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

STATE OF VERMONT
PUBLIC SERVICE BOARD
Petition of Entergy Nuclear Vermont Yankee, LLC August 19, 2003

and Entergy Nuclear Operations, Inc., pursuant to Docket 6812
30 V.S.A. §248, for a Certificate of Public Good
to 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 Vermont

Yankee, LLC and Entergy Nuclear Operation, Inc., (“Entergy”) witnesses on issues of
reliability, feasibility of the proposed power uprate, environmental and radiological
impacts and certain externalities such as carbon offset.
Mr. Gundersen also responds to the Direct Testimony of Entergy witnesses
Thayer, Yasi, and Dodson where Entergy responses to New England Coalition’s First Set
of 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 July
2, 2003.
Mr. Gundersen is prevented from responding in full by Entergy’s continuing refusal, in
apparent 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 England
Coalition’s First Set of Information Requests.
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Prefiled Surrebuttal Testimony of Arnold Gundersen
August 19, 2003 - Page 2
1 Q1. Please state your name and address.
2 Response: My name is Arnold Gundersen. My Address is 139 Killarney Drive,
3 Burlington, Vermont.
4 Q2. What is the purpose of your testimony?
5 Response: The purpose of my testimony is to respond to Rebuttal Testimony of
6 Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operation, Inc.,
7 (“Entergy”) witnesses on issues of reliability, feasibility of the proposed power
8 uprate, environmental and radiological impacts and certain externalities such as
9 carbon offset.
10 I will also respond to the Direct Testimony of Entergy witnesses Thayer, Yasi,
11 and Dodson where Entergy responses to New England Coalition’s First Set of
12 Information Requests (April 23, 2003) were provided following both the Technical
13 Hearings (June 16, 17, and 19, 2003) and the filing of Entergy rebuttal testimony on July
14 2, 2003.
15 I am prevented from responding in full by Entergy’s continuing refusal, in
16 apparent defiance of the Vermont Public Service Board (“Board”) Orders of June 13,
17 2003 and July 10, 2003, to provide timely and complete answers to New England
18 Coalition’s First Set of Information Requests.
19 Q.3 Is there evidence of physical deterioration of Vermont Yankee components
20 that will be likely to have an adverse effect on reliability under extended power
21 uprate conditions?
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1 Response: There is evidence of physical deterioration of Vermont Yankee components
2 that will be likely to have an adverse effect on reliability under extended power uprate
3 conditions.
4 Although my review component wearing and aging has been severely hampered
5 by Entergy’s untimely and incomplete responses to New England Coalition information
6 requests, numerous examples of deteriorated components, only marginally reliable
7 without uprate, have been uncovered through examination of Entergy documents.
8 Q.4 Can you cite an example of a worn or deteriorated component likely to have an
9 adverse effect on reliability under extended power uprate conditions?
10 Response: Yes, there are many. One example is feedwater pipe wear which is
11 discussed in Entergy’s Accelerated Corrosion Inspection Program, 1999 refueling outage
12 inspection report, issued in February 2000. In this report, Vermont Yankee expresses
13 serious uncertainties with respect to their ability to predict the wear and thinning of
14 essential reactor system piping, "The wear rate calculations and projected times to code
15 minimum are assumed to be linear. In fact they may not be… " (Page 5).
16 Page 8 continues, “Feedwater piping from the feed pumps past the feed regulator
17 valves...this section of the feedwater system has the highest … operating pressure...there
18 may be a small margin for wall loss due to flow accelerated corrosion. In addition to the
19 limited margin, areas at counter bores for specific welds were originally fabricated with
20 thicknesses close to code minimum wall thickness. Increased FAC wear rates are
21 expected in the feedwater system and portions of the Heater Drain system."
22 On page 9 it is stated" the main area of concern is the feedwater system piping
23 from the feed pumps past the feed regulator valves. Due to the design pressures and the
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1 installed wall thickness, this portion of the feedwater system has a relatively low margin
2 for wall loss due to flow accelerated corrosion." NOTE: This is at present power not
3 upgrade power.
4 It is important to note that this sampling program is only a statistical sampling
5 which means that problems can still exits elsewhere.
6 On page 9 it is stated, "Also, provision for procuring piping and fittings for
7 replacement of selected components on short notice should be established". NOTE: This
8 indicates that the authors acknowledge how likely the is that a failure in this piping could
9 occur. Page 10 expands on this argument by stating "The potential for finding significant
10 wear in any piping component exists. Contingency planning as required for either repair
11 or replacement of large bore components in the feedwater system should be considered."
12 On page 10 it is also acknowledges that only a "...relatively small number of components
13 inspected each outage."
14 On page 9 in the 2002 Refueling Outage Report on Flow Accelerated Corrosion,
15 it is stated that "… with future operation under GE hydrogen water chemistry, wear rates
16 in the feedwater system and heater drain system are expected to increase. The feedwater
17 system piping from the feed pumps past the regulator valves has a relatively low margin
18 for wall loss due to flow accelerated corrosion."
19
20 On page 10, it is acknowledged that things will get worse with the proposed
21 upgrade. "The planned power upgrade project underway at VY will require a complete
22 review of program evaluations, piping modeling, and procedures to account for changes
23 in equipment and flow regimes in plant piping systems. The review should be performed
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1 prior to the next refueling outage..."This recommendation was made in January of 2003,
2 however no additional information regarding this program was provided in discovery
3 seven months later.
4 In an Entergy provided email from Enrico Betti to Craig Nelson 4/16/03, Betti
5 states “What this says to me is that the feedwater system has little or no reserve
6 margin… ”
7 Despite all these indications that the system is marginal even at VY’s current
8 power level, VY has apparently chosen not to improve the system in any way.
9 Specifically, in Jay Thayer’s Prefiled Rebuttal Testimony, dated July 2, 2003, page 2, Mr.
10 Thayer states that “...plant modifications that are necessary to achieve the power upgrade
11 have been firmly established for months.” And in attachment EN-JKT-10 to the same
12 testimony entitled Vermont Yankee Power Upgrade Project Description a list
13 ofcomponents planned to be changed is provided. There are no listings for the feedwater
14 system. Based on this description, VY has no intention of making any improvements to
15 the feedwater system.
16 Q5 Please give another example of a component likely to have an adverse effect on
17 reliability under extended power uprate conditions.
18 Response: Another outstanding example of a worn component that is not likely to
19 withstand the stresses of extended power uprate through end of license in 2012 is the
20 steam condenser. According to page 1 of the Vermont Yankee Nuclear Plant Condenser
21 Evaluation, dated November 1999, but signed by Carl Kuester on March 9, 2000, VY
22 planned that the condenser would last 12 more years, but only if power increased by a 5%
23 or less and modifications (beyond the presently planned, tube staking) were made. The
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1 Kuester study concluded that if all his recommendations were implemented (including
2 upgraded inspections of tubes each refueling outage, epoxy coating of tube inlets and
3 outlets for $ 285,000, and tube staking). On page 26, Kuester concludes “If programs are
4 formulated and acted upon, this condenser should be in satisfactory service in 2012
5 baring any unusual accident or occurrence not yet seen.”
6 ENVY provided no documentation that I am aware of to show that Kuester’s
7 recommendations were acted upon.
8 Had Kuester’s recommended for epoxy coating of the tube inlet been
9 implemented, this would reduce erosion. However, two years later in a 11/28/01 report
10 to Marstaller from Zalewski, section 1.1 notes that “Inlet end erosion is also
11 present… .While wall losses are not so severe to present an immediate hazard, the
12 corrosion continues to grow.” According to section 2.9 of this report, “The random stress
13 cracking may be limiting factor in the remaining useful life of the brass condenser tubes.”
14 It also states that “The corrodent necessary to propagate these cracks has not been
15 identified. Identifying and removing the corrodent is likely to be the only way to
16 interrupt the progression of the stress cracking… ”
17 In a 2/7/02 memo from Betti to “File UND2002-042 07”, entitled Condenser
18 Long Term Plan, Betti states “VY has been fortunate to have our condenser tubes last 30
19 years.” He also states “The current erosion inspection sample is too small.” (This was
20 Kuester’s recommendation 3 years earlier).
21 Both Betti and Kuester identify that it is important to note that any inspection
22 program is only a statistical sampling which means that problems can still exits
23 elsewhere. Also three years after Kuester recommended epoxy coating, Betti states,
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1 “One preemptive measure to prevent continued tube end and tube sheet erosion would be
2 epoxy coating… .” He goes on to state “The coating… (is) better done soon before leaks
3 occur.”
4 Betti then states, “It is unlikely even with preemptive repairs the current tubes
5 could be maintained long beyond 2012. Retubing as early as possible would reduce the
6 risk of condenser leaks.”
7 Also, if Figures 3 and 4 in Betti’s Condenser Long Term Plan are any indication,
8 VY has not accounted for power uprate. The projections of wear rates are linear, even
9 after the proposed extended power uprate happens.
10 Even as of October 2002, ENVY was still contemplating Kuester’s
11 recommendation from 1999. Specifically, the Record of the Nineteenth Eddy Current
12 Inspection, signed by Zalewski, recommends epoxy coating the tube sheets and inlet
13 tubes and increasing the inspection sample.
14 ENVY provided nothing during discovery that indicated that that any of these
15 important recommendations, which they have known about for four years, have been
16 acted upon.
17 Despite all these indications that the system was marginal even at VY’s current
18 power level, VY only plans to improve the system by staking the tubes as a result of the
19 power upgrade. Specifically Project Definition Document VMY 2003-012 dated April
20 15, 2003 (Attachment to DPS-1-15-b) states’ “The SWEC EPU Feasibility Study
21 concludes that the main condenser tubes require staking to eliminate the susceptibility to
22 vibration wear… ” In fact the evidence is clear that ENVY has known for four year that it
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1 has needed to stake the tubes in order to have the condenser last until 2012 under existing
2 conditions.
3 Staking was required in 1999 and is still required because the tubes are thinning
4 from both the waterside and the steam side from erosion. As tubes get much thinner than
5 their original condition, because they are no longer rigid, they begin to flutter in the
6 stream of condenser flow; much like a blade of grass held between fingers as you blow
7 across it. Metal fatigue, cracking, and failure result. Staking was required to eliminate
8 only this one part of the condenser’s problems in 1999 and ENVY is just recognizing it
9 four years later.
10 Because the cooling towers are under sized for 120% power, the condenser
11 backpressure will fluctuate, as it has not in the past. This will be especially true in
12 summer months when no heat can be dumped to the Connecticut River and all Cooling
13 Tower cells are operating. This fluctuating pressure will increase the high cycle fatigue
14 on the condenser tube sheet, which is already damaged.
15 Technical Evaluation No. TE 2001-047, approved by E Betti on 6/22/01, reveals
16 that ”The original Westinghouse condenser bracing system had deficiencies that
17 (following 23 years of operation) contributed to a 6 foot crack in the A
18 condenser...Additional large cracks were found and repaired in the following refuel
19 outage in the same location in the B condenser (1995).”
20 The report goes on to say, “It should be noted that the original condenser welds
21 were very poor” and “These welds from the standpoint of ultimate strength under primary
22 load standpoint can… support gravity and pressure loads from service
23 conditions… secondary loads are important from the standpoint of fatigue failure.
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1 Fortunately VY is a base load plant, and the pressurization cycles for the condenser will
2 not likely exceed 200 cycles through the end of license.” When this report was written,
3 this may have been true, but the 120% upgrade introduces fatigue cycles, which the
4 author had not anticipated.
5 Despite all these indications that the system is marginal even at VY’s current
6 power level, VY has chosen not to improve the system in any way. Specifically, in Jay
7 Thayer’s Prefiled Rebuttal Testimony, dated July 2, 2003, page 2, Mr. Thayer states that
8 “… plant modifications that are necessary to achieve the power upgrade have been firmly
9 established for months.” And in attachment EN-JKT-10 to the same testimony entitled
