Arnold Gundersen

376 Appletree Point Road, Burlington, VT 05401

Phone 802-865-9955 & Fax 802-865-9933
arnie@sailchamplain.net

November 14, 2005

Open Letter to:

The Citizens of Vermont, The Vermont State Legislature, Vermont's Congressional
Delegation, and the Nuclear Regulatory Commission's (NRC's) Advisory Committee on
Reactor Safeguards (ACRS)

I write to you as the only private citizen who has been accepted as an Expert Witness
before both the Vermont Public Service Board (PSB) and the NRC's Atomic Safety and
Licensing 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 throughout
the entire evaluation process, I am not a member of New England Coalition. My
technological recommendation is to continue Vermont Yankeeʼs operation at its existing
power 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 the
Extended Power Uprate (EPU) on the plant's aging components, and the inability of the
EPU 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 ever
have an accident, 40% more radiation would be released, and according to
Entergy's own expert witness testimony, the likelihood of such an accident will
be 25% higher than if the EPU power increase were not approved.
A. Gundersen ACRS Testimony 11-14-05 Page 2 of 5

2. Vermont Yankee is already an old plant, a 33-year-old plant, which will be

subjected to new increased stresses.
3. Finally, Entergy's proposed EPU power increase changes the most critical
safety design feature of Vermont Yankee. This so-called “NPSH issue”
leaves Vermont Yankee open to a China Syndrome type accident, a situation
that does not exist with Vermont Yankee's current operational design – only
with the proposed EPU power increase changes that would be made to the
operational 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 is
an international consensus that the radiation available to be immediately released will
increase by more than 40%. To avoid exceeding State and Federal allowable exposure
limits to the citizens of Brattleboro after the EPU power increase, Entergy requested and
the NRC has allowed Vermont Yankee to lower the theoretical radiation releases at its
present 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 radiation
assessment shell game is called the "Alternate Source Term." The real net effect after
the EPU is that the actual radiation released from a potential accident will be 40% more
than what would be released at the power level Vermont Yankee operates at today.

Furthermore, during the actual hearings before the Vermont Public Service Board in
2003, Entergy's expert witness acknowledged that the likelihood of an accident after the
EPU power increase would be 25 percent higher than if operations at this nuclear power
plant remained unchanged. If the likelihood of an accident increases by 25% and the
consequences of an accident increase by more than 40%, it is clear that Vermont
Yankee's safety margins will be significantly reduced after the EPU.

My second concern: Vermont Yankee has already been operating for 33 years, and the
age related problems the plant already has will be compounded by the additional
stresses 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 acknowledged
that this nuclear power plant would be less reliable after the EPU power increase. The
industry record of EPU power increase related failures is replete with five steam dryer
failures, two cracked turbine generator shaft failures, and numerous other failures of
aging equipment after much smaller uprate power increases than that which is currently
proposed for Vermont Yankee.

However, we need not look to other reactors to identify that age related equipment
failures 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 leak
criterion, and
• the condenser is so old that Entergy itself has stated that Vermont Yankeeʼs
condenser is "lucky to withstand gravity"!
Remember last year's fire that shut down Vermont Yankee for almost three weeks? In a
direct quote to the NRC about what really caused the fire, Vermont Yankee employees
stated, "The root causes of the event were determined to be inadequate preventative
maintenance…and failure to monitor age related degradation." The evidence shows
that the preventative maintenance issues to which Vermont Yankee refers in its
statement were known as critical preventive maintenance issues throughout the nuclear
industry since 1990, and yet, still ignored by Entergy as late as 2004 in its rush to put
Vermont Yankee back on line.

That fire confirmed what I stated back in October 2003 in formal testimony before
Vermont's Public Service Board, that there is "growing evidence that aging management
programs aren't working." My question remains the same in 2005. "What will break
next 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, there
is a reliable scientific and technical method to test the plant under the additional stress
of the proposed EPU power increase, called Full Power Transient Testing. The NRC
A. Gundersen ACRS Testimony 11-14-05 Page 4 of 5

originally required this test in order to allow Vermont Yankee to complete its proposed
EPU power increase and I also endorsed Full Power Transient Testing. Entergy has
consistently and adamantly opposed these tests, and with one minor exception, after
several years of pressure from Entergy, the NRC now appears to be willing to allow
Entergy to avoid any rigorous testing of Vermont Yankee.

Finally, my third concern: With the proposed EPU power increase, but not as Vermont
Yankee now operates, any one of several common, routine single failures within the
containment system must inevitably also cause the failure of the entire emergency
cooling system. This is the so-called "NPSH problem" or Net Positive Suction Head.
Containment failure simultaneous with emergency core cooling failure is catastrophic,
yet it becomes a profound possibility at Vermont Yankee for the first time with this
proposed EPU power increase.

In lay terminology, the proposed EPU power increase generates extra heat so that the
emergency pumps will not be able to draw a suction unless the containment is
absolutely leak-tight to push the water into the pumps. This is not a problem as
Vermont Yankee operates today, but it becomes a serious problem if the proposed EPU
power increase is approved. The ACRS and the NRC have published two written
directives prohibiting the use of containment pressure to push water toward the
emergency pumps. These regulations make a lot of sense, for if there were to be a
"single failure" of the containment system, Vermonter's need the emergency core
cooling system at Vermont Yankee to still operate in order to reduce the amount of
radiation released to the environment and to prevent a China Syndrome. After this
proposed EPU power increase, the Vermont Yankee Nuclear Power Plant will not be
able to withstand a "single failure". Yet with Entergy's push for increased power and
increased revenue, the NRC is now choosing to ignore both of the published NPSH
safety directives in order to grant Entergy its proposed EPU power increase for Vermont
Yankee.
A. Gundersen ACRS Testimony 11-14-05 Page 5 of 5

What benefits do Vermonters gain to offset these increased risks? Entergy will pay
Vermonters about one million dollars a year, or a buck and a quarter per Vermonter.
The extra power will not be used in Vermont, and the $20,000,000 in yearly profits will
go directly to the Louisiana-based Entergy Corporation.

If there is an accident, even a "small accident", all that we hold dear about the purity of
our natural lifestyle will be lost forever, all for a buck and a quarter per person per year.
Vermonters are risking the reputation of the integrity of our dairy, produce, recreational,
and tourist industries to gain that buck and a quarter. To me, a Vermont citizen with
nothing to gain financially or professionally on either side of this argument, the benefits
simply do not warrant the extensive risks.