Gundersen Testimony Vermont Yankee Extended Power Uprate 8-19-03

8/9/2019 Gundersen Testimony Vermont Yankee Extended Power Uprate 8-19-03

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STATE OF VERMONT

PUBLIC SERVICE BOARD

Petition of Entergy Nuclear Vermont Yankee, LLCand Entergy Nuclear Operations, Inc., pursuant to30 V.S.A. 248, for a Certificate of Public Goodto modify certain generation facilities

PREFILED SURREBUTTAL TESTIMONY OF ARNOLD GUNDERSEN

ON BEHALF OF NEW ENGLAND COALITION

Summary

Mr. Gundersen responds to Rebuttal Testimony of Entergy Nuclear VermontYankee, LLC and Entergy Nuclear Operation, Inc., (Entergy) witnesses on issues ofreliability, feasibility of the proposed power uprate, environmental and radiologicalimpacts and certain externalities such as carbon offset.

Mr. Gundersen also responds to the Direct Testimony of Entergy witnessesThayer, Yasi, and Dodson where Entergy responses to New England Coalitions First Setof Information Requests (April 23, 2003) were provided following both the Technical

Hearings (June 16, 17, and 19, 2003) and the filing of Entergy rebuttal testimony on July2, 2003.Mr. Gundersen is prevented from responding in full by Entergys continuing refusal, inapparent defiance of the Vermont Public Service Board (Board) Orders of June 13,2003 and July 10, 2003, to provide timely and complete answers to New EnglandCoalitions First Set of Information Requests.

August 19, 2003

Docket 6812


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VPSB DOCKET 6812

Prefiled Surrebuttal Testimony of Arnold GundersenAugust 19, 2003 - Page 2

Q1. Please state your name and address.1

Response: My name is Arnold Gundersen. My Address is 139 Killarney Drive,2

Burlington, Vermont.3

Q2. What is the purpose of your testimony?4

Response: The purpose of my testimony is to respond to Rebuttal Testimony of5

Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operation, Inc.,6

(Entergy) witnesses on issues of reliability, feasibility of the proposed power7

uprate, environmental and radiological impacts and certain externalities such as8

carbon offset.9

I will also respond to the Direct Testimony of Entergy witnesses Thayer, Yasi,10

and Dodson where Entergy responses to New England Coalitions First Set of11

Information Requests (April 23, 2003) were provided following both the Technical12

Hearings (June 16, 17, and 19, 2003) and the filing of Entergy rebuttal testimony on July13

2, 2003.14

I am prevented from responding in full by Entergys continuing refusal, in15

apparent defiance of the Vermont Public Service Board (Board) Orders of June 13,16

2003 and July 10, 2003, to provide timely and complete answers to New England17

Coalitions First Set of Information Requests.18

Q.3 Is there evidence of physical deterioration of Vermont Yankee components19

that will be likely to have an adverse effect on reliability under extended power20

uprate conditions?21


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VPSB DOCKET 6812Prefiled Surrebuttal Testimony of Arnold Gundersen

August 19, 2003 - Page 3

Response: There is evidence of physical deterioration of Vermont Yankee components1

that will be likely to have an adverse effect on reliability under extended power uprate2

conditions.3

Although my review component wearing and aging has been severely hampered4

by Entergys untimely and incomplete responses to New England Coalition information5

requests, numerous examples of deteriorated components, only marginally reliable6

without uprate, have been uncovered through examination of Entergy documents.7

Q.4 Can you cite an example of a worn or deteriorated component likely to have an8

adverse effect on reliability under extended power uprate conditions?9

Response: Yes, there are many. One example is feedwater pipe wear which is10

discussed in Entergys Accelerated Corrosion Inspection Program, 1999 refueling outage11

inspection report, issued in February 2000. In this report, Vermont Yankee expresses12

serious uncertainties with respect to their ability to predict the wear and thinning of13

essential reactor system piping, "The wear rate calculations and projected times to code14

minimum are assumed to be linear. In fact they may not be" (Page 5).15

Page 8 continues, Feedwater piping from the feed pumps past the feed regulator16

valves...this section of the feedwater system has the highest operating pressure...there17

may be a small margin for wall loss due to flow accelerated corrosion. In addition to the18

limited margin, areas at counter bores for specific welds were originally fabricated with19

thicknesses close to code minimum wall thickness. Increased FAC wear rates are20

expected in the feedwater system and portions of the Heater Drain system."21

On page 9 it is stated" the main area of concern is the feedwater system piping22

from the feed pumps past the feed regulator valves. Due to the design pressures and the23


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prior to the next refueling outage..."This recommendation was made in January of 2003,1

however no additional information regarding this program was provided in discovery2

seven months later.3

In an Entergy provided email from Enrico Betti to Craig Nelson 4/16/03, Betti4

states What this says to me is that the feedwater system has little or no reserve5

margin6

Despite all these indications that the system is marginal even at VYs current7

power level, VY has apparently chosen not to improve the system in any way.8

Specifically, in Jay Thayers Prefiled Rebuttal Testimony, dated July 2, 2003, page 2, Mr.9

Thayer states that ...plant modifications that are necessary to achieve the power upgrade10

have been firmly established for months. And in attachment EN-JKT-10 to the same11

testimony entitled Vermont Yankee Power Upgrade Project Description a list12

ofcomponents planned to be changed is provided. There are no listings for the feedwater13

system. Based on this description, VY has no intention of making any improvements to14

the feedwater system.15

Q 5 Please give another example of a component likely to have an adverse effect on16

reliability under extended power uprate conditions.17

Response: Another outstanding example of a worn component that is not likely to18

withstand the stresses of extended power uprate through end of license in 2012 is the19

steam condenser. According to page 1 of the Vermont Yankee Nuclear Plant Condenser20

