units 2 and 3 in those two exhibits? MR. ALEKSICK: The reason I'm hesitating is that -- the answer is yes with respect to all modeled components and all of the inspection data collected for those components. However, there may be non-modeled components that by definition are not in the CHECWORKS model; and, therefore, the data is not in it. JUDGE KENNEDY: So, it's the data relevant to CHECWORKS. MR. ALEKSICK: It's the inspection data of CHECWORKS modeled components, yes. JUDGE KENNEDY: I wonder if we could put Exhibit 50 and 51 on the screen, at least the first page, Entergy-50 and Entergy-51. I guess I'd like to turn to Dr. Hopenfeld. Did you have a chance to review this information? Is this the data you were talking about? DR. HOPENFELD: I don't know what I'm
Page 1773 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 F. JUDGE KENNEDY: Did it give a page number on the Table of Contents? JUDGE WARDWELL: Well, the text is about 41, I think, because it says page of 41, so if we go down that will bring us to Appendix A, at least. MR. ROTH: Your Honor, it's Dave Roth for a page? JUDGE KENNEDY: I do not. I was hoping it would say Appendix F. Maybe we should go back to the Table of Contents. I'm -- it's my understanding that the data is contained in Appendix F. JUDGE WARDWELL: UT inspection data is looking at. I see CSI -JUDGE KENNEDY: Would you like us to scroll through it a bit? DR. HOPENFELD: Yes. JUDGE WARDWELL: This is Entergy's Exhibit 51. Is that correct, Andy? DR. HOPENFELD: It looks familiar. Yes, I'm sure I looked at it. Yes. I went through it, absolutely, yes. JUDGE KENNEDY: Maybe we could take a look at Appendix F. And maybe not. PARTICIPANT: Judge Kennedy, do you have
Page 1774 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 Staff. It looks like it's page 200 of 1,277 in the PDF. JUDGE KENNEDY: Thank you. JUDGE WARDWELL: One thousand -JUDGE KENNEDY: Two hundred -MR. ROTH: Page 200 of 1,277. (Off the record comments.) MR. ROTH: Your Honors are on Exhibit 50 or Exhibit 51? JUDGE WARDWELL: We're on 51. MR. ROTH: Okay. JUDGE KENNEDY: I'm looking for Appendix F in either document, and I guess what I'm trying to pursue here is whether Dr. Hopenfeld had a chance to review this data. DR. HOPENFELD: I've looked at all these documents. To what degree, I don't know. JUDGE KENNEDY: Mr. Aleksick, is this the inspection data for the modeled components that you were referring to? MR. ALEKSICK: Yes, Your Honor, this is one location. It is in other places, as well. This is the most -- this is the best summary. JUDGE KENNEDY: Mr. Aleksick, do you have a sense of how far back this data goes?
Page 1775 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: Yes, I have more than a sense, Your Honor, I know precisely. If we look at page F-2, Foxtrot 2, the very top line working from left to right you see the CHECWORKS line name at the very top, the component name within that line, and go a few -- to the fourth column, it says "period." So, that component was inspected in Refuel 8 which was in 1992. JUDGE KENNEDY: 1992? If we were to look at the -- I'm sorry, this is Unit 3, or Unit 2? MR. ALEKSICK: Unit 3, Your Honor. JUDGE KENNEDY: Now, if we were to look in Exhibit 50, I think it -- we could go through Exhibit 50. MR. ALEKSICK: Yes, Your Honor, there is an analogous table, or an analogous appendix in Exhibit 50. However, in that -- that is the Unit 2, which had a change of ownership before it was -- it was a Consolidated Edison Plant before it came under the umbrella of sister plants with Unit 3. So, the history of the Unit 2 document here starts at a later point in time, so that table in that exhibit does not go all the way back to that outage. However, there are -- I can point Your Honor to different sections in that report that do provide
Page 1776 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
traceability back to I believe it's 1993, where there is UT data from that period. JUDGE KENNEDY: So, I wouldn't look in Appendix F to go all the way back to the original, or the oldest data that may be exist for Unit 2. MR. ALEKSICK: That's correct, Your Honor. I would point Your Honor to Appendix I. JUDGE KENNEDY: And, Dr. Hopenfeld, did you have a chance to look at the Unit 2 data, as well? These are the data reports that you were referring to when you -DR. HOPENFELD: If I may, I can tell you what I did when I got the data. I got the data and I saw that I'm getting data here for four or five outages. And I think they're listed on the table that I provided. And I didn't delve into the possibility there would be some two, or three, or four points that were provided from 1992. I thought that most of the data came from the latest outages. That's how it was labeled. I didn't go through each point in the back to see where it came from, so we asked, we asked Entergy please provide us the data, the comparison, the same comparison that you're doing here for these outages starting from 2003, or whatever it was. There were some at 2000, but that's
Page 1777 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
guess -DR. HOPENFELD: No, it doesn't, may have a few points, but it doesn't reflect that, not that I saw. I saw -- what I saw when I was looking at it, it was the latest data all the way to a year ago. where it started, before it changed ownership. Just provide us data, because I wanted to see what the progression was, all the data, not a few points, separate, just outage by outage. Just they gave us outage 15, 16, 17, I wanted outage one or whatever they started in `92, I wanted the same thing so I can see how the thing progresses. And they said that they've lost the data, they misplaced the data. And now they say well, we gave it to you. It's somewhere in there. Yes, it could be somewhere. I don't know where I could go. I mean, there's limited time that we can spend looking at every data point here. There are thousands of data points. It's not fair to ask us to do that, what was labeled an outage. The figure didn't say this point is from `92. If they felt it was important, they should have done so. JUDGE KENNEDY: But do you feel that this data reflects data that goes back as far as 1992? DR. HOPENFELD: No, it doesn't. JUDGE KENNEDY: At least in this case, I
Page 1778 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: Okay. DR. HOPENFELD: I was looking for outage, whatever it is, outage 10, 11, 12, whatever is done, `92, and see in each case to see a comparison. That's what I was looking for. JUDGE KENNEDY: All right, thank you. JUDGE McDADE: Okay. Anything further before we break for tonight? Mr. Turk, from the NRC Staff? MR. TURK: Not for tonight, Your Honor. JUDGE McDADE: From Clearwater? MS. RAIMUNDI: Nothing for -JUDGE McDADE: I was looking to see whether -- Ms. Greene was down behind the big screen there. MS. RAIMUNDI: Hello, can you hear me? JUDGE McDADE: Anything from Clearwater? MS. RAIMUNDI: No, no. And Ms. Greene is not here. She had a prior commitment that she had to honor. JUDGE McDADE: Okay, from Riverkeeper. MS. BRANCATO: No, Your Honor, thank you. JUDGE McDADE: New York? MR. SIPOS: No, Your Honor. JUDGE McDADE: Entergy?

