ML081490553

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Pilgrim Watch Motion to Strike Incorrect and Misleading Testimony from the Record
ML081490553
Person / Time
Site: Pilgrim
Issue date: 05/15/2008
From: Lampert M
Pilgrim Watch
To:
Atomic Safety and Licensing Board Panel
SECY RAS
References
50-293-LR, RAS J-124
Download: ML081490553 (53)


Text

1YAS cJi/Oq DOCKETED USNRC.

May 15, 2008 1:04 pm OFFICE OF SECRETARY UNITED STATES OF AMERICA RULEMAKINGS AND ADJUDICATIONS STAFF NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the matter of Docket # 50-293 Entergy Corporation Pilgrim Nuclear Power Station License Renewal Application May 15,2008 PILGRIM WATCH MOTION TO STRIKE INCORRECT AND MISLEADING TESTIMONY FROM THE RECORD PRELIMINARY STATEMENT Pilgrim Watch submits this motion because some of the critical testimony presented by Entergy and NRC Staff at the April 10, 2008 Hearing 'regarding cured in place linings, coatings and cathodic protection/stray current interference was either inaccurate, incomplete or gave a misleading impression.' Because the following information could materially affect the decision of the Atomic Safety andLicensing Board (the "Board") in this proceeding, the Board either should strike the offending testimony from the record' and take account of the errors in testimony when evaluating the rest of Entergy's and NRC's testimony on the issue or reopen the hearing.

ARGUMENT I. The Board Should Strike Inaccurate and Misleading Testimony From the Record Regarding Cured-In-Place Liners (CIPP)

We all agree that the SSW Discharge rubber liner is not credited with a protective function.

Entergy's own disclosure [PILLRO0000855, Verification of PNPS License Renewal Project Report Rev.0,' (Draft G) 6/20/05 (3.1) Carbon Steel Components] says that "SSW system 1 Pilgrim Watch consulted with Entergy and NRC Staff regarding this Motion. They both oppose.

, 1

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includes carbon steel components (including cast iron), the majority of which are rubber lined.

For identifying aging effects the liner is not credited with a protective function, aging effects are identified for carbon steel in contact with salt water."

At the hearing, Entergy provided misleading and inaccurate statements that implied the cured-in place liner (CIPP) in Loop A and Loop B of the Salt Water Discharge were somehow different and' could be relied upon. However, Entergy failed to disclose specific and key facts about Pilgrim's CIP; instead Entergy's experts simply opined about CIP liners in general.They provided no useful, relevant or accurate site-specifip information.

Entergy could have provided relevant information; and in fact, they said that they did. Mr.

Lewis' stated at the hearing that "We disclosed every document that was relevant [Transcript 712, line 20]. However Entergy failed to produce a key document by the vendor that installed Pilgrim's SSW discharge CIP liners. The vendor's paper was presented to the North American Society for Trenchiess Technology (NASST). It described factual details, errors and lessons learned from that installation. 2 The document is attached, Exhibit 1.

It is difficult to imagine that Entergy did not consider engaging an expert who had experience with Pilgrim's CIP installation - such as Miller Pipeline Corp., the installer. Perhaps they did so and decided not to disclose that fact. Speculation aside, it is clear that the paper should be made part of the record because: Entergy failed to produce it, as they should have; information therein contradicts some of Entergy's statements; and last, and most important, it adds important information necessary for the Board to make a fair and reasoned decision. For example at the hearing, Judge Young asked Entergy "What is the material that the felt is made of?" Mr. Spataro, Entergy's expert, did not know; then guessed incorrectly; and said that Entergy would get back

[Transcript, at 687]. Pilgrim Watch provides the answers below.

2 Pilgrim NuclearPower Station: Salt Water DischargePiping Trenchless Rehabilitation Challenges,Jonathan Raymer, Miller Pipeline Corporation, Indianapolis, IN March 22-24, 2004, North American Society for Trenchless Technology (NASTT) No-Did 2004,http:i/www.nastt.org/store/technical papersPDF/364.pdf.

2

A. Entergy incorrectly stated that the entire piping was lined; when in fact the liner was not applied in an area near and inside the auxiliary building - approximately 10 feet 3

outside the building and an indeterminate footage inside the building.

In response to Judge Cole's question that, "This sock liner is placed in the entire length of the pipe on each of the two loops, correct?" Mr. Woods responded, "Yes" [Transcript 673, line 3].

However the vendor stated that an approximate 10 foot portion of the piping was not lined.

After removing a vault cover and piping spool located under the main reactor building, the upstream mouth of the pipe was accessed 8' blow grade, 6' off the bottom of the vault, and offset 10' horizontally under the building exiting the vault away from the building4 . [And]

In April 2001, PNPS developed a specification for lining Loop "A" and Loop "B" from the last flange connection at the Auxiliary Building piping vault to the end of the discharge pipe at the outfall. 5 What basis is there to assume that the unlined piping sections can do without added CIP protection, even assuming that the CIP is installed properly and provides requisite protection

.over a period of years?