Evaluation, dated November 1999, but signed by Carl Kuester on March 9, 2000, VY21

planned that the condenser would last 12 more years, but only if power increased by a 5%22

or less and modifications (beyond the presently planned, tube staking) were made. The23


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Kuester study concluded that if all his recommendations were implemented (including1

upgraded inspections of tubes each refueling outage, epoxy coating of tube inlets and2

outlets for $ 285,000, and tube staking). On page 26, Kuester concludes If programs are3

formulated and acted upon, this condenser should be in satisfactory service in 20124

baring any unusual accident or occurrence not yet seen.5

ENVY provided no documentation that I am aware of to show that Kuesters6

recommendations were acted upon.7

Had Kuesters recommended for epoxy coating of the tube inlet been8

implemented, this would reduce erosion. However, two years later in a 11/28/01 report9

to Marstaller from Zalewski, section 1.1 notes that Inlet end erosion is also10

present.While wall losses are not so severe to present an immediate hazard, the11

corrosion continues to grow. According to section 2.9 of this report, The random stress12

cracking may be limiting factor in the remaining useful life of the brass condenser tubes.13

It also states that The corrodent necessary to propagate these cracks has not been14

identified. Identifying and removing the corrodent is likely to be the only way to15

interrupt the progression of the stress cracking16

In a 2/7/02 memo from Betti to File UND2002-042 07, entitled Condenser17

Long Term Plan, Betti states VY has been fortunate to have our condenser tubes last 3018

years. He also states The current erosion inspection sample is too small. (This was19

Kuesters recommendation 3 years earlier).20

Both Betti and Kuester identify that it is important to note that any inspection21

program is only a statistical sampling which means that problems can still exits22

elsewhere. Also three years after Kuester recommended epoxy coating, Betti states,23


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One preemptive measure to prevent continued tube end and tube sheet erosion would be1

epoxy coating. He goes on to state The coating(is) better done soon before leaks2

occur.3

Betti then states, It is unlikely even with preemptive repairs the current tubes4

could be maintained long beyond 2012. Retubing as early as possible would reduce the5

risk of condenser leaks.6

Also, if Figures 3 and 4 in Bettis Condenser Long Term Plan are any indication,7

VY has not accounted for power uprate. The projections of wear rates are linear, even8

after the proposed extended power uprate happens.9

Even as of October 2002, ENVY was still contemplating Kuesters10

recommendation from 1999. Specifically, the Record of the Nineteenth Eddy Current11

Inspection, signed by Zalewski, recommends epoxy coating the tube sheets and inlet12

tubes and increasing the inspection sample.13

ENVY provided nothing during discovery that indicated that that any of these14

important recommendations, which they have known about for four years, have been15

acted upon.16

Despite all these indications that the system was marginal even at VYs current17

power level, VY only plans to improve the system by staking the tubes as a result of the18

power upgrade. Specifically Project Definition Document VMY 2003-012 dated April19

15, 2003 (Attachment to DPS-1-15-b) states The SWEC EPU Feasibility Study20

concludes that the main condenser tubes require staking to eliminate the susceptibility to21

vibration wear In fact the evidence is clear that ENVY has known for four year that it22


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has needed to stake the tubes in order to have the condenser last until 2012 under existing1

conditions.2

Staking was required in 1999 and is still required because the tubes are thinning3

from both the waterside and the steam side from erosion. As tubes get much thinner than4

their original condition, because they are no longerrigid, they begin to flutter in the5

stream of condenser flow; much like a blade of grass held between fingers as you blow6

across it. Metal fatigue, cracking, and failure result. Staking was required to eliminate7

only this one part of the condensers problems in 1999 and ENVY is just recognizing it8

four years later.9

Because the cooling towers are under sized for 120% power, the condenser10

backpressure will fluctuate, as it has not in the past. This will be especially true in11

summer months when no heat can be dumped to the Connecticut River and all Cooling12

Tower cells are operating. This fluctuating pressure will increase the high cycle fatigue13

on the condenser tube sheet, which is already damaged.14

Technical Evaluation No. TE 2001-047, approved by E Betti on 6/22/01, reveals15

that The original Westinghouse condenser bracing system had deficiencies that16

(following 23 years of operation) contributed to a 6 foot crack in the A17

condenser...Additional large cracks were found and repaired in the following refuel18

outage in the same location in the B condenser (1995).19

The report goes on to say, It should be noted that the original condenser welds20

were very poor and These welds from the standpoint of ultimate strength under primary21

load standpoint cansupport gravity and pressure loads from service22

conditionssecondary loads are important from the standpoint of fatigue failure.23


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Fortunately VY is a base load plant, and the pressurization cycles for the condenser will1

not likely exceed 200 cycles through the end of license. When this report was written,2

this may have been true, but the 120% upgrade introduces fatigue cycles, which the3

author had not anticipated.4

Despite all these indications that the system is marginal even at VYs current5

power level, VY has chosen not to improve the system in any way. Specifically, in Jay6

Thayers Prefiled Rebuttal Testimony, dated July 2, 2003, page 2, Mr. Thayer states that7

plant modifications that are necessary to achieve the power upgrade have been firmly8

established for months. And in attachment EN-JKT-10 to the same testimony entitled9

Vermont Yankee Power Upgrade Project Description, a list of components Entergy is10

planning to replace or modify is provided. There are no listings for the condenser tube11

sheet. Based on this description, VY has no intention of making any improvements to the12

condenser tube sheet.13

Q 5 Are there additional examples of a components likely to have an adverse effect14

on reliability under extended power uprate conditions that you would like to bring15

to the Boards attention?16

Response: There are many examples of components at Vermont Yankee that are17

showing signs of age and wear; all of which result in reduced safety margins and reduced18

reliability. Reactor components are embrittled, the reactor vessel pressure head has19

indications of surface cracking, and the reactor core shroud has cracked and is held20

together with improvised fixtures.21

The progress of these phenomena under normal conditions that is, original license22

power or even minor uprate conditions, can largely be anticipated from the experience of23