10 Vermont Yankee Power Upgrade Project Description, a list of components Entergy is
11 planning to replace or modify is provided. There are no listings for the condenser tube
12 sheet. Based on this description, VY has no intention of making any improvements to the
13 condenser tube sheet.
14 Q5 Are there additional examples of a components likely to have an adverse effect
15 on reliability under extended power uprate conditions that you would like to bring
16 to the Board’s attention?
17 Response: There are many examples of components at Vermont Yankee that are
18 showing signs of age and wear; all of which result in reduced safety margins and reduced
19 reliability. Reactor components are embrittled, the reactor vessel pressure head has
20 indications of surface cracking, and the reactor core shroud has cracked and is held
21 together with improvised fixtures.
22 The progress of these phenomena under normal conditions that is, original license
23 power or even minor uprate conditions, can largely be anticipated from the experience of
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1 other reactors. I would like to point out however that the program for extended power
2 uprates is very new with only eight reactors uprated 17 percent or more and just three
3 reactors having received 20 percent uprates; all during 2002. The record so far is not
4 good. The Quad Cities- Unit 2 nuclear reactor, uprated by 17.8 percent in 2001, had a
5 major steam dryer failure in June 2002.
6 As early as 9/26/02, VY was aware that increasing the reactor flow would cause
7 problems with the Steam Dryer. Rather than completely analyze the problem, in an
8 unsigned, undated, untitled document provided by Entergy in discovery, reviewer Brian
9 Hobbs was told “ … add a statement justifying why expansion of the operating domain
10 will not result in dryer component failures.” (The only available reference to the identity
11 of this document provided by Entergy is 128/t0305, but I do not know what that means.)
12 I testified before the Board on June 19, and was unaware that the same dryer had
13 failed a second time on June 11, 2003. In my oral testimony, I related problems that I
14 had encountered on early BWR’s wherein we had thought we had solved the problem,
15 only to have it erupt again within a year. This is exactly what happened at Quad Cities,
16 and what ENVY had denied could happen at Vermont Yankee. In fact, the second failure
17 now appears to be much worse than originally reported.
18 According to NRC Information Notice 2002-26, supplement 1, dated July 21,
19 2003, “Inspection of the dryer revealed (10 through wall cracks (about 90 inches long) in
20 the vertical and horizontal portions of the blank hood, 90 degree side, (2) one vertical and
21 two diagonal braces detached… (3) one severed internal brace… and (4) three cracked tie
22 bars. … The licensee believes that the most probable cause of the failure is low
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1 frequency, high cycle fatigue driven by flow induced vibrations associated with higher
2 steam flows present during EPU operating conditions.”
3 The Board is urged to remember that in 2002, Quad Cities told the NRC that the
4 repairs would successful solve the first failure. In the “Preliminary OE Report”,
5 OE16403, the NRC states that after the first failure, “Several teams of Excelon Nuclear,
6 General Electric and industry experts are assembled to … determine the … corrective
7 actions.”
8 Despite this expert review, the dryer failed again and the failure was much worse,
9 less than a year later. The key statement from the latest NRC information notice is
10 exactly what I had been trying to tell the Board in my oral testimony. “GE Nuclear
11 Energy and the licensee did not foresee this phenomenon.” As Shakespeare would say,
12 “There are more things in heaven and earth, Horatio, then are dreamt of in your
13 philosophy.” When you push an old plant beyond what it was designed to perform, there
14 will always be situations where Entergy “… did not foresee this phenomenon.”
15 ENVY Expert Witness Burns (reliability expert) provides an exhibit highlighting
16 the significance of the two events at Quad Cities. It is an Inside NRC trade publication
17 article from June 30, 2003 that states, “… fatigue relating to the age of the plant may have
18 contributed to the crack.” By providing this exhibit, Mr. Burns apparently supports the
19 point I made in my oral testimony, when I stated that plants built when Lawrence Welk
20 was on TV were more likely to experience failures.
21 Despite all indications that the steam dryer is marginal even at VY’s current
22 power level, Entergy has chosen not to improve the system in any major way.
23 Specifically, in Jay Thayer’s Prefiled Rebuttal Testimony, dated July 2, 2003, attachment
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1 EN-JKT-10 is entitled Vermont Yankee Power Upgrade Project Description. Based on
2 this description, VY has no intention of making any improvements to the steam dryer
3 system in response to the second Quad Cities event. In response to the first Quad Cities
4 event, Entergy had committed only to provide a heavier top plate and round over the
5 plate’s edges in hopes of avoiding eddy currents. Thus Entergy’s approach to design
6 analysis remains reactive and may well lead to Entergy conducting post-analysis on its
7 own version of steam dryer or other component failure.
8 VY already has cracks in its steam dryer and surrounding area.
9 The number 215 Dryer support bracket has had cracks since 1983 according to a
10 Report of In-Vessel Examination, dated March-April 1995).
11 In 1999 a report titled, Vermont Yankee RFO 21, identified three new cracks in
12 three of the Steam Dryer Jacking Bolts (144,215, and 324). (Despite our discovery
13 request, ENVY failed to provide section 2.4 of this report, which discusses the magnitude
14 of these cracks.
15 In the 2002 RFO 23 In-vessel Services Final Report, new debris was located on
16 the 180 degree end of the Dryer Cover Plate. Despite our discovery request, ENVY
17 failed to provide tab 9 of this report, which discusses the magnitude of this debris.
18 Because ENVY failed to provide key pieces of information, I am forced to
19 conclude that the trend is that failures in this area are continuing to grow.
20 Q 6 Is there any single, common extended power uprate phenomenon that appears
21 in the three examples that you cited above, feedwater piping, condensers, and steam
22 dryer?
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1 Response: Yes, the GE extended power uprate requires increased flow of steam and
2 feedwater. The affected equipment was not designed to withstand increased flow induced
3 corrosion (wear) nor was it designed to handle increased flow-induced vibration at
4 uprate conditions. Many components including reactor control elements and fuel pins
5 can be adversely affected.
6 Among the historical issues at Vermont Yankee and throughout the industry is the
7 failure of in-vessel spargers resulting from flow-induced vibration. A sparger is
8 generally a heavy-walled pipe designed to distribute fluid uniformly within the vessel.
9 Failure of feed water spargers has been observed at a number of boiling water reactors in
10 addition to Vermont Yankee; among them: Millstone I, Monticello, Pilgrim, Dresden,
11 and Quad Cities.
12 A host of NRC reports and correspondence recount a history of ongoing sparger
13 problems at Vermont Yankee.
14 Sparger failure can lead to damage of other reactor components and core
15 reactivity issues. At its most benign, sparger failure may require redesign and
16 replacement. In the past this has resulted in significant personnel radiation exposure and
17 outage time.
18 Entergy appears to be undertaking the uprate project without a documented and
19 serious analysis of the susceptibility to increased flow-induced vibration of feedwater
20 spargers at Vermont Yankee. It is a mistake to assume that damage to feedwater spargers
21 under uprate conditions is not an issue based on two years experience at plants uprated.
22 20 percent. In my experience sparger damage was typically found after four to five years
23 of operation.
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1 Q7 How can Entergy and the U.S. Nuclear Regulatory Commission or any other
2 reviewer be certain that components, systems, and procedures are properly
3 analyzed for performance and durability under extended uprate conditions?
4 Response: One irreducible requirement is that Entergy and NRC must be certain that
5 they have a clear and accurate basis on which to support their various analyses, designs,
6 calculations, and projections. The design basis documents for a nuclear power plant
7 must, by law, contain such fundamental information. Design basis documents for a
8 nuclear power plant are analogous to DNA in biota. They are the message that sets out
9 and justifies materials, design, and construction; that forms, that permits modification,
10 times maintenance, anticipates, sets limits and expectations.
11 Although Vermont Yankee expended considerable time and money to round up design
12 basis issues during the mid 1990’s, there remain obvious weaknesses in Vermont
13 Yankee’s design basis documents and the company’s willingness to maintain, to be
14 familiar with, and to heed accurate and comprehensive design basis documents.
15 VY apparently did not know their plant had a 40-year life, as they asked why I
16 stated it had a 40-year life in their information requests on my direct testimony. They
17 initially refused to provide us documents that could prove our assertion, then provided the
18 document with 146 key pages ‘accidentally missing”.
19 It was only after a detailed page count that we were able to identify the pages
20 which would support the 40 year design life statement. The document, VYC-378
21 supposedly contains 155 pages...even after we requested a full copy we only got 131
22 pages plus a 6 pages cover memo. Page 1 of 6 of VYC- 378 states, "This document
23 contains 155 pages" but only 131 (plus 6), or 137 pages followed. Where are the missing
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1 18 pages? Are VY’s files in such awful shape that they have lost this key and
2 fundamental documentation? I conclude that pieces of this key design basis document
3 are missing, which shows a clear weakness in the design basis for the plant.
4 In a 131 page appendix to document VYC 378, dated December 14, 1987 and
5 signed by Jay Thayer, on page 23 of 131, E. J. Betti states “..the reactor vessel was
6 designed for the major transients that could occur during the plant 40 year life.” NOTE,
7 the text say PLANT lifetime, not reactor lifetime. Page 32 of 131 appears to be from the
8 VY Final Safety Analysis Report (“FSAR”), and it states “”The reactor vessel is designed
9 for a 40 year life… ” Page 43 of 131 also states “”The reactor vessel is designed for a 40
10 year life… ” Page 69 of 131 also states “”… extrapolate to a 40 year life.” This same page
11 also states “They values shown for VY are projected annual frequency averaged over a
12 40 year plant lifetime.” Please note again, the text says PLANT lifetime, not reactor
13 lifetime. It is also important to note that this document makes clear that the consideration
14 is not for licensed life, but for design life. This would be the life limit for which the plant
15 and all of its components were designed to last at its original intended power and flow. It
16 is clear that VY had no knowledge of a fundamental criterion in the FSAR or their design
17 basis. This gouache failure implies the need for a vertical slice assessment (typical of
18 NRC’s Diagnostic Evaluation Program) of the plant's systems and a cross cutting
19 evaluation of Vermont Yankee management’s relationship to their design basis.
20 VY promised to inspect piping hanger RR-44 in their August 2001 ISI Summary
21 Report to the NRC (BVY 01-66) Page 19 states that problems with hanger RR-44 will be
22 “revisited” during the next refueling outage… However, in the January 9 2003 ISI
23 Summary Report to the NRC for the next refueling outage (BVY 03-02), there is no
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1 reference that this hanger was ever re-inspected. This is an indication that the
2 commitment follow-up system, which is used to maintain design basis does not work.
4 It has become increasingly clear that Vermont Yankee has lost its design basis or
5 perhaps never had an accurate design basis for its electrical wiring; in particular for the
6 design requirement of cable separation.
7 Two years ago the reactor was inadvertently scrammed when workers caused a
8 short or an electrical signal when simply changing an indicator light bulb on the control
9 room instrument panel.
10 Earlier this year, NRC inspectors noted an “A” cable in the “B” cable tray. But
11 because Entergy was eager to remedy the situation, NRC decided not to list a violation.
12 On July 30, 2003, NRC issued an Integrated Inspection Report in which a Non-
13 cited Violation was identified for “failure to take effective corrective actions… to address
14 cable separation issues in the cable vault.”
15 AS NRC explains, “The cable vault contains both safety and non safety related
16 control, instrumentation, and power cables routed in cable trays and conduit.
17 The report continues “ Criteria are specified in Vermont Yankees licensing
18 documents (design basis) that is used to provide physical separation and electrical
19 isolation of circuits and components so that safety functions required during and
20 following any design basis event can be accomplished.”
21 Also, “ Since May 2000, the licensee has documented several separate instances
22 of cable separations in the cable vault… In each of the above examples, the licensee took
23 immediate actions… to ensure deficiencies were corrected. However, corrective actions

