ML081090352
| ML081090352 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 03/06/2008 |
| From: | Chan T, Jennifer Davis, Andrea Keim, Sexton K Office of Nuclear Reactor Regulation, NRC/OGC |
| To: | Atomic Safety and Licensing Board Panel, NRC/SECY/RAS |
| SECY RAS | |
| References | |
| 50-293-LR, ASLBP 06-848-02-LR, Pilgrim-Staff-41, RAS J-71 | |
| Download: ML081090352 (20) | |
Text
1F5~~7
/
March 6, 2008 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of Entergy Nuclear Generation Co. and Entergy. Nuclear Operations, Inc.
(Pilgrim Nuclear Power Station)
))
)
)
)
)
)
Docket No. 50-293-LR ASLBP No. 06-848-02-LR REBUTTAL TESTIMONY AND RESPONSES TO BOARD QUESTIONS OF DR. JAMES A. DAVIS, TERENCE L. CHAN AND ANDREA T. KEIM CONCERNING PILGRIM WATCH CONTENTION 1 James A. Davis ("JAD"), Terence L. Chan ("TLC") and Andrea T. Keim ("ATK"), do hereby state as foliows:
Q1.
Please state your name.
Ala.
(JAD) James A Alb.
(TLC) Terence Alc.
(ATK) Andrea Q2.
Have you provi A2. ' (JAD) (TLC) (A U.S&NUCL.A-REGLATORY CO*&.0O oa#e*
S 4,,CJe fma*-_ -LibaulI' this matter and is provided to the Pilgrim Watch witnesses E dated February 21, 2008.1 DOCKETED I I5.NIf Q3.
Have you revie Andl 15. 2008 (10:00am)
OFFICE OF SECRETARY P*I 1 FIMAKINr.
ANn An).II Ifl).ATION.R.5TAFF A3.
(JAD) (TLC) (A Ahlfeld.
1 Order and Notice (Re(
for Parties (Feb. 21, 2008) (unpu 7~99~56 W~e-
& 27 zxso.Eý>
March 6, 2008 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
Entergy Nuclear Generation Co. and Entergy Nuclear Operations, Inc.
)
Docket No. 50-293-LR
)
ASLBP No. 06-848-02-LR (Pilgrim Nuclear Power Station)
REBUTTAL TESTIMONY AND RESPONSES TO BOARD QUESTIONS OF DR. JAMES A. DAVIS, TERENCE L. CHAN AND ANDREA T. KEIM CONCERNING PILGRIM WATCH CONTENTION 1 James A. Davis ("JAD"), Terence L. Chan ("TLC") and Andrea T. Keim ("ATK"), do hereby state as follows:
Q1.
Please state your name.
Ala.
(JAD) James A. Davis.
Alb.
(TLC) Terence L. Chan.
Alc.
(ATK) Andrea T. Keim.
Q2.
Have you provided testimony previously in this matter?
A2.
(JAD) (TLC) (ATK) Yes. This testimony is in addition to my previous testimony in this matter and is provided to specifically respond to issues raised in the prefiled testimony of the Pilgrim Watch witnesses and also to respond to the Licensing Board's questions in its Order dated February 21, 2008.1 Q3.
Have you reviewed the testimony of the Pilgrim Watch witnesses?
A3.
(JAD) (TLC) (ATK) Yes, I have reviewed the testimony of Mr. Gundersen and Dr.
Ahlfeld.
1 Order and Notice (Regarding Hearing, Limited Appearance Session and Additional Questions for Parties (Feb. 21,2008) (unpublished).
Q4.
Pilgrim Watch asserts that the aggressiveness of the soil has not been properly evaluated.2 Does Entergy have a procedure for testing the aggressiveness of soil?
A4.
(JAD) Yes, Entergy Specification EN-DC-343 gives the procedure for testing the aggressiveness of soil. 3 in addition, in Entergy's Testimony, the witnesses state that there are three precautions taken to ensure that the piping is not buried in an aggressive soil environment. Entergy Testimony at A83. First, the piping is buried using select backfill. Id.