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other reactors. I would like to point out however that the program for extended power1

uprates is very new with only eight reactors uprated 17 percent or more and just three2

reactors having received 20 percent uprates; all during 2002. The record so far is not3

good. The Quad Cities- Unit 2 nuclear reactor, uprated by 17.8 percent in 2001, had a4

major steam dryer failure in June 2002.5

As early as 9/26/02, VY was aware that increasing the reactor flow would cause6

problems with the Steam Dryer. Rather than completely analyze the problem, in an7

unsigned, undated, untitled document provided by Entergy in discovery, reviewer Brian8

Hobbs was told add a statement justifying why expansion of the operating domain9

will not result in dryer component failures. (The only available reference to the identity10

of this document provided by Entergy is 128/t0305, but I do not know what that means.)11

I testified before the Board on June 19, and was unaware that the same dryer had12

failed a second time on June 11, 2003. In my oral testimony, I related problems that I13

had encountered on early BWRs wherein we had thought we had solved the problem,14

only to have it erupt again within a year. This is exactly what happened at Quad Cities,15

and what ENVY had denied could happen at Vermont Yankee. In fact, the second failure16

now appears to be much worse than originally reported.17

According to NRC Information Notice 2002-26, supplement 1, dated July 21,18

2003, Inspection of the dryer revealed (10 through wall cracks (about 90 inches long) in19

the vertical and horizontal portions of the blank hood, 90 degree side, (2) one vertical and20

two diagonal braces detached(3) one severed internal brace and (4) three cracked tie21

bars. The licensee believes that the most probable cause of the failure is low22


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frequency, high cycle fatigue driven by flow induced vibrations associated with higher1

steam flows present during EPU operating conditions.2

The Board is urged to remember that in 2002, Quad Cities told the NRC that the3

repairs would successful solve the first failure. In the Preliminary OE Report,4

OE16403, the NRC states that after the first failure, Several teams of Excelon Nuclear,5

General Electric and industry experts are assembled to determine the corrective6

actions.7

Despite this expert review, the dryer failed again and the failure was much worse,8

less than a year later. The key statement from the latest NRC information notice is9

exactly what I had been trying to tell the Board in my oral testimony. GE Nuclear10

Energy and the licensee did not foresee this phenomenon. As Shakespeare would say,11

There are more things in heaven and earth, Horatio, then are dreamt of in your12

philosophy. When you push an old plant beyond what it was designed to perform, there13

will always be situations where Entergy did not foresee this phenomenon.14

ENVY Expert Witness Burns (reliability expert) provides an exhibit highlighting15

the significance of the two events at Quad Cities. It is an Inside NRC trade publication16

article from June 30, 2003 that states, fatigue relating to the age of the plant may have17

contributed to the crack. By providing this exhibit, Mr. Burns apparently supports the18

point I made in my oral testimony, when I stated that plants built when Lawrence Welk19

was on TV were more likely to experience failures.20

Despite all indications that the steam dryer is marginal even at VYs current21

power level, Entergy has chosen not to improve the system in any major way.22

Specifically, in Jay Thayers Prefiled Rebuttal Testimony, dated July 2, 2003, attachment23


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EN-JKT-10 is entitled Vermont Yankee Power Upgrade Project Description. Based on1

this description, VY has no intention of making any improvements to the steam dryer2

system in response to the second Quad Cities event. In response to the first Quad Cities3

event, Entergy had committed only to provide a heavier top plate and round over the4

plates edges in hopes of avoiding eddy currents. Thus Entergys approach to design5

analysis remains reactive and may well lead to Entergy conducting post-analysis on its6

own version of steam dryer or other component failure.7

VY already has cracks in its steam dryer and surrounding area.8

The number 215 Dryer support bracket has had cracks since 1983 according to a9

Report of In-Vessel Examination, dated March-April 1995).10

In 1999 a report titled, Vermont Yankee RFO 21, identified three new cracks in11

three of the Steam Dryer Jacking Bolts (144,215, and 324). (Despite our discovery12

request, ENVY failed to provide section 2.4 of this report, which discusses the magnitude13

of these cracks.14

In the 2002 RFO 23 In-vessel Services Final Report, new debris was located on15

the 180 degree end of the Dryer Cover Plate. Despite our discovery request, ENVY16

failed to provide tab 9 of this report, which discusses the magnitude of this debris.17

Because ENVY failed to provide key pieces of information, I am forced to18

conclude that the trend is that failures in this area are continuing to grow.19

Q 6 Is there any single, common extended power uprate phenomenon that appears20

in the three examples that you cited above, feedwater piping, condensers, and steam21

dryer?22


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Response: Yes, the GE extended power uprate requires increased flow of steam and1

feedwater. The affected equipment was not designed to withstand increased flow induced2

corrosion (wear) nor was it designed to handle increased flow-induced vibration at3

uprate conditions. Many components including reactor control elements and fuel pins4

can be adversely affected.5

Among the historical issues at Vermont Yankee and throughout the industry is the6

failure of in-vessel spargers resulting from flow-induced vibration. A sparger is7

generally a heavy-walled pipe designed to distribute fluid uniformly within the vessel.8

Failure of feed water spargers has been observed at a number of boiling water reactors in9

addition to Vermont Yankee; among them: Millstone I, Monticello, Pilgrim, Dresden,10

and Quad Cities.11

A host of NRC reports and correspondence recount a history of ongoing sparger12

problems at Vermont Yankee.13

Sparger failure can lead to damage of other reactor components and core14

reactivity issues. At its most benign, sparger failure may require redesign and15

replacement. In the past this has resulted in significant personnel radiation exposure and16

outage time.17

Entergy appears to be undertaking the uprate project without a documented and18

serious analysis of the susceptibility to increased flow-induced vibration of feedwater19

spargers at Vermont Yankee. It is a mistake to assume that damage to feedwater spargers20

under uprate conditions is not an issue based on two years experience at plants uprated.21