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1 taken by the licensee to date have been insufficient to ensure the extent-of-condition of
2 cable separation deficiencies was fully understood.
3 As a result, inspectors continue to identify cable vault cable separation
4 deficiencies… despite corrective actions having been taken by the licensee to address
5 previously identified cable vault cable separation deficiencies.
6 The above narrative on cable separation spells out a glaring and classic example
7 of a design basis deficiency indicator. It is evident that Vermont Yankee does not know
8 nor can it document the layout of the plant’s wiring. Therefore no predictions can be
9 made regarding the performance of electrically powered or controlled accident mitigation
10 and recovery systems under accidents conditions. Probabilistic risk assessment, such as
11 that so favored by witness Burns, is effectively voided when plant design cannot be
12 ascertained or verified.
13 There are also indications that were plant design is documented, plant personnel
14 may remain unfamiliar with design features. Mr. Thayer’s ignorance of the overall 40
15 year design life of the Vermont plant is one such example.
16 Another example is provided by an incident that took place on October 6, 2002,
17 when Vermont Yankee declared an accident mitigation system, the Reactor Core
18 Isolation Cooling System (RCIC), inoperable.
19 The Event Notification (39250) stated, “ Following reactor core isolation cooling
20 system check valve surveillance, the check valve apparently did not fully close. This
21 resulted in high pump suction trip which would have prevented further system
22 operation.” (emphasis added)