Second, during construction, all rocks over 6 inches, shrubs, and trees are removed from the backfill. Id. Third, when Pilgrim was erected, a storm drain system was installed to prevent the buildup of water; and buried pipes are buried above the water table. Id.
Q5.
Pilgrim Watch claims that Entergy's failure to address Flow Accelerated Corrosion ("FAC") in its License Renewal Application ("LRA") is a deficiency. PW Statement at 32-33. Is FAC an aging mechanism that is of concern for buried piping containing radioactive contaminated water?
A5.
(JAD) No. Pilgrim Watch suggests that FAC would be a factor in the degradation of the buried pipes at Pilgrim in their testimony as follows:
7.2.3. Flow Accelerated Corrosion (FAC): FAC is a pipe wall thinning phenomena in which the thinning rate is accelerated by flow velocity. FAC includes wall thinning by electrochemical corrosion, erosion-corrosion and cavitation-corrosion. All three are affected by flow velocities. Although the main causes of FAC (turbulence intensity, material compositions, oxygen content and pH) have been identified, the behavior of FAC is not completely understood......
PW Statement at 32-33.
2 Pilgrim Watch Presents Statements of Position, Direct Testimony andExhibits under 10 CFR 2.1207 at 56 (Jan. 29, 2008, modified Mar. 3, 2008) ("Pilgrim Watch Statement", or "PW Statement").
3 Testimony of Alan Cox, Brian Sullivan, Steve Woods, and William Spataro of Pilgrim Watch Contention 1, Regarding Adequacy of Aging Management Program for Buried Pipes and Tanks and Potential Need for Monitoring Wells to Supplement Program (Jan. 8, 2008) ("Entergy Testimony"), Exhibit 5 at 10-16 ("Entergy Ex.").
There are a number of incorrect statements in Pilgrim Watch's testimony regarding FAC,
(
which shows a complete misunderstanding of this phenomenon. Flow accelerated corrosion has never been observed in service water piping or buried condensate storage piping. As Pilgrim Watch's footnote 4 indicates, FAC occurs in feed water piping constructed from carbon steel with no internal lining. NRC Bulletin No. 87-01, Thinning of Pipe Walls in Nuclear Power Plants,"5 was written to request information concerning licensees' programs for monitoring the thickness of pipe walls in high-energy single-phase and two-phase carbon steel piping systems.
High energy piping systems are piping systems that operate at temperatures above 200TF or above 275 pound per square inch gage ("psig") or both. Neither the CS system piping nor the SSW system piping qualify as high-energy piping systems and are therefore not subject to FAC.
The Electric Power Research Institute has developed several computer codes to give guidance to operators of nuclear power plants on how to ins'pect for flow accelerated corrosion in feedwater piping. The programs are Checkmate and Checkworks. These programs determine where flow accelerated corrosion is most likely to occur and guidance is given on how to inspect for flow accelerated corrosion. Basically, the licensees place a grid on the outside of the pipes and make periodic ultrasonic thickness measurements in the high susceptibility locations. Licensees may select additional locations to monitor in addition to the locations predicted by Checkmate or Checkworks. In areas where flow accelerated corrosion is identified, the carbon steel piping is replaced with carbon steel that contains 2% chromium, a material like stainless steel or titanium that is resistant to flow accelerated corrosion. Contrary to Pilgrim Watch's statement, PW Statement at 33, the computer code RELAP cannot be used to predict where flow accelerated corrosion might occur.
Q6.
Is "leak before break" applicable to buried piping?
4 PW Statement at 33, n.45.
5 Staff Exhibit ("Staff Ex.") 21.
A6.
(JAD) No. On page 19 of Pilgrim Watch's Statement of Position, the argument is made that Monitoring wells and a more robust inspection protocol are necessary to detect small leaks from the buried piping/tanks that, left alone, could become larger leaks. Whereas small leaks do not pose a serious challenge by themselves to the ability of the buried piping in the condensate system, for example, to get the required water volume from the condensate storage tank to the RCIC/HPCI systems, the "leak before break" concept suggests that the small leak could be indicative of deteriorating conditions that could lead to a pipe break. But "indicative" only works if one has the means to recognize the indication.