20 percent. In my experience sparger damage was typically found after four to five years22

of operation.23


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18 pages? Are VYs files in such awful shape that they have lost this key and1

fundamental documentation? I conclude that pieces of this key design basis document2

are missing, which shows a clear weakness in the design basis for the plant.3

In a 131 page appendix to document VYC 378, dated December 14, 1987 and4

signed by Jay Thayer, on page 23 of 131, E. J. Betti states ..the reactor vessel was5

designed for the major transients that could occur during the plant 40 year life. NOTE,6

the text say PLANT lifetime, not reactor lifetime. Page 32 of 131 appears to be from the7

VY Final Safety Analysis Report (FSAR), and it states The reactor vessel is designed8

for a 40 year life Page 43 of 131 also states The reactor vessel is designed for a 409

year life Page 69 of 131 also states extrapolate to a 40 year life. This same page10

also states They values shown for VY are projected annual frequency averaged over a11

40 year plant lifetime. Please note again, the text says PLANT lifetime, not reactor12

lifetime. It is also important to note that this document makes clear that the consideration13

is not forlicensed life, but fordesign life. This would be the life limit for which the plant14

and all of its components were designed to last at its original intended power and flow. It15

is clear that VY had no knowledge of a fundamental criterion in the FSAR or their design16

basis. This gouache failure implies the need for a vertical slice assessment (typical of17

NRCs Diagnostic Evaluation Program) of the plant's systems and a cross cutting18

evaluation of Vermont Yankee managements relationship to their design basis.19

VY promised to inspect piping hanger RR-44 in their August 2001 ISI Summary20

Report to the NRC (BVY 01-66) Page 19 states that problems with hanger RR-44 will be21

revisited during the next refueling outageHowever, in the January 9 2003 ISI22

Summary Report to the NRC for the next refueling outage (BVY 03-02), there is no23


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reference that this hanger was ever re-inspected. This is an indication that the1

commitment follow-up system, which is used to maintain design basis does not work.2

3

It has become increasingly clear that Vermont Yankee has lost its design basis or4

perhaps never had an accurate design basis for its electrical wiring; in particular for the5

design requirement of cable separation.6

Two years ago the reactor was inadvertently scrammed when workers caused a7

short or an electrical signal when simply changing an indicator light bulb on the control8

room instrument panel.9

Earlier this year, NRC inspectors noted an A cable in the B cable tray. But10

because Entergy was eager to remedy the situation, NRC decided not to list a violation.11

On July 30, 2003, NRC issued an Integrated Inspection Report in which a Non-12

cited Violation was identified for failure to take effective corrective actionsto address13

cable separation issues in the cable vault.14

AS NRC explains, The cable vault contains both safety and non safety related15

control, instrumentation, and power cables routed in cable trays and conduit.16

The report continues Criteria are specified in Vermont Yankees licensing17

documents (design basis) that is used to provide physical separation and electrical18

isolation of circuits and components so that safety functions required during and19

following any design basis event can be accomplished.20

Also, Since May 2000, the licensee has documented several separate instances21

of cable separations in the cable vaultIn each of the above examples, the licensee took22

immediate actionsto ensure deficiencies were corrected. However, corrective actions23


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taken by the licensee to date have been insufficient to ensure the extent-of-condition of1

cable separation deficiencies was fully understood.2

As a result, inspectors continue to identify cable vault cable separation3

deficienciesdespite corrective actions having been taken by the licensee to address4

previously identified cable vault cable separation deficiencies.5

The above narrative on cable separation spells out a glaring and classic example6

of a design basis deficiency indicator. It is evident that Vermont Yankee does not know7

nor can it document the layout of the plants wiring. Therefore no predictions can be8

made regarding the performance of electrically powered or controlled accident mitigation9

and recovery systems under accidents conditions. Probabilistic risk assessment, such as10

that so favored by witness Burns, is effectively voided when plant design cannot be11

ascertained or verified.12

There are also indications that were plant design is documented, plant personnel13

may remain unfamiliar with design features. Mr. Thayers ignorance of the overall 4014

year design life of the Vermont plant is one such example.15

Another example is provided by an incident that took place on October 6, 2002,16

when Vermont Yankee declared an accident mitigation system, the Reactor Core17

Isolation Cooling System (RCIC), inoperable.18

The Event Notification (39250) stated, Following reactor core isolation cooling19

system check valve surveillance, the check valve apparently did not fully close. This20

resulted in high pump suction trip which would have prevented further system21

operation. (emphasis added)22


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On October 11, 2002, Entergy retracted the notification stating, The RCIC pump1

does not have this aforementioned trip device (emphasis added).2

Effective accident mitigation requires that operators, supervisors, and other3

responsible plant personnel be familiar in detail with the design of their plant. This was4

driven home in the 1979 TMI power plant accident when operators trying to recover safe5

reactor cooling parameters inadvertently worked to frustrate engineered safety features.6

According to the NRCs Advisory Committee on Reactor Safety, extended7

uprates will shorten response time required of reactor operators and make accident8

mitigation more difficult. Thus reliable design information, well understood, is essential9

for extended uprate conditions.10

Vermont Yankee has not shown that it can meet this test.11

Q 8 Are there other indicators of safety culture issues at Vermont Yankee that12

could have an adverse impact on safety and reliability under extended uprate13

conditions?14

Response: Yes. Having examined numerous documents related to uprate and to systems15

maintenance, I find a general lack of attention to detail and a lack of questioning attitude.16

There also seems to surface from time to time what I perceive as failure to take17

public safety seriously or as top priority. The following Entergy communication18

exemplifies this.19

In a telecom from Jim Metcalf to Pedro Perez, dated 11/23/02, Metcalf states,20

... making sure VY gets the 24-hour reduction credit... is imperative. I'm trying to21

figure out why the main condenser approach bothers me as much as it does. I think (in22

addition to the expense), it troubles me to think that in response to a core damage23