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1 On October 11, 2002, Entergy retracted the notification stating, The RCIC pump
2 does not have this aforementioned trip device” (emphasis added).
3 Effective accident mitigation requires that operators, supervisors, and other
4 responsible plant personnel be familiar in detail with the design of their plant. This was
5 driven home in the 1979 TMI power plant accident when operators trying to recover safe
6 reactor cooling parameters inadvertently worked to frustrate engineered safety features.
7 According to the NRC’s Advisory Committee on Reactor Safety, extended
8 uprates will shorten response time required of reactor operators and make accident
9 mitigation more difficult. Thus reliable design information, well understood, is essential
10 for extended uprate conditions.
11 Vermont Yankee has not shown that it can meet this test.
12 Q 8 Are there other indicators of safety culture issues at Vermont Yankee that
13 could have an adverse impact on safety and reliability under extended uprate
14 conditions?
15 Response: Yes. Having examined numerous documents related to uprate and to systems
16 maintenance, I find a general lack of attention to detail and a lack of questioning attitude.
17 There also seems to surface from time to time what I perceive as failure to take
18 public safety seriously or as top priority. The following Entergy communication
19 exemplifies this.
20 In a telecom from Jim Metcalf to Pedro Perez, dated 11/23/02, Metcalf states,
21 “... making sure VY gets the 24-hour reduction credit... is imperative. I'm trying to
22 figure out why the main condenser approach bothers me as much as it does. I think (in
23 addition to the expense), it troubles me to think that in response to a core damage