MS. SUTTON: Nothing further. JUDGE McDADE: We will see you then tomorrow morning, 9:00. And, again, for planning purposes, we plan to go for at least an hour or up to an hour on TC-2, and then to get started on New York's contention. Thank you. (Whereupon, the proceedings went off the record at 5:15 p.m.)
CERTIFICATE
This is to certify that the attached proceedings before the United States Nuclear Regulatory Commission
Proceeding:
Entergy Nuclear Operations, Inc. Indian Point Units 2 and 3
Docket Number: 50-247-LR and 50-286-LR ASLBP Number: Location: 07-858-03-LR-BD01 Tarrytown, New York
were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission taken and thereafter reduced to typewriting under my direction and that said transcript is a true and accurate record of the proceedings.
----------------------Official Reporter Neal R. Gross & Co., Inc.
NEAL R. GROSS
COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

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Page 1457 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 Tuesday, October 16, 2012 9:00 a.m.

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There's a couple of preliminary

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came up from what Mr. Turk just said.

It's my understanding that there are

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fully intend to sample in Haverstraw Bay.

Your Honor, I'm sorry. Sherwin Turk

need to make one more statement. again.

sampling location be established at Haverstraw Bay,

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cited as a test for drinking water, I think we -- I

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We're okay, Your Honor. For the NRC staff?

Nothing further, Your Honor. Okay, yesterday, there

We discussed yesterday the motion, the

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Your Honor, John Sipos. Ms.

had some difficulty accessing the material.

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would -- for example, in New York-5, I believe it's

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And I guess what

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is Alan Cox for the Applicant.

cycle, every refueling outage. remaining service life.

And in doing that, that

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Again, you're not necessarily

Your Honor, Ian Mew for the

The service life of a component is done It's done in accordance

make sure I understand you correctly.

service life based on the wear rates from measured

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JUDGE WARDWELL: from other witnesses.

No one objects to that, that

me just make sure I understand it.

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MR. ALEKSICK: clarification, Your Honor? the Applicant.

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Nelson Azevedo for Entergy.

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EN-DC-315 implements NSAC-202L. JUDGE KENNEDY: So would NSAC-202 be the

That's, I believe, Section 4.5. JUDGE KENNEDY: JUDGE McDADE:

All right, thank you. Before you move forward,

that was presented.

of overall inspections that are based on CHECWORKS,

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But on average, it's around one

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Stress power uprate. Okay, Mr. Mew, the thing