However, leak before break is not applicable to Pilgrim. It is a concept applied to high energy piping in PWRs. The leak before break concept concerns high energy pipe breaks, such as during postulated loss of coolant accidents ("LOCAs"), where a pipe will leak and the leak will be detected before a flaw reaches the fracture mechanics critical flaw size and the pipe ruptures. It is used to analyze the behavior of cast stainless elbows, for instance. Leak before break does not apply to the CS or SSW buried piping at the Pilgrim site. Leak before break also does not apply to buried stainless steel, carbon steel, or titanium piping.
Q7.
Was any action taken by the NRC regarding the possibility that counterfeit pipes could-have been used at nuclear power plants such as Pilgrim?
A7.
(JAD) The NRC issued Generic Letter 89-02, "Actions to Improve the Detection of Counterfeit and Fraudulently Marked Products," in 1989 to advise holders of operating licenses and construction permits for nuclear power plants of ways to reduce the likelihood of the introduction of counterfeit or fraudulent products into their plants and to assure the quality of procured vendor products. Upon receipt of the generic letter, licensees were to take appropriate actions to avoid using counterfeit and fraudulently marked products using the methods identified in the generic letter.
Q8.
Pilgrim Watch makes multiple statements about Entergy's supposed failure to use cathodic protection. Is there a requirement to use cathodic protection for buried pipelines?
A8.
(JAD) No. There is no requirement to use cathodic protection for buried pipelines. There is no discussion of cathodic protection in 10 C.F.R. Part 50 or in the American Society of Mechanical Engineers ("ASME") Boiler and Pressure Vessel Code.
Q9.
Is the bathtub curve relevant to the buried piping at Pilgrim?
A9.
(JAD) No. Statements made in Pilgrim Watch's Statement of Position are incorrect. For instance, Pilgrim Watch states: "Stainless steel and titanium are known as passive metals which form a "passive" oxide layer on their surface that makes it immune to general corrosion until the oxide layer is breached, which will eventually happen; then corrosion occurs on the bare metal underneath. The oxide layer can be breached by a variety of factors."
Pilgrim Watch Statement at 26.
While the portion of the statement about stainless steel and titanium being passive metals is correct, the rest of the statement is incorrect. Stainless steel and titanium spontaneously repassivate if the oxide film is ruptured. The time required for spontaneous repassivation is measured in nanoseconds and significant corrosion does not occur. The spontaneous repassivation experiments I have conducted showed repassivation rates too fast to accurately record. Therefore, the stainless steel and titanium piping at Pilgrim would not show the bathtub curve behavior.
Furthermore, the purpose of the aging management program Buried Piping and Tanks Inspection Program ("BPTIP") is to prevent region C of the bathtub curve from occurring.
Q10.
Is Pilgrim Watch accurate in quoting Dr. Davis as follows:
Mr. Davis, the NRC Staffs expert, in NRC Staff Response to Entergy's Motion of Summary Disposition, June 28, 2007, explained why relying on industry experience may need to be qualified. Davis said, at 16 [Pilgrim Watch Exhibit 11] that,
'...industry practice has shown that properly applied coatings will prevent corrosion as long as the soil is not extremely aggressive (as Entergy states is not the case at Pilgrim) or unless there is damage during application of the coating and handling of the pipe.' [Emphasisadded]."?
6 6 PW Staternent at 72.
A10.
(JAD) No. Pilgrim Watch took the quote out of context, entirely ignoring my discussion of the program at Pilgrim. In the answer to Q9 of my testimony, I stated that:
The BPTl AMP calls for using preventative measures to mitigate corrosion and periodic inspections to determine if corrosion is occurring that could affect the pressure-retaining capacity of the buried steel piping and tanks. The preventive measures to mitigate corrosion involve the use of protective coatings combined with periodic inspections. Corrosion can occur as a result of exposure to an aggressive soil environment. The four relevant aging effects are general, pitting, crevice corrosion, and microbiologically-influenced corrosion ("MIC"). Inspections are to be conducted each time the piping is uncovered for maintenance.