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1 accident (very comparable to the one at TMI-2), one would commit to opening up
2 isolated systems and to intentionally spread radioactive contamination further into the
3 plant.
4 And this would be done to avoid a "paper" problem. It just doesn't seem right to
5 me. The "right" answer (in my view) would be to effect pH control, spray the
6 containment to control pressure and to remove everything that can be removed, allow
7 some time for noble gas decay (at least 24 hours), and wait for the right meteorological
8 conditions (wind blowing towards Canada, for example?) to vent the containment from
9 the torus gas space up the stack (which is basically done for combustible gas control
10 anyway).”
11 This Memo shows a gross lack of adequate regard for the licensing concepts
12 underlying the safety analysis… . Venting the containment is only allowed to reduce the
13 pressure immediately after an accident when the chance of failing fuel has not yet
14 occurred.
15 To suggest that venting should occur 24 hours later when the winds are blowing
16 toward Canada is to completely destroy the concepts that are used to develop the
17 emergency plan after a core damage accident similar to TMI.
18 To suggest that not venting the containment is only as a result of a “paper
19 problem” is to show utter disregard for human life. The writer is concerned about not
20 spreading radiation around the plant, which presumably is designed to hold it, but would
21 rather wait only 24 hours to dump it on Canada. Furthermore, Metcalf places a premium
22 on the cost of safety improvements, before considering public health and safety. I
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1 conclude that the management of ENVY fosters a culture where getting the plant running
2 again takes precedence over dumping hundreds of millions of curies on Canada.
3 Q 9 Entergy attorneys have suggested that New England Coalition and, by
4 extension, the Vermont Public Service Board should rely on General Electric studies
5 to confirm the feasibility and reliability of the proposed extended power uprate.
6 Would you advise this course?
7 Response: No, I would not. GE is a vendor whose primary interest appears to be selling
8 a prepackaged extended uprate program. Although NRC does not appear to have the
9 heart to buck the nuclear industry, even NRC questions the worth of GE’s program. One
10 example lies in notes of a private Entergy phone call to NRC (Telecon 1/8/03 9-10 AM).
11 In this call the NRC told Entergy that the GE Constant Power Upgrade Licensing Topical
12 Report (CLTR), upon which the extended power uprate is based, was “ambiguous”
13 because GE had provided “a piece-meal safety analysis” and that there was “insufficient
14 analysis information on which to judge a decision on public safety”. The NRC
15 complained that with GE, “Every time we talk, the ambiguity gets larger”. The NRC
16 also told Entergy that GE “… assumes the staff can reach conclusions on public safety
17 without having adequate analysis on how the plant will operate in the future.” The NRC
18 also told Entergy that GE had not “… integrated fuel, accidents, and transient analysis… ”,
19 and that nothing was analyzed in the CLRT unless the fuel was provided by GE. The
20 NRC also told Entergy that “GE wants to carve everything into little pieces that are not
21 analyzed in an integrated fashion.” The NRC told Entergy that GE was trying to get
22 licensed power upgrades “ ON THE CHEAP”. (emphasis added)
23 What GE cannot accomplish by dissembling, they appear ready to attempt by coercion.

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1 In a "Private and Confidential" memo dated 12/18/02 Entergy's Don Leach told Entergy
2 staffers that he had spoken to Jim Klaproth of GE. The memo says that Klaproth of GE
3 was meeting with the NRC Chairman and commissioners on 1/22/03, and that if the NRC
4 had not approved the GE report, Klaproth was "… going for the jugular.” I conclude that
5 General Electric is using threats to get approval of the CLRT.
6 Q 9 Entergy and Entergy witnesses have frequently stated that Vermont may have
7 confidence in the proposed extended power uprate because the process has had
8 success elsewhere. Do you agree?
9 Response: No, I do not agree that GE’s experience elsewhere can give Vermont
10 confidence that the uprate will yield reliability or safety. I have already recounted GE
11 uprate failures elsewhere. I have explained that based on industry experience some
12 components will be expected to fail after four or five years while the 20 percent uprates
13 have been in place only a year or two.
14 During the era of Vermont Yankee’s construction, very few identical plants were
15 built; each plant retaining unique features. Therefore it cannot be said that experience
16 elsewhere can carry over wholesale to Vermont Yankee.
17 There are significant differences between VY and other plants GE has licensed. In
18 an internal memo from Robert Vita to VY staff on 12/19/02, Vita states, “Again, it
19 appears that VY is not a “normal” plant when trying to bound us generically with other
20 BWR-4s.” There is no suggestion why Vita stated “AGAIN”, but there must be many
21 instances where VY does not fit the analysis that GE is trying to get the NRC to approve.
22 In this memo, VY has discovered that its nuclear reactor has exceeded its ultimate
23 design pressure under certain accidents at the 120% power level. Vita states that
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1 compared to other BWR-4, VY has low steam capacity and a different safety relief valve
2 arrangement.
3 Vita then states, ”I am concerned that we are seeing VY challenge generic
4 analysis previously performed by GE.I am not sure that the statements, engineering
5 judgment or bounded by previous plant experience (sic), is acceptable for VY. “
6 Q 10 Entergy witness Thayer now says that direct radiation as a result of uprate
7 will not exceed 16 millirem at site boundary thus remaining well below the state
8 limit of 20 millirem. Would you please comment?
9 Response: It should be noted that the Board was notified of the “shine” dose, which was
10 first provided to the board on April 25, 2003. This April 25 submittal was identified as a
11 “… conservative preliminary estimate..”, and it raised the total exposure from the plant to
12 18.6 mrem, which is within 10% of the Vermont limit of 20 mrem.
13 In the July 31, 2003 transmittal, witness George Thomas states that calculation
14 CYC -2298 was the basis for the turbine “shine” dose. These calculations were
15 completed on June 6, 2003.
16 It is surprising that this “accurate” data was calculated two months after ENVY
17 provided supposed “preliminary” “shine” dose values as part of these proceedings on
18 April 25, and it is more surprising that the “accurate” analysis is exactly the same dose
19 value as the “preliminary” one.
20 I have reviewed CYC-2298 and conclude that the “accurate” dose numbers
21 identified by Thomas on July 31 are indeed wrong and that Stone and Webster has made
22 non-conservative assumptions in developing the transit time for the steam from the
23 reactor to the steam turbine.