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accident (very comparable to the one at TMI-2), one would commit to opening up1

isolated systems and to intentionally spread radioactive contamination further into the2

plant.3

And this would be done to avoid a "paper" problem. It just doesn't seem right to4

me. The "right" answer (in my view) would be to effect pH control, spray the5

containment to control pressure and to remove everything that can be removed, allow6

some time for noble gas decay (at least 24 hours), and wait for the right meteorological7

conditions (wind blowing towards Canada, for example?) to vent the containment from8

the torus gas space up the stack (which is basically done for combustible gas control9

anyway).10

This Memo shows a gross lack of adequate regard for the licensing concepts11

underlying the safety analysis. Venting the containment is only allowed to reduce the12

pressure immediately after an accident when the chance of failing fuel has not yet13

occurred.14

To suggest that venting should occur 24 hours later when the winds are blowing15

toward Canada is to completely destroy the concepts that are used to develop the16

emergency plan after a core damage accident similar to TMI.17

To suggest that not venting the containment is only as a result of a paper18

problem is to show utter disregard for human life. The writer is concerned about not19

spreading radiation around the plant, which presumably is designed to hold it, but would20

rather wait only 24 hours to dump it on Canada. Furthermore, Metcalf places a premium21

on the cost of safety improvements, before considering public health and safety. I22


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conclude that the management of ENVY fosters a culture where getting the plant running1

again takes precedence over dumping hundreds of millions of curies on Canada.2

Q9 Entergy attorneys have suggested that New England Coalition and, by3

extension, the Vermont Public Service Board should rely on General Electric studies4

to confirm the feasibility and reliability of the proposed extended power uprate.5

Would you advise this course?6

Response: No, I would not. GE is a vendor whose primary interest appears to be selling7

a prepackaged extended uprate program. Although NRC does not appear to have the8

heart to buck the nuclear industry, even NRC questions the worth of GEs program. One9

example lies in notes of a private Entergy phone call to NRC (Telecon 1/8/03 9-10 AM).10

In this call the NRC told Entergy that the GE Constant Power Upgrade Licensing Topical11

Report (CLTR), upon which the extended power uprate is based, was ambiguous12

because GE had provided a piece-meal safety analysis and that there was insufficient13

analysis information on which to judge a decision on public safety. The NRC14

complained that with GE, Every time we talk, the ambiguity gets larger. The NRC15

also told Entergy that GE assumes the staff can reach conclusions on public safety16

without having adequate analysis on how the plant will operate in the future. The NRC17

also told Entergy that GE had not integrated fuel, accidents, and transient analysis,18

and that nothing was analyzed in the CLRT unless the fuel was provided by GE. The19

NRC also told Entergy that GE wants to carve everything into little pieces that are not20

analyzed in an integrated fashion. The NRC told Entergy that GE was trying to get21

licensed power upgrades ON THE CHEAP. (emphasis added)22

What GE cannot accomplish by dissembling, they appear ready to attempt by coercion.23


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In a "Private and Confidential" memo dated 12/18/02 Entergy's Don Leach told Entergy1

staffers that he had spoken to Jim Klaproth of GE. The memo says that Klaproth of GE2

was meeting with the NRC Chairman and commissioners on 1/22/03, and that if the NRC3

had not approved the GE report, Klaproth was "going for the jugular. I conclude that4

General Electric is using threats to get approval of the CLRT.5

Q 9 Entergy and Entergy witnesses have frequently stated that Vermont may have6

confidence in the proposed extended power uprate because the process has had7

success elsewhere. Do you agree?8

Response: No, I do not agree that GEs experience elsewhere can give Vermont9

confidence that the uprate will yield reliability or safety. I have already recounted GE10

uprate failures elsewhere. I have explained that based on industry experience some11

components will be expected to fail after four or five years while the 20 percent uprates12

have been in place only a year or two.13

During the era of Vermont Yankees construction, very few identical plants were14

built; each plant retaining unique features. Therefore it cannot be said that experience15

elsewhere can carry over wholesale to Vermont Yankee.16

There are significant differences between VY and other plants GE has licensed. In17

an internal memo from Robert Vita to VY staff on 12/19/02, Vita states, Again, it18

appears that VY is not a normal plant when trying to bound us generically with other19

BWR-4s. There is no suggestion why Vita stated AGAIN, but there must be many20

instances where VY does not fit the analysis that GE is trying to get the NRC to approve.21

In this memo, VY has discovered that its nuclear reactor has exceeded its ultimate22

design pressure under certain accidents at the 120% power level. Vita states that23


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compared to other BWR-4, VY has low steam capacity and a different safety relief valve1

arrangement.2

Vita then states, I am concerned that we are seeing VY challenge generic3

analysis previously performed by GE.I am not sure that the statements, engineering4

judgment or bounded by previous plant experience (sic), is acceptable for VY. 5

Q 10 Entergy witness Thayer now says that direct radiation as a result of uprate6

will not exceed 16 milliremat site boundary thus remaining well below the state7

limit of 20 millirem. Would you please comment?8

Response: It should be noted that the Board was notified of the shine dose, which was9

first provided to the board on April 25, 2003. This April 25 submittal was identified as a10

conservative preliminary estimate.., and it raised the total exposure from the plant to11

18.6 mrem, which is within 10% of the Vermont limit of 20 mrem.12

In the July 31, 2003 transmittal, witness George Thomas states that calculation13

CYC -2298 was the basis for the turbine shine dose. These calculations were14

completed on June 6, 2003.15

It is surprising that this accurate data was calculated two months after ENVY16

provided supposed preliminary shine dose values as part of these proceedings on17