For example, the coating and external surface of two 40 foot sections of piping on the discharge loops were examined in 1999 when the two 40 foot sections were replaced. The coatings were found to be in good condition and no external corrosion was noted. Those coatings were then removed to inspect the outside surface of the piping which was also found to be in good condition.
This means that aggressive soils will not cause corrosion of buried piping with properly applied coatings. Corrosion will only occur if the coating is damaged and the aggressive soil contacts the steel where the coating has been damaged. There is no evidence that the coating has been damaged in the buried piping at Pilgrim.
In addition, Entergy discussed its program for preventing damage to the buried piping in its testimony:
PNPS coatings exceed industry standards in two major respects.
PNPS has generally double wrapped its buried piping. As described earlier, Specification No. 6498-M-306 provided for double wrapping of buried pipe consisting of a permanent protective coal-tar coating, fiberglass wrapping, another layer of coal-tar, a layer of insulation, and a final layer of heavy Kraftpaper.
The standard industry practice, as set forth in AWWA C-203, requires a single wrapping for buried piping under normal soil conditions. AWWA C-203 does provide for double wrapping of pipe but only for unusual or severe conditions, such as when pipes are submerged under water. The coal-tar enamel permanent coating and bonded double outerwrap used at PNPS is specifically designed for use on submerged lines, river crossings, 7 NRC Staff Testimony of Dr. James A. Davis Concerning Pilgrim Watch Contention 1 at A9 (Jan. 29, 2008) ("Davis Testimony").
or similar installations involving aggressive environments, or where trench conditions are extraordinarily severe, conditions that do not apply at PNPS.
Second, it has been the practice at PNPS to wrap titanium and stainless steel buried piping, although neither is susceptible to corrosion caused by soil conditions. This is not the standard practice for the industry, which typically buries titanium and stainless steel pipe with no protective coatings because of their inherent corrosion resistance.
Entergy Testimony at A57.
Entergy also discussed the precautions taken to ensure that the soil environment around the buried piping is not aggressive. That includes placing the piping "on a bed of sand or specially engineered fill before it is covered by another layer of fill." Id. at A83. The sand or fill is very porous so water can percolate through, and therefore moisture is not retained and there is a high resistivity to corrosion. Id. In addition, during construction of Pilgrim, the site was excavated and all rocks over'six inches, shrubs, and trees 'Vere removed from the soil. Id.
"These two precautions serve to reduce the corrosivity of the soil environment experienced by K
the buried piping at PNPS. Additionally....
the soil's pH of 6.2-6.82 and Cl-content of 210 -
420 ppm show that neither of these factors creates an aggressive soil environment." Id.
Entergy went on to say:
(SPW) In addition to surrounding buried pipe with sand or special fill material, as already described, two other important precautions are taken to prevent high levels of soil moisture from occurring: (1) when PNPS was erected, a storm drain system was installed to prevent the buildup of water; and (2) buried pipes are buried above the water table.
Id. at A84.
The combination of these statements provided additional information about the special precautions that are taken at Pilgrim in handling the coated pipe, in addition to the fact that the pipes are inspected using a high voltage holiday detector just prior to back filling, and demonstrate that the coatings had not suffered any damage during handling and that they were not placed in an aggressive soil environment.
Ql1.
Did Entergy find that its buried piping and tanks program was inadequate and develop the BPTIP because of the contention filed by Pilgrim Watch, as suggested by Mr.
Gundersen in § 12 of his testimony? 8 Al 1.
(JAD) No. When Entergy prepared their application for license renewal, Entergy was required to identify any potential aging effects for systems, structures, and components in scope for license renewal and then provide an aging management program to manage the effects of aging for the period of extended operation in accordance with 10 C.F.R.
§ 54.21 (a)(3). Entergy identified loss of material due to general, pitting, crevice, and MIC as the relevant aging effects and proposed the BPTIP to manage the effects of aging for the period of extended operation. LRA at 3.3-22.
Q12.
Is a baseline inspection required for buried piping as suggested by Mr.
Gundersen in'his testimony at.§§ 12.4.1.1 and 12.4.1.3?
A12.