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1 Specifically, the S&W calculations were based on an earlier calculation (Hansen
2 to Strum 4/9/85). In the earlier calculations, a steam transit time of 3.6 seconds was
3 determined, and there was considerable uncertainty even in that value. In 1985, Hansen
4 stated “As can be seen from the above, there are not enough hard cold facts to base a
5 calculation on.” Despite the fact that Hansen calculated 3.6 seconds, on page 16 of the
6 recent S&W report, S&W arbitrarily INCREASES the pre-EPU transit time to 4 seconds.
7 This 11% increase in transit time is not conservative for two reasons. First, the
8 longer the transit time the more N 16 will decay before reaching relatively unshielded
9 areas in the turbine hall which decreases the calculated exposure.
10 Second, the 1985 value was not based on “… hard, cold facts.” This mistake by
11 S&W means that the predicted shine dose is approximately 16% lower than it should be,
12 and in fact total exposure at the fence line exceeds state limits. (The 16% is not linear
13 with the 11% because of the exponential decay of N-16).
14 I conclude from this error that there is a gross breakdown in the ENVY quality
15 assurance system and also that the dose to the public is not conservatively calculated. On
16 numerous occasions, Entergy has claimed that the power upgrade would produce an
17 exposure of 18.6 mrem at the fence line. This nonconservative error by Stone and
18 Webster is the reason the fence line exposure appears to stay below the Vermont
19 standard.
20 I conclude that the Vermont standard of 20 mrem will be exceeded when the plant
21 reaches 120% power. I also note that Witness Thayer, in his Prefiled Rebuttal Testimony
22 incorrectly states, ”This is a conservative estimate… This exposure level is within the 20
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1 millirem limit set by the State.” Clearly witness Thayer has not reached the correct
2 conclusion, as the dose is neither “conservative” nor “with the state limit”.
3 What is more, though Entergy annually reported calculated fence line dose
4 measurements in excess of 15 millirem for several years for which we have
5 documentation, it is only with the excess radiation of extended power uprate in sight that
6 the base fence line radiation dose is recalibrated to 12 millirem. In some instances, it
7 appears that the dose was back calculated from a desired outcome.
8 In any case, the measurements and calculated results appear disturbingly elastic.
9 Q 11 During the Technical Hearings, Entergy announced that it had modified its
10 cooling tower plans so as to retain 125 horsepower for fan motor rating but to
11 replace the motors and fans with more efficient models. Entergy rebuttal witnesses
12 have reiterated this position. In your opinion, how will plant operation be affected
13 under extended power uprate conditions?
14 Response: The modest proposal of only upgrading the efficiency of the motors and fans
15 to the cooling towers is sub- minimal compared to the impact of 300 megawatts of
16 anticipated increase in heat output from the proposed modification.
17 Since there are already days when the plant output is limited by river temperature
18 and cooling tower performance at existing power level, the obvious conclusions are:
19 1. that there will be many more days when plume visibility will be dramatically
20 increased,
21 2. many more days when the plume will be denser and larger and more visible than on
22 the "worst" day under current conditions,

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1 3. that there will be many more days when cooling tower drift will be dramatically
2 increased, and
3 4. that there will be many more days when the makeup for drift and evaporative losses
4 will increase.
5 I note that ENVY has failed to provide the board with estimates of increased drift,
6 estimates of the number of additional days when the plume will be visible, and accurate
7 estimates of the additional size of the plume. In an effort to assist the Board in one of
8 these areas, I have determined the drift ramifications as a result of the modification.
9 From the Stone & Webster Evaporation Loss Study, Exhibit DEY-3, drift of 183
10 gallons per minute is stated twice on pages 4 & 7, at 120% power. Assuming that Stone
11 & Webster numbers are accurate and using elementary Algebra, this converts to 263,520
12 gallons per day. The calculation is provided below.
13 1) 183 gallons per minute x 60 = 10,980 gallons/hr.
14 2) 10,980 gallons per hour x 24 = 263,520 gallons/day.
15 3) 263,520 gallons per day/55 gallon drum = 4,791 drums/day.
16 This means that the surrounding community will be converted into swamp-like
17 conditions, as almost Five Thousand 55 gallon drums of water will be dropped on them
18 each day.
19 In addition to all this drift water, it is important to identify that the drift carries
20 with it all the biocides and other chemicals used to prevent the towers from being clogged
21 it mold and algae.
22 There is a conflict between ENVY documents on this mater. In witness Lesser 's
23 testimony on 2/18/03, he states t there would be no change in chemical treatment