April 25, and it is more surprising that the accurate analysis is exactly the same dose18

value as the preliminary one.19

I have reviewed CYC-2298 and conclude that the accurate dose numbers20

identified by Thomas on July 31 are indeed wrong and that Stone and Webster has made21

non-conservative assumptions in developing the transit time for the steam from the22

reactor to the steam turbine.23


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Specifically, the S&W calculations were based on an earlier calculation (Hansen1

to Strum 4/9/85). In the earlier calculations, a steam transit time of 3.6 seconds was2

determined, and there was considerable uncertainty even in that value. In 1985, Hansen3

stated As can be seen from the above, there are not enough hard cold facts to base a4

calculation on. Despite the fact that Hansen calculated 3.6 seconds, on page 16 of the5

recent S&W report, S&W arbitrarily INCREASES the pre-EPU transit time to 4 seconds.6

This 11% increase in transit time is not conservative for two reasons. First, the7

longer the transit time the more N 16 will decay before reaching relatively unshielded8

areas in the turbine hall which decreases the calculated exposure.9

Second, the 1985 value was not based on hard, cold facts. This mistake by10

S&W means that the predicted shine dose is approximately 16% lower than it should be,11

and in fact total exposure at the fence line exceeds state limits. (The 16% is not linear12

with the 11% because of the exponential decay of N-16).13

I conclude from this error that there is a gross breakdown in the ENVY quality14

assurance system and also that the dose to the public is not conservatively calculated. On15

numerous occasions, Entergy has claimed that the power upgrade would produce an16

exposure of 18.6 mrem at the fence line. This nonconservative error by Stone and17

Webster is the reason the fence line exposure appears to stay below the Vermont18

standard.19

I conclude that the Vermont standard of 20 mrem will be exceeded when the plant20

reaches 120% power. I also note that Witness Thayer, in his Prefiled Rebuttal Testimony21

incorrectly states, This is a conservative estimateThis exposure level is within the 2022


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millirem limit set by the State. Clearly witness Thayer has not reached the correct1

conclusion, as the dose is neither conservative nor with the state limit.2

What is more, though Entergy annually reported calculated fence line dose3

measurements in excess of 15 millirem for several years for which we have4

documentation, it is only with the excess radiation of extended power uprate in sight that5

the base fence line radiation dose is recalibrated to 12 millirem. In some instances, it6

appears that the dose was back calculated from a desired outcome.7

In any case, the measurements and calculated results appear disturbingly elastic.8

Q 11 During the Technical Hearings, Entergy announced that it had modified its9

cooling tower plans so as to retain 125 horsepower for fan motor rating but to10

replace the motors and fans with more efficient models. Entergy rebuttal witnesses11

have reiterated this position. In your opinion, how will plant operation be affected12

under extended power uprate conditions?13

Response: The modest proposal of only upgrading the efficiency of the motors and fans14

to the cooling towers is sub- minimal compared to the impact of 300 megawatts of15

anticipated increase in heat output from the proposed modification.16

Since there are already days when the plant output is limited by river temperature17

and cooling tower performance at existing power level, the obvious conclusions are:18

1. that there will be many more days when plume visibility will be dramatically19

increased,20

2. many more days when the plume will be denser and larger and more visible than on21

the "worst" day under current conditions,22


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3. that there will be many more days when cooling tower drift will be dramatically1

increased, and2

4. that there will be many more days when the makeup for drift and evaporative losses3

will increase.4

I note that ENVY has failed to provide the board with estimates of increased drift,5

estimates of the number of additional days when the plume will be visible, and accurate6

estimates of the additional size of the plume. In an effort to assist the Board in one of7

these areas, I have determined the drift ramifications as a result of the modification.8

From the Stone & Webster Evaporation Loss Study, Exhibit DEY-3, drift of 1839

gallons per minute is stated twice on pages 4 & 7, at 120% power. Assuming that Stone10

& Webster numbers are accurate and using elementary Algebra, this converts to 263,52011

gallons per day. The calculation is provided below.12

1) 183 gallons per minute x 60 = 10,980 gallons/hr.13

2) 10,980 gallons per hour x 24 = 263,520 gallons/day.14

3) 263,520 gallons per day/55 gallon drum = 4,791 drums/day.15

This means that the surrounding community will be converted into swamp-like16

conditions, as almost Five Thousand 55 gallon drums of water will be dropped on them17

each day.18

In addition to all this drift water, it is important to identify that the drift carries19

with it all the biocides and other chemicals used to prevent the towers from being clogged20

it mold and algae.21

There is a conflict between ENVY documents on this mater. In witness Lesser 's22

testimony on 2/18/03, he states t there would be no change in chemical treatment23


26/34



chemicals, however this is in direct contradiction to Lynn DeWald's letter to the1

Department of Environmental Conservation of February 15, 2003 requesting to change in2

Biocides from Bulab 6002 to NALCO-550.3

In any event, based on a drift rate of 183 gallons per minute, hundreds of pounds4

of Bulab or Nalco will be released from the plant, each day that these corrosive toxins are5

employed, to fall on the surrounding trees, plants, and people. ENVY fails to identify the6

adverse consequences of the chemicals in the drift on the surrounding human and natural7

environment.8

In addition to these environmental impacts, there will be many more days when9

the plant's output and reliability will be reduced. (See discussion on reliability for impact10

of increased backpressure on the plant's reliability.)11

Based on these adverse environmental impacts to the surrounding communities,12

the appropriate thing to do when making a 300 megawatt change in the heat output, given13

the fact that the cooling towers already limit performance, would be to build additional14

dry cooling towers to augment the existing 22 wet units already in place. Dry units15

would produce no additional plume visibility concerns, would limit draw down from the16

river for makeup, and would eliminate the issue of additional drift, which wet towers17

produce. A positive impact of dry towers is that under certain circumstances, the dry hot18

air would mix with the dry moist air from the existing towers to REDUCE the visibility19

of the plume. An additional improvement as a result of dry towers is that condenser20

backpressure concerns due to inlet water box temperature would be reduced.21

I make two conclusions as to why ENVY has not chosen to increase the heat removal22

capacity by adding dry towers. First, given the profit goals espoused in their 200323