(JAD) No. However, in effect, there is a baseline inspection conducted and described in Entergy Specification No. 6498-M-306 (3 of 4). Entergy Ex. 3 at 3. After the pipe is coated, it is visually inspected and then inspected for cracks, dents, and holidays using a high voltage holiday detector. After field joints are prepared and coated, the piping is reinspected using the high voltage holiday detector prior to being buried using select backfill to avoid damage to the coating. Id.
Q13.
Mr. Gundersen states that if buried piping with a low inspection priority is excavated for other reasons, then the procedure should have workers inspect the coatings when the piping is uncovered. Gundersen Testimony at §§ 12.4.5.4 -12.5.4.5. Is this done?
A13.
(JAD) Yes. The BPTIP requires that regardless of inspection priority, when a section of buried piping is uncovered, it will be inspected.
8 Declaration of Arnold Gundersen Supporting Pilgrim Watch's Petition for Contention 1 at § 12 (Jan. 26, 2008) ("Gundersen Testimony").
Q14.
Mr. Gundersen comments in his testimony that the BPTIP is silent on internal
(.
corrosion. Gundersen Testimony at § 12.4.6.3. Is this correct?
A14.
(JAD) Yes. The BPTIP only applies to external corrosion of buried piping.
There are other programs thatdeal with internal corrosion such as the Service Water Integrity Program (LRA at § B.1.28) for SSW and the Water Chemistry Control - BWR Program (LRA at
§ B.1.32.2) for CS system.
Q15.
What requirements are there to initiate a condition report ("CR") and what happens after it is initiated?
A15.
(JAD) 10 C.F.R. Part 50 Appendix B, XVI states:
Measures will be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition. The identification of the cause of the condition, and corrective action taken shall be documented and reported to appropriate levels of management.
10 C.F.R. Part 50 Appendix B, XVII states:
Sufficient records shall be maintained to furnish evidence of activities affecting quality. The records shall include at least the following: Operating logs and the results of reviews, inspections, tests, audits, monitoring of work performance, and materials analyses. The records will also include closely-related data such as qualifications of personnel, procedures, and equipment.
Inspection and test records shall, as a minimum, identify the inspector or data recorder, the type of observation, the results, the acceptability, and the action taken in connection with any deficiencies noted. Records shall be identifiable and retrievable.
Consistent with applicable regulatory requirements, the applicant shall establish requirements concern record retention, such as duration, location, and assigned responsibility."
Pilgrim's 10 C.F.R. Part 50 Appendix B program is applicable to all aging management programs that will be required during the period of extended operation. This includes all safety-related and non-safety related systems, structures and components covered by an AMP during the period of extended operation.
Every CR is reviewed briefly by the NRC Resident Inspectors at Pilgrim. In addition, there is an inspection module for auditing the CR process by selecting a sample of the CRs and conducting an in depth review of the CRs. 9 This audit is carried out by the Regional Inspectors on the selected CRs.
10 C.F.R. § 72.75 contains the criteria for determining which events must be reported to the NRC staff. Not all CRs are required to be reported to the NRC.
Q16.
Does Entergy's program have commitments associated with each plant?
A16.
(JAD) Yes. The commitments for license renewal for Pilgrim are presented in Appendix B of the Safety Evaluation.
Q17.
Are the AMPs for buried piping containing radioactive liquids. adequate?
A17.
(JAD) I have stated that the buried pipes at Pilgrim that could potentially contain radioactive liquid have either been replaced or have not experienced external or internal degradation. In addition, aging of buried piping at Pilgrim is effectively managed by the Buried Piping and Tanks Inspection Program. for the external surfaces, by the Service Water Integrity Program for SSW piping, and by the Water Chemistry Control - BWR Program and One-Time Inspection Program for the CS piping. The external inspection is a visual inspection that looks for any evidence of damaged wrapping or coating defects, such as coating perforation, holidays, or other damage that is an indicator that there is possible corrosion damage to the external surface of the piping. As described in detail above, the combination of these AMPs provide reasonable assurance that the buried piping and tanks containing or potentially, containing radioactive liquid at Pilgrim will maintain their intended functions for the period of extended operation. For these reasons, as I stated in the Staff's Prefiled Testimony, these AMPs are adequate as they are and no leak detection devices are required. Davis Testimony at Al 7.