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1 chemicals, however this is in direct contradiction to Lynn DeWald's letter to the
2 Department of Environmental Conservation of February 15, 2003 requesting to change in
3 Biocides from Bulab 6002 to NALCO-550.
4 In any event, based on a drift rate of 183 gallons per minute, hundreds of pounds
5 of Bulab or Nalco will be released from the plant, each day that these corrosive toxins are
6 employed, to fall on the surrounding trees, plants, and people. ENVY fails to identify the
7 adverse consequences of the chemicals in the drift on the surrounding human and natural
8 environment.
9 In addition to these environmental impacts, there will be many more days when
10 the plant's output and reliability will be reduced. (See discussion on reliability for impact
11 of increased backpressure on the plant's reliability.)
12 Based on these adverse environmental impacts to the surrounding communities,
13 the appropriate thing to do when making a 300 megawatt change in the heat output, given
14 the fact that the cooling towers already limit performance, would be to build additional
15 dry cooling towers to augment the existing 22 wet units already in place. Dry units
16 would produce no additional plume visibility concerns, would limit draw down from the
17 river for makeup, and would eliminate the issue of additional drift, which wet towers
18 produce. A positive impact of dry towers is that under certain circumstances, the dry hot
19 air would mix with the dry moist air from the existing towers to REDUCE the visibility
20 of the plume. An additional improvement as a result of dry towers is that condenser
21 backpressure concerns due to inlet water box temperature would be reduced.
22 I make two conclusions as to why ENVY has not chosen to increase the heat removal
23 capacity by adding dry towers. First, given the profit goals espoused in their 2003
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1 Business Plan Strategic Goals, ENVY simply would prefer to enrich their stockholders
2 rather than protect the environment by adding dry towers. Second, given that new
3 nuclear construction in Vermont requires legislative approval and altering the plant
4 footprint may require additional permitting, it appears that ENVY does not wish to face
5 legislative or permitting delays by constructing the appropriate remediation technology.
6 Q 12 Entergy witnesses have reiterated their position that an uprate Vermont
7 Yankee will be a reliable plant. Do you agree that no reliability will be lost as a
8 effect of uprate and that Vermonters will suffer no economic loss as a result?
9 Response: No, based on all the evidence before us, I conclude that Vermont Yankee
10 will be a less reliable plant under extended power uprate conditions.
11 In the Prefiled Rebuttal Testimony of Edward Burns, Entergy’s nuclear reliability
12 expert states that as a result of the Power Upgrade, he would anticipate that the loss of
13 availability of the VY unit as a result of the Power Upgrade will be 2%.
14 Availability is defined in the NRC's “gray book” (NUREG-0020) as number of
15 hours the reactor was critical divided by the number of hours in the period. If the
16 availability is reduced by 2%, it means the reactor is not critical for a longer period of
17 time, and hence not producing as much power. If the reactor is available 90% of the
18 time, it is critical 328.5 days out of a 365 day period. If the reactor is available 2% less
19 (88%), it is critical 321.2 days out of a 365 day period.
20 In any event, 2% of 365 days is 7.3 additional days when VY will not be
21 operating as a result of the power upgrade.
22 Assuming for a moment that this 2% is correct, Witness William Sherman has
23 calculated that a day of lost generation costs the ratepayers of Vermont $88,000 based on
VPSB DOCKET 6812
1 $50 per megawatt on the spot market. As I write this, the August spot market price is
2 $160. Multiplying 7.3 lost days times $88,000 yields a loss to the Vermont ratepayers of
3 $642,000. If the plant breaks down for 7 days in August when the spot market is high,
4 ratepayers will lose $2,168,320.
5 A summer breakdown is more likely, as that is the time of the year that cooling
6 tower restraints place backpressure on the condenser, which as shown elsewhere is
7 already prone to failure.
8 When the unit is running, Entergy collects significant revenues and pays the State
9 approximately $400,000. But because the unit will be less reliable, the ratepayers will in
10 fact be loosing at least $220,000 each year (and quite possibly $1,768,000) while VY
11 continues to make significant revenues when it operates.
12 Entergy rebuttal witness Connie Wells appears to agree with this lack of shared
13 risk, with benefits accruing to ENVY. According to page 4 of the Prefiled Rebuttal
14 Testimony of Connie Wells, “… VY’s obligation is to provide power to VPNPC only
15 when the VY station is producing power, and if for any reason the Station is not
16 producing power, Entergy Nuclear VY has no obligation to obtain replacement power or
17 otherwise indemnify VYNPC.”
18 However, in an apparent attempt to distort this fact, Entergy spokesman, Brian
19 Cosgrove, states in a memo on Public Relations Strategy, dated April 28, 2003, “Vermont
20 ratepayers will have no economic risk” (August 1, 2003, Entergy Response to New
21 England Coalition’s First Set of Information Requests). Clearly, VY does not what the
22 public to know how big a tab they are being asked to pick up.
VPSB DOCKET 6812
1 This same misinformation was provided to the board as testimony. Specifically,
2 in Department of Public Service Second Set of Informational Requests, Witness J. Lesser
3 disagrees with Mr. Burns’analysis of reduced reliability by saying “ Since Entergy VY
4 does not anticipate any lost energy generation as a result of the upgrade, there will be no
5 expected difference to the overall costs to Vermont rate payers.”
6 The above analysis assumes that the 2% decrease in reliability calculated by
7 Burns is correct. I believe this value, drawn from the operating history of all plants with
8 extended power uprates is understated for several reasons:
9 First, Entergy witness Burns provides an exhibit highlighting the significance of
10 the two events at Quad Cities. It is an Inside NRC trade journal article from June 30,
11 2003 that states, “… fatigue relating to the age of the plant may have contributed to the
12 crack.” By providing this exhibit, Mr. Burns apparently supports the point I made in my
13 oral testimony, when I stated that aging plants, plants built when Lawrence Welk was on
14 TV, were more likely to experience failures.
15 Second, Mr. Burns’analysis fails to include the seriously degraded condition of
16 the feedwater system at VY compared to the other plants in the sample.
17 Third, Mr. Burns’analysis fails to include the seriously degraded condition of the
18 condenser tubes at VY compared to the other plants in the sample.
19 Fourth, Mr. Burns’analysis fails to include the seriously degraded condition of
20 the condenser tube sheet at VY compared to the other plants in the sample.
21 Fifth, Mr. Burns’analysis relies on the assumption that Vermont Yankee’s design
22 basis is intact, which it is not.

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1 Sixth, Mr. Burns analysis pays little heed to human performance factors at
2 Vermont Yankee that, as I have already testified, exhibit negative indicators.
3 Early in his presentation, Mr. Burns introduces the “Bath tub curve” as a scientific
4 fact, which I agree that it is. I find it incredible though, that at the end of his analysis he
5 dismisses the bathtub curve and, with no scientific basis, claims that VY’s reliability,
6 now exempt from his calculations on upgraded plant fleet performance, will be the same
7 in 2010 as it was in 2000. There is absolutely no scientific reason to dismiss the fact that
8 VY’s age will become more of a factor as it approaches the end of its design life at
9 normal power, and even a greater factor if it is allowed to run at 120% power. Even if a
10 major malfunction or accident is averted, the bathtub curve implies that VY’s availability
11 will decrease to the 60 to 70% range as it approaches the end of its 40-year life. To deny
12 the bath tub curve is to not understand the aging phenomena at work at VY.
13 Q 13 Will increased direct radiation and increased releases of radioactive
14 contaminants resulting from an extended power uprate have a quantifiable increase
15 in risk, societal cost, and direct cost to Vermont residents?
16 Response: Yes, and concurrence is found in a February 7, 1997 letter from Carol
17 Browner, Administrator, EPA to Shirley Jackson, Chairman, Nuclear Regulatory
18 Commission, an August 22, 1997 EPA Memorandum, OSWER No. 9200.4-18, and an
19 EPA August 20, 1997 attachment thereto, “ Analysis of What Radiation Dose Limit is
20 Protective of Human Health at CERCLA Sires (Including Review of Dose Limits in NRC
21 Decommissioning Rule).
22 This analysis states, “… The NRC rule sets an allowable cleanup level of 25
23 millirem per year effective dose equivalent (EDE) (equivalent to approximately 5X10 –4
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1 lifetime cancer risk) … These limits are beyond the upper bound of risk range generally
2 considered protective under CERCLA. Protectiveness for carcinogens under CERCLA is
3 generally determined with reference to a cancer risk range of 10 –4 and 10 to –6 deemed
4 acceptable by EPA.. Guidance that provides for cleanup levels exceeding 15 millirem per
5 year (which equates to approximately 3 X 10 –4 increased lifetime risk) is similarly not
6 protective under CERCLA and should not be used to establish cleanup levels.”
7 Entergy rebuttal witness Auxier disputes the validity of the Linear No Threshold
8 (LNT) dose model. However, in assessing radiation risk, most regulatory bodies adhere
9 to the LNT. The latest publicly available report of the International Commission on
10 Radiation Protection, the 2001 Annual Report, recounts the activities of its working
11 group on Cancer Risk at Low Doses on Page 9, “ The dose threshold issue is also being
12 pursued via a review of fundamental cellular/molecular data particularly in relation to
13 DNA damage repair- as yet the TG (task Group) have not identified convincing scientific
14 evidence of such a threshold mechanism.”
15 Witness Auxier suggests that there are no known ill health effects from radiation
16 at levels below background at an average 360 millirem. Most industry and government
17 literature now attributes 180 to 200 millirem of that background to radon exposure.
18 According to the EPA, approximately 23,000 Americans die of radon-induced lung
19 cancer each year. Thus radon a component of background radiation is a cause of induced
20 lung cancers exceeded only by smoking.
21 Q 14 In responding to New England Coalition’s call for an Independent Safety
22 Assessment (ISA), Department of Public Service Witness, William Sherman
23 characterized an ISA at Maine Yankee as having resulted from a string of problems

