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Gundersen Letter to NRC ACRS re VY Uprate 11-05, Fairewinds Associates, Inc

Gundersen Letter to NRC ACRS re VY Uprate 11-05, Fairewinds Associates, Inc

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Published by: fairewinds on Apr 13, 2010
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Arnold Gundersen
376 Appletree Point Road, Burlington, VT 05401
Phone 802-865-9955 & Fax 802-865-9933
November 14, 2005Open Letter to:The Citizens of Vermont, The Vermont State Legislature, Vermont's CongressionalDelegation, and the Nuclear Regulatory Commission's (NRC's) Advisory Committee onReactor Safeguards (ACRS)I write to you as the only private citizen who has been accepted as an Expert Witnessbefore both the Vermont Public Service Board (PSB) and the NRC's Atomic Safety andLicensing Board in the case regarding the proposed power increase at Entergy's 33-year-old Vermont Yankee Nuclear Power Plant to 120 percent of design capacity.Although New England Coalition retained me as a technical expert witness throughoutthe entire evaluation process, I am not a member of New England Coalition. Mytechnological recommendation is to continue Vermont Yankee
s operation at its existingpower level until its 40-year license expires in 2012.I believe that increasing the power output of this 33-year-old nuclear reactor by 20%more than it was designed to produce should be reexamined for three broad reasons:reduction of safety margins, additional increased power production stresses of theExtended Power Uprate (EPU) on the plant's aging components, and the inability of theEPU design to protect Vermonters in the event of a "single failure."Briefly, my personal technical safety concerns are as follows:1.
After a power increase of this magnitude, if Vermont Yankee should everhave an accident, 40% more radiation would be released, and according toEntergy's own expert witness testimony, the likelihood of such an accident willbe 25% higher than if the EPU power increase were not approved.
A. Gundersen ACRS Testimony 11-14-05
Page 2 of 5
Vermont Yankee is already an old plant, a 33-year-old plant, which will besubjected to new increased stresses.3.
Finally, Entergy's proposed EPU power increase changes the most criticalsafety design feature of Vermont Yankee. This so-called “NPSH issue”leaves Vermont Yankee open to a China Syndrome type accident, a situationthat does not exist with Vermont Yankee's current operational design – onlywith the proposed EPU power increase changes that would be made to theoperational and safety design.Let me elaborate on each power related safety concern with technical details:My first concern: In the event of an accident after a 20% EPU power increase, there isan international consensus that the radiation available to be immediately released willincrease by more than 40%. To avoid exceeding State and Federal allowable exposurelimits to the citizens of Brattleboro after the EPU power increase, Entergy requested andthe NRC has allowed Vermont Yankee to lower the theoretical radiation releases at itspresent power level by about 40%. This 40% theoretical reduction offsets the real 40%net increase. Thus it appears on paper as if there is no difference. This radiationassessment shell game is called the "Alternate Source Term." The real net effect afterthe EPU is that the actual radiation released from a potential accident will be 40% morethan what would be released at the power level Vermont Yankee operates at today.Furthermore, during the actual hearings before the Vermont Public Service Board in2003, Entergy's expert witness acknowledged that the likelihood of an accident after theEPU power increase would be 25 percent higher than if operations at this nuclear powerplant remained unchanged. If the likelihood of an accident increases by 25% and theconsequences of an accident increase by more than 40%, it is clear that VermontYankee's safety margins will be significantly reduced after the EPU.My second concern: Vermont Yankee has already been operating for 33 years, and theage related problems the plant already has will be compounded by the additionalstresses of the proposed EPU power increase. During the hearings before the Vermont
A. Gundersen ACRS Testimony 11-14-05
Page 3 of 5
Public Service Board, an expert hired by Entergy and Vermont Yankee acknowledgedthat this nuclear power plant would be less reliable after the EPU power increase. Theindustry record of EPU power increase related failures is replete with five steam dryerfailures, two cracked turbine generator shaft failures, and numerous other failures ofaging equipment after much smaller uprate power increases than that which is currentlyproposed for Vermont Yankee.However, we need not look to other reactors to identify that age related equipmentfailures are already impacting Vermont Yankee's performance.
Vermont Yankee's steam dryer has 40 new cracks since only 18 months ago,
the Main Steam Isolation Valves are no longer able to meet their original leakcriterion, and
the condenser is so old that Entergy itself has stated that Vermont Yankee
scondenser is "lucky to withstand gravity"!Remember last year's fire that shut down Vermont Yankee for almost three weeks? In adirect quote to the NRC about what really caused the fire, Vermont Yankee employeesstated, "The root causes of the event were determined to be inadequate preventativemaintenance…and failure to monitor age related degradation." The evidence showsthat the preventative maintenance issues to which Vermont Yankee refers in itsstatement were known as critical preventive maintenance issues throughout the nuclearindustry since 1990, and yet, still ignored by Entergy as late as 2004 in its rush to putVermont Yankee back on line.That fire confirmed what I stated back in October 2003 in formal testimony beforeVermont's Public Service Board, that there is "growing evidence that aging managementprograms aren't working." My question remains the same in 2005. "What will breaknext in a very old plant under very new EPU increased power stresses?"If the Vermont Yankee nuclear power plant is indeed as robust as Entergy claims, thereis a reliable scientific and technical method to test the plant under the additional stressof the proposed EPU power increase, called Full Power Transient Testing. The NRC

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