9 NRC Inspection Manual, Inspection Procedure 35101, QA Program Implementation Inspection for Operational Programs (Staff Ex. 23).
Q18.
Pilgrim Watch states that all buried pipes and tanks have the same four intended safety functions:
(1) keeping the liquid inside the component and not to allow leakage into the ground, the principle function of any pipe; (2) service the system it feeds; (3) prevent radioactive contamination from entering the ground that could result in significant harm to the health and safety of the public; and (4) prevent future legacy sites.
PW Statement at 90. Further, "their primary intended function" is to "isolate[] the liquid from the environment." Id. at 99. Do you agree?
A18.
(ATK) No. My initial testimony contains a discussion of the safety functions of the SSW system and the CS System at Pilgrim. 10 As I have previously stated, the SSW system is addressed in the Pilgrim Nuclear Power Station Final Safety Analysis Report ("FSAR") at chapter 10.7. Chan and Keim Testimony at A15. The CS system is addressed in chapter 11.9 of the FSAR. Id. atA7, A10. 11 Q19. How are systems, structures, and components determined to be within the scope of license renewal?
A19.
(ATK) The scoping criteria for license renewal is set forth in 10 C.F.R. § 54.4.
As I stated in the Staff's response to the Board Questions, "That regulation describes the structures, systems or components that are in-scope for license renewal. If a structure, system or component fulfills a function listed in 10 C.F.R. §§ 54.4(a)(1),(2), or (3), then it is within scope
[for] license renewal."'12 Q20.
Are Pilgrim Watch's references to recent research Dr. Gilbert Bellanger relevant to Pilgrim?
10 NRC Staff Testimony of Terence L. Chan and Andrea T. Keim Concerning Pilgrim Watch Contention 1 atA7, A10, A15 (Jan. 29, 2008) ("Chan and Keim Testimony").
11 The CS system does not have a credited safety function in the FSAR. Chan and Keim Testimony at A7, A10.
12 Affidavit of Dr. James A. Davis and Andrea T. Keim in Response to Licensing Board Questions in Order (Board Questions for the NRC Staff and Applicant) at 3 (Feb. 11, 2008) ("Staff Affidavit") (Staff Ex. 24).
A20.
(ATK) No, the research, found in the book 13 referenced by Pilgrim Watch, Pilgrim Watch Statement at 27, addresses highly concentrated tritium and tritium water and is not relevant to light water reactors such as Pilgrim. Dr. Bellanger specifically states that the testing and research medium used "is very reactive and its properties are completely different from the light water in nuclear power stations." Staff Ex. 22 at 35. He goes on to say th'at the behaviors and types of corrosion are completely different in the installations he is discussing and that no comparison is possible. Id.
Q21.
Pilgrim Watch makes reference to a Brookhaven Report entitled "Risk Informed Assessment of Degraded Buried Piping Systems in Nuclear Power Plants" 1 4 in various locations of its testimony.1 5 What is the purpose of that report?
A21.
(TLC) The report documents the efforts of the NRC's Office of Regulatory Research to assess the effects of age-related degradation of buried piping at nuclear power plants. As stated in the Abstract of the report, "The evaluation of buried piping was conducted in order to develop analytical methods and degradation acceptance criteria (DAC) that can be used to assess the condition of degraded buried piping." Brookhaven Report at iii. Further, "The methodology and degradation acceptance criteria (DAC) developed in this report are intended to provide guidance to the NRC staff for making an assessment in a timely manner whether degraded conditions, identified at a plant site, potentially have an immediate significant effect on plant risk. Id. This knowledge is important in order to provide input that can help determine whether immediate repairs are warranted, or whether... other actions can be determined in the normal course of evaluating the condition....." Id.
13 G. Bellanger, Corrosion Induced by Low Energy Radionuclides: Modeling of Tritium and Its Radiolytic and Decay Products Formed in Nuclear Installations, Elsevier Publications, 2004 (excerpt).