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1 and issues quite different from the situation at Vermont Yankee. Do you agree with
2 this characterization?
3 Response: No, I do not. Maine Yankee received a regimen of routine and special
4 inspections quite similar to those experienced at Vermont Yankee. Like Vermont
5 Yankee, Maine Yankee received the very highest performance and safety ratings. Were it
6 not for the chance of whistleblower allegations that Yankee Atomic Electric Company
7 had knowingly performed inadequate analyses to support an uprate, the ISA would likely
8 never have happened. The 1997 NRC ISA report has it that this single “ issue raised a
9 question of whether similar problems existed in other areas. In order to address this
10 question, as well as to respond to concerns by the Governor of Maine about the safety
11 and effectiveness of regulatory oversight of Maine Yankee, the NRC Chairman initiated
12 an independent safety assessment of Maine Yankee.”
13 In my opinion the numerous defects in material, design basis, corporate culture,
14 and procedures detailed in my testimony far outweigh the reasons for the Maine Yankee
15 ISA. In fact, they more resemble the conclusions of the Maine Yankee ISA than the
16 reasons for the ISA.
17 Moreover, the New England Coalition is calling for an ISA at Vermont Yankee
18 because it is deemed the best tool for rooting out the problems that would lead to
19 decreased reliability and decreased safety under uprate conditions. NRC standard review
20 of EPU applications does not to our knowledge include a thorough review of design
21 basis, for example. But, at least for selected safety related systems, the ISA does.
22 Finally, it should be said that the ISA found Maine Yankee safe to operate though not at
23 uprated power.
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1 Q 15 Is there anything else of which you think the Board should take note?
2 Response: Yes, apropos to the question of potential adverse effects on the electric grid
3 and on reliability resulting from the uprate, I think that the Board should take notice of
4 the recent European nuclear power cooling constraints due to the unprecedented heat
5 wave as well as the recent interstate blackout. A July 23, 2003 letter from the North
6 American Electric Reliability Council warns that loss of reactive capability under nuclear
7 plant uprate conditions could adversely affect grid reliability. Specifically, the letter
8 warns, “ Another point in your report that deserves mention is the identified loss of 4,340
9 Mvar of generator reactive capability that accompanied the 1,200 MW increase in electric
10 output. In some cases, this loss of reactive capability could have significant effect on the
11 ability of the grid operator to maintain adequate voltages on the grid. An increase in real
12 power output at NPPs is certainly desirable, but not if it comes at the expense of
13 increased risk of inadequate grid voltages.”
14 Also I would like to share with the Board my conclusion that much of the
15 deferred maintenance of critical plant components, which is evidenced above, seems to
16 stem from Entergy’s single-mindedness about its bottom line. Vermonters certainly
17 appear to be handed an uneven share of the risks when compared to Entergy
18 shareholders.
19 Entergy policy is clearly spelled out in the Entergy Nuclear Vermont Yankee
20 Business Plan 2003 (April 2003, rev 1, “Lower costs translate into higher profits. With
21 clear corporate and market expectations of ENVY’s contributions to earnings, a
22 concentrated focus on lowering costs is required. Nuclear plants must have a low-cost
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1 position to remain competitive in an increasingly unregulated northeast market for
2 electricity.”
3 Q 16 Does that conclude you testimony?
4 Response Yes, it does.

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

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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, LLC August 19, 2003

PREFILED SURREBUTTAL TESTIMONY OF ARNOLD GUNDERSEN

Mr. Gundersen responds to Rebuttal Testimony of Entergy Nuclear Vermont

1 Q1. Please state your name and address.

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

4 Q2. What is the purpose of your testimony?

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

7 (“Entergy”) witnesses on issues of reliability, feasibility of the proposed power

8 uprate, environmental and radiological impacts and certain externalities such as

15 I am prevented from responding in full by Entergy’s continuing refusal, in

18 Coalition’s First Set of Information Requests.

19 Q.3 Is there evidence of physical deterioration of Vermont Yankee components

1 Response: There is evidence of physical deterioration of Vermont Yankee components

5 by Entergy’s untimely and incomplete responses to New England Coalition information

6 requests, numerous examples of deteriorated components, only marginally reliable

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

9 adverse effect on reliability under extended power uprate conditions?

11 discussed in Entergy’s Accelerated Corrosion Inspection Program, 1999 refueling outage

4 It is important to note that this sampling program is only a statistical sampling

5 which means that problems can still exits elsewhere.

7 replacement of selected components on short notice should be established". NOTE: This

11 or replacement of large bore components in the feedwater system should be considered."

12 On page 10 it is also acknowledges that only a "...relatively small number of components

13 inspected each outage."

14 On page 9 in the 2002 Refueling Outage Report on Flow Accelerated Corrosion,

18 for wall loss due to flow accelerated corrosion."

2 however no additional information regarding this program was provided in discovery

3 seven months later.

12 testimony entitled Vermont Yankee Power Upgrade Project Description a list

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

15 the feedwater system.

16 Q5 Please give another example of a component likely to have an adverse effect on

17 reliability under extended power uprate conditions.

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

5 baring any unusual accident or occurrence not yet seen.”

6 ENVY provided no documentation that I am aware of to show that Kuester’s

7 recommendations were acted upon.

16 interrupt the progression of the stress cracking… ”

17 In a 2/7/02 memo from Betti to “File UND2002-042 07”, entitled Condenser

20 Kuester’s recommendation 3 years earlier).

6 risk of condenser leaks.”

9 after the proposed extended power uprate happens.

10 Even as of October 2002, ENVY was still contemplating Kuester’s

13 tubes and increasing the inspection sample.

9 four years later.

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

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

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

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

4 author had not anticipated.

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

13 condenser tube sheet.

14 Q5 Are there additional examples of a components likely to have an adverse effect

16 to the Board’s attention?

21 together with improvised fixtures.

5 major steam dryer failure in June 2002.

8 unsigned, undated, untitled document provided by Entergy in discovery, reviewer Brian

17 now appears to be much worse than originally reported.

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

2 steam flows present during EPU operating conditions.”

15 ENVY Expert Witness Burns (reliability expert) provides an exhibit highlighting