27/34



Business Plan Strategic Goals, ENVY simply would prefer to enrich their stockholders1

rather than protect the environment by adding dry towers. Second, given that new2

nuclear construction in Vermont requires legislative approval and altering the plant3

footprint may require additional permitting, it appears that ENVY does not wish to face4

legislative or permitting delays by constructing the appropriate remediation technology.5

Q 12 Entergy witnesses have reiterated their position that an uprate Vermont6

Yankee will be a reliable plant. Do you agree that no reliability will be lost as a7

effect of uprate and that Vermonters will suffer no economic loss as a result?8

Response: No, based on all the evidence before us, I conclude that Vermont Yankee9

will be a less reliable plant under extended power uprate conditions.10

In the Prefiled Rebuttal Testimony of Edward Burns, Entergys nuclear reliability11

expert states that as a result of the Power Upgrade, he would anticipate that the loss of12

availability of the VY unit as a result of the Power Upgrade will be 2%.13

Availability is defined in the NRC's gray book (NUREG-0020) as number of14

hours the reactor was critical divided by the number of hours in the period. If the15

availability is reduced by 2%, it means the reactor is not critical for a longer period of16

time, and hence not producing as much power. If the reactor is available 90% of the17

time, it is critical 328.5 days out of a 365 day period. If the reactor is available 2% less18

(88%), it is critical 321.2 days out of a 365 day period.19

In any event, 2% of 365 days is 7.3 additional days when VY will not be20

operating as a result of the power upgrade.21

Assuming for a moment that this 2% is correct, Witness William Sherman has22

calculated that a day of lost generation costs the ratepayers of Vermont $88,000 based on23


28/34



$50 per megawatt on the spot market. As I write this, the August spot market price is1

$160. Multiplying 7.3 lost days times $88,000 yields a loss to the Vermont ratepayers of2

$642,000. If the plant breaks down for 7 days in August when the spot market is high,3

ratepayers will lose $2,168,320.4

A summer breakdown is more likely, as that is the time of the year that cooling5

tower restraints place backpressure on the condenser, which as shown elsewhere is6

already prone to failure.7

When the unit is running, Entergy collects significant revenues and pays the State8

approximately $400,000. But because the unit will be less reliable, the ratepayers will in9

fact be loosing at least $220,000 each year (and quite possibly $1,768,000) while VY10

continues to make significant revenues when it operates.11

Entergy rebuttal witness Connie Wells appears to agree with this lack of shared12

risk, with benefits accruing to ENVY. According to page 4 of the Prefiled Rebuttal13

Testimony of Connie Wells, VYs obligation is to provide power to VPNPC only14

when the VY station is producing power, and if for any reason the Station is not15

producing power, Entergy Nuclear VY has no obligation to obtain replacement power or16

otherwise indemnify VYNPC.17

However, in an apparent attempt to distort this fact, Entergy spokesman, Brian18

Cosgrove, states in a memo on Public Relations Strategy, dated April 28, 2003, Vermont19

ratepayers will have no economic risk (August 1, 2003, Entergy Response to New20

England Coalitions First Set of Information Requests). Clearly, VY does not what the21

public to know how big a tab they are being asked to pick up.22


29/34



This same misinformation was provided to the board as testimony. Specifically,1

in Department of Public Service Second Set of Informational Requests, Witness J. Lesser2

disagrees with Mr. Burns analysis of reduced reliability by saying Since Entergy VY3

does not anticipate any lost energy generation as a result of the upgrade, there will be no4

expected difference to the overall costs to Vermont rate payers.5

The above analysis assumes that the 2% decrease in reliability calculated by6

Burns is correct. I believe this value, drawn from the operating history of all plants with7

extended power uprates is understated for several reasons:8

First, Entergy witness Burns provides an exhibit highlighting the significance of9

the two events at Quad Cities. It is an Inside NRC trade journal article from June 30,10

2003 that states, fatigue relating to the age of the plant may have contributed to the11

crack. By providing this exhibit, Mr. Burns apparently supports the point I made in my12

oral testimony, when I stated that aging plants, plants built when Lawrence Welk was on13

TV, were more likely to experience failures.14

Second, Mr. Burns analysis fails to include the seriously degraded condition of15

the feedwater system at VY compared to the other plants in the sample.16

Third, Mr. Burns analysis fails to include the seriously degraded condition of the17

condenser tubes at VY compared to the other plants in the sample.18

Fourth, Mr. Burns analysis fails to include the seriously degraded condition of19

the condenser tube sheet at VY compared to the other plants in the sample.20

Fifth, Mr. Burns analysis relies on the assumption that Vermont Yankees design21

basis is intact, which it is not.22


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Sixth, Mr. Burns analysis pays little heed to human performance factors at1

Vermont Yankee that, as I have already testified, exhibit negative indicators.2

Early in his presentation, Mr. Burns introduces the Bath tub curve as a scientific3

fact, which I agree that it is. I find it incredible though, that at the end of his analysis he4

dismisses the bathtub curve and, with no scientific basis, claims that VYs reliability,5

now exempt from his calculations on upgraded plant fleet performance, will be the same6

in 2010 as it was in 2000. There is absolutely no scientific reason to dismiss the fact that7

VYs age will become more of a factor as it approaches the end of its design life at8

normal power, and even a greater factor if it is allowed to run at 120% power. Even if a9

major malfunction or accident is averted, the bathtub curve implies that VYs availability10

will decrease to the 60 to 70% range as it approaches the end of its 40-year life. To deny11

the bath tub curve is to not understand the aging phenomena at work at VY.12

Q 13 Will increased direct radiation and increased releases of radioactive13

contaminants resulting from an extended power uprate have a quantifiable increase14

in risk, societal cost, and direct cost to Vermont residents?15

Response: Yes, and concurrence is found in a February 7, 1997 letter from Carol16