(Staff Ex.22).
14 Brookhaven National Laboratory, NUREG/CR6876 (June 2005) ("Brookhaven Report").
15 See, e.g., PW Statement at 12, 17-18, 20, 25-28.
The report does not make any attempt to conclude what leakage is acceptable or not acceptable, nor does it address the capability of a system which contains the degraded buried piping to fulfill its safety function.
Q22.
Is Pilgrim Watch accurate in quoting the Brookhaven report as follows?
Buried piping systems at a nuclear power plant can degrade [and]
Such deterioration could impair the operation of the system that contains the buried piping, and thus impact the overall safety of the NPP [Brookhaven Report at 97].
Pilgrim Watch Statement of Position at 18.
A22.
(TLC) No. The Brookhaven report actually states:
Buried piping systems at a nuclear power plant can degrade, as described in the previous sections. Such deterioration potentially could impair the operation of the system that contains the buried piping, and thus impact the overall risk of an NPP.
Brookhaven Report at 97. The use of the word "risk" rather than "safety" is significant in that a change in risk does not necessarily impact safety. The Brookhaven report is careful not to conclude that all degradation has the potential of impairing operation of a system.
Q23.
Is the result of the Bernoulli principle, as described by Pilgrim Watch, capable of "rendering the system 'unable to perform the intended safety function"'? Gundersen Testimony at § 17.2; PW Statement at 18-19.
A23.
(TLC) The Staff does not possess detailed knowledge about the systems' configuration and design features to provide a plant-or system-specific answer. However, the estimated velocity of the fluids within service water systems and condensate systems are such that the normal pressure within such piping readily overcomes the negative contribution of the Bernoulli principle and results in out-leakage of liquid from a breach in the pipe wall, rather than intrusion of debris.
Board Questions By Order dated January 11, 2008, the Board directed the Staff and the Applicant to answer several questions. Order (Board Questions for the NRC Staff and Applicant) (Jan.11, 2008). The Staff's answers to the Board's questions are attached hereto as Staff Ex. 24.
In its Order of February 21, 2008, the Board asked additional questions. The Staffs answers follow.
Qa.
In follow-up to the Board's questions of January 31, 2008, we direct the Licensee to address the following fundamental question regarding the Condensate Storage System ("CSS"): How large of a leak can the CSS withstand before its ability to satisfy its intended safety function is challenged, and how small of a leak is certain to be detected? The other parties may reply to this inquiry to the extent of their capability to do so.
Aa.
(ATK) The Staff does not have detailed design information for this system.
However, the Staff notes that the CS system does not have a credited safety function.
Qb. With regard to corrosion-induced small leaks that might grow rapidly into large enough leaks to challenge the ability of the CS system to satisfy its intended safety function, the parties shall provide, to the extent of their capability, concise and specific technical testimony addressing the reasonably expected growth in leakage rate over times ranging from at least four hours to three days.
Ab.
(JAD) The only way that a leak could form in the stainless, steel CS system piping is by pitting or corrosion of the heat affected zone as a result of microbiologically-influenced corrosion ("MIC"). Neither of these types of corrosion has been observed at Pilgrim. Once a leak starts, it will not grow rapidly and the leak rate will not be expected to noticeably increase over four days. The flow of water out of the leak source would be too low to cause erosion.
There would be an almost unnoticeable increase in leak rate.
f-~,*
iI UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of Entergy Nuclear Generation Co. and Entergy Nuclear Operations, Inc.
)
Docket No. 50-293-LR
)
ASLBP No. 06-848-02-LR (Pilgrim Nuclear Power Station)
PREFILED REBUTTAL TESTIMONY OF TERENCE L. CHAN CONCERNING CONTENTION 1 I, Terence L. Chan, do declare under penalty of perjury that my statements in the foregoing testimony are true and correct to the best of my knowledge and belief.
/Original Signed By!
Terence L. Chan Executed at Rockville, Maryland This 3rd day of March, 2008.
(K>..
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of Entergy Nuclear Generation Co. and Entergy Nuclear Operations, Inc.
(Pilgrim Nuclear Power Station)
)
)
)
Docket No. 50-293-LR ASLBP No. 06-848-02-LR PREFILED REBUTTAL TESTIMONY OF DR. JAMES A. DAVIS 1, James A. Davis, do declare under penalty of perjury that my statements in the foregoing testimony are true and correct to the best of my knowledge and belief.
/Original Signed By!
James A. Davis Executed at Shippingport, Pennsylvania this 5 th day of March, 2008.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of Entergy Nuclear Generation Co. and Entergy Nuclear Operations, Inc.
(Pilgrim Nuclear Power Station)
Docket No. 50-293-LR ASLBP No. 06-848-02-LR PREFILED REBUTTAL TESTIMONY OF ANDREA T. KEIM 1, Andrea T. Keim, do declare under penalty of perjury that my statements in the foregoing testimony are true and correct to the best of my knowledge and belief.
lOriginal Signed By!
Andrea T. Keim Executed at Rockville, Maryland this 6 th day of March, 2008.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ENTERGY NUCLEAR OPERATIONS, INC.
(Pilgrim Nuclear Power Station)
))
)
)
)
)
Docket No. 50-293-LR ASLBP No. 06-848-02-LR CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF INITIAL STATEMENT OF POSITION ON PILGRIM WATCH CONTENTION 1", "NRC STAFF TESTIMONY OF TERENCE L. CHAN AND ANDREA T. KEIM CONCERNING PILGRIM WATCH CONTENTION 1", "NRC STAFF TESTIMONY OF DR. JAMES A. DAVIS REGARDING PILGRIM WATCH CONTENTION 1", CERTIFICATIONS of Terence L. Chan, Andrea T. Keim and Dr. James A. Davis and Exhibits 1 - 20 in the above-captioned proceeding have been served on the following by electronic mail and by deposit in the U.S. Nuclear Regulatory Commission's internal mail system as indicated by a single asterisk(*), or by electronic mail and by deposit in the U.S. Mail System, as indicated by a double asterisk (**) this 29th day of January, 2008.
Administrative Judge*
"Richard F. Cole Atomic Safety and Licensing Board Panel Mail Stop:.T-3F23 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 E-mail: rfcl @nrc..qov Administrative Judge*
Ann Marshall Young, Chair Atomic Safety and Licensing Board Panel Mail Stop: T-3F23 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 E-mail: amyv6nrc.qov Sheila Slocum Hollis**
Duane Morris LLP 1.667 K Street, NW, Suite 700 Washington, DC 20006 E-mail: sshoIlis(cduanemorris.com Administrative Judge*
Paul B. Abramson Atomic Safety and Licensing Board Panel Mail Stop: T-3F23 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001, E-mail: pbadnrc.qov Office of Commission Appellate
- Adjudication Mail Stop: 0-16G4 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 E-mail: OCAAMail(anrc.gov Office of the Secretary*
Attn: Rulemaking and Adjudications Staff Mail Stop: O-16G4 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 E-mail: hearingdocket()nrc.gov
(
Atomic Safety and Licensing Board*
Mail Stop: T-3F23 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Mary Lampert**
148 Washington Street Duxbury, MA 02332 E-mail: lampert(cadelphia.net Terence A. Burke, Esq.**
Entergy Nuclear 1340 Echelon Parkway Mail Stop: M-ECH-62 Jackson, MS 39213 David R. Lewis, Esq.**
Paul A. Gaukler, Esq.
Pillsbury, Winthrop, Shaw, Pittman, LLP 2300 N Street, NW Washington, DC 20037-1137 E-mail: david.lewisnpillsburylaw.com PauI.gaukler( pillsburylaw.com Town Manager**
Town of Plymouth 11 Lincoln St.
Plymouth, MA 02360 E-mail: msylvia (townha1l.plymouth.ma.us Chief Kevin M. Nord**
Fire Chief & Director Duxbury Emergency Management Agency 668 Tremont Street
.Duxbury, MA 02332 E-mail: nord(ctown.duxbury.ma.us Fax: 781-934-6530 IRA!
Kimberly A. Sexton Counsel for the NRC Staff