Browner, Administrator, EPA to Shirley Jackson, Chairman, Nuclear Regulatory17

Commission, an August 22, 1997 EPA Memorandum, OSWER No. 9200.4-18, and an18

EPA August 20, 1997 attachment thereto, Analysis of What Radiation Dose Limit is19

Protective of Human Health at CERCLA Sires (Including Review of Dose Limits in NRC20

Decommissioning Rule).21

This analysis states, The NRC rule sets an allowable cleanup level of 2522

millirem per year effective dose equivalent (EDE) (equivalent to approximately 5X10 423


31/34



lifetime cancer risk) These limits are beyond the upper bound of risk range generally1

considered protective under CERCLA. Protectiveness for carcinogens under CERCLA is2

generally determined with reference to a cancer risk range of 10 4 and 10 to 6 deemed3

acceptable by EPA.. Guidance that provides for cleanup levels exceeding 15 millirem per4

year (which equates to approximately 3 X 10 4 increased lifetime risk) is similarly not5

protective under CERCLA and should not be used to establish cleanup levels.6

Entergy rebuttal witness Auxier disputes the validity of the Linear No Threshold7

(LNT) dose model. However, in assessing radiation risk, most regulatory bodies adhere8

to the LNT. The latest publicly available report of the International Commission on9

Radiation Protection, the 2001 Annual Report, recounts the activities of its working10

group on Cancer Risk at Low Doses on Page 9, The dose threshold issue is also being11

pursued via a review of fundamental cellular/molecular data particularly in relation to12

DNA damage repair- as yet the TG (task Group) have not identified convincing scientific13

evidence of such a threshold mechanism.14

Witness Auxier suggests that there are no known ill health effects from radiation15

at levels below background at an average 360 millirem. Most industry and government16

literature now attributes 180 to 200 millirem of that background to radon exposure.17

According to the EPA, approximately 23,000 Americans die of radon-induced lung18

cancer each year. Thus radon a component of background radiation is a cause of induced19

lung cancers exceeded only by smoking.20

Q 14 In responding to New England Coalitions call for an Independent Safety21

Assessment (ISA), Department of Public Service Witness, William Sherman22

characterized an ISA at Maine Yankee as having resulted from a string of problems23


32/34



and issues quite different from the situation at Vermont Yankee. Do you agree with1

this characterization?2

Response: No, I do not. Maine Yankee received a regimen of routine and special3

inspections quite similar to those experienced at Vermont Yankee. Like Vermont4

Yankee, Maine Yankee received the very highest performance and safety ratings. Were it5

not for the chance of whistleblower allegations that Yankee Atomic Electric Company6

had knowingly performed inadequate analyses to support an uprate, the ISA would likely7

never have happened. The 1997 NRC ISA report has it that this single issue raised a8

question of whether similar problems existed in other areas. In order to address this9

question, as well as to respond to concerns by the Governor of Maine about the safety10

and effectiveness of regulatory oversight of Maine Yankee, the NRC Chairman initiated11

an independent safety assessment of Maine Yankee.12

In my opinion the numerous defects in material, design basis, corporate culture,13

and procedures detailed in my testimony far outweigh the reasons for the Maine Yankee14

ISA. In fact, they more resemble the conclusions of the Maine Yankee ISA than the15

reasons for the ISA.16

Moreover, the New England Coalition is calling for an ISA at Vermont Yankee17

because it is deemed the best tool for rooting out the problems that would lead to18

decreased reliability and decreased safety under uprate conditions. NRC standard review19

of EPU applications does not to our knowledge include a thorough review of design20

basis, for example. But, at least for selected safety related systems, the ISA does.21

Finally, it should be said that the ISA found Maine Yankee safe to operate though not at22

uprated power.23


33/34



Q 15 Is there anything else of which you think the Board should take note?1

Response: Yes, apropos to the question of potential adverse effects on the electric grid2

and on reliability resulting from the uprate, I think that the Board should take notice of3

the recent European nuclear power cooling constraints due to the unprecedented heat4

wave as well as the recent interstate blackout. A July 23, 2003 letter from the North5

American Electric Reliability Council warns that loss of reactive capability under nuclear6

plant uprate conditions could adversely affect grid reliability. Specifically, the letter7

warns, Another point in your report that deserves mention is the identified loss of 4,3408

Mvar of generator reactive capability that accompanied the 1,200 MW increase in electric9

output. In some cases, this loss of reactive capability could have significant effect on the10

ability of the grid operator to maintain adequate voltages on the grid. An increase in real11

power output at NPPs is certainly desirable, but not if it comes at the expense of12

increased risk of inadequate grid voltages.13

Also I would like to share with the Board my conclusion that much of the14

deferred maintenance of critical plant components, which is evidenced above, seems to15

stem from Entergys single-mindedness about its bottom line. Vermonters certainly16

appear to be handed an uneven share of the risks when compared to Entergy17

shareholders.18

Entergy policy is clearly spelled out in the Entergy Nuclear Vermont Yankee19

Business Plan 2003 (April 2003, rev 1, Lower costs translate into higher profits. With20

clear corporate and market expectations of ENVYs contributions to earnings, a21

concentrated focus on lowering costs is required. Nuclear plants must have a low-cost22


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position to remain competitive in an increasingly unregulated northeast market for1

electricity.2

Q 16 Does that conclude you testimony?3

Response Yes, it does.4

Gundersen Testimony Vermont Yankee Extended Power Uprate 8-19-03

Documents

Transcript of Gundersen Testimony Vermont Yankee Extended Power Uprate 8-19-03