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70 . If P.-* F-3 8 Figure 5 Top View of Vault not to scale: Discharge Piping, lower left; intake piping lower right; dotted line, path CIP liner; mid-horizontal line building marks building edge.

PW notes that this same factual inaccuracy is repeated by NRC Staff in the SER, 3-37, "Since then, the entire length of both SSW buried discharge loops have been lined internally with pipe linings cured in place - "B" Loop in 2001 and "A" Loop in 2003."

4 Ibid, at 1 5 Ibid, at 3; refer to diagram Figure 1, page 4 and Figure 5, page 8 3

B. Entergy failed to mention errors in field application of the CIP liner The vendor stated that "The construction of Loop B [earlier in 2001] provided the planning team with many lessons learned that allowed for an improved plan to be implemented for the construction of Loop A in April, 2003."

Specifically, "the liner in Loop B was allowed to reach excessive temperatures during the steam cure of the epoxy resin that caused noted concern at the plant, and the liner split upon cool down at each of the bends. Belzona and WEKO-Seals were utilized to repair these areas before putting the piping back into service..."

And, at 7, the vendor says that, Movement of the liner upon curing, cool down, and during variations in temperature during use was of noted concern. This movement is what was determined to have caused the cracks in the liner installed in Loop B in 2002.

,.Therefore from "lessons learned" from failures in Loop B, when Loop A was lined two years

.later changes were made. In Loop A: polyester resin was used instead of epoxy resin and hardener; heated water was used to cure instead of a steam cure; and, "a procedure was set to initiate cracks at each of the bends by cutting the liner to allow stress to be relieved and then

.initiate repairs at each crack" [at 3].

The two loops are not equivalent so that their performance and "life expectancy" cannot be assumed to be the same. The resins are dissimilar. This is important because installers say that "the resin is the pipe" - resin determines the new pipe's physical properties, corrosion resistance and ability to withstand effluent temperatures and other aggressive elements that are immediately introduced or introduced in future. Loop A has polyester resin and Loop B used epoxy resin.

There is no evidence that the resins are equivalent in thickness and durability; nor is there evidence that they are equally compatible with rubber - the CIP was placed over the rubber liner.

Because of errors in field installation, it cannot be assumed that: one inspection in 10 years is sufficient; neither can it be assumed that the liners, or the repairs made to the splits in Loop B's liner, are necessarily good for 35 years as claimed by the applicant at the hearing [Transcript at 4

681]. In the Vendor's own words, at 3, "[Pilgrim] had utilized trenchless technology with mixed results."

C. Rapid Completion Schedule required - increases the probability of error The vendor's document stated that, The project was scheduled to be completed during an April 2003 plant refueling outage, in which time was of the essence. Miller assembled a team to work a continuous 24-hour/day schedule to complete the work in the allotted time." [and] "...the refueling schedule dictates the amount of time allotted for inspection, maintenance, and construction activities taking place throughout the plant [at 1].

And, The schedule was set up for work to be performed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day until the work was i-i*'-*completed. The date for that SSW Service Line Loop 'A" was required to go back into service was May 2 nd allowing 315 hours0.00365 days <br />0.0875 hours <br />5.208333e-4 weeks <br />1.198575e-4 months <br /> for all construction to be completed [at 7].

The probability of worker error is increased if the task is challenging. The vendor specifically says that, "The challenges of this particular installation were plentiful. The site challenges included access to the pipe, bends in the pipe, and grade" [at 3]

.D. Steel pipe, not liner, structural component of the pipe Entergy's statements at the hearing are at best not comprehensible; however they attempt to leave the impression that the CIP liner has the structural integrity of a pipe so that if the carbon steel pipe corroded that it would not make much difference.

They state [Transcript at 677-8] that, MR. COX:-.... The cured-in-place pipe, we have been calling it cured-in-place pipe lining. The literature actually refers to that as a cured-in-place pipe. And it's actually analyzed to be able to stand the pressure loads and the loads from outside the hydraulic pressures of the water above it as if there was no outside pipe. It's actually a pipe within a pipe. It is rigid.

CHAIR YOUNG: So you are saying it is analyzed separately from the metal pipe. It's analyzed as a separate pipe that would need to withstand pressures. What sort of pressures are you talking about?

5

MR. COX: It is analyzed for the head of water above it and the -- because the pipe runs downhill, it actually draws a vacuum in parts of it. So it's analyzed to a negative 11 pounds per square inch from the outside, and it's analyzed to -- I can't remember the --

whatever the design pressure is from the inside. But it is -- I mean, it's not -- we credit both the metal and the pipe, but it does 7- the pipe does have its own separate analysis.

The cured-in-place pipe has a separate analysis. It says it can withstand the normal pressure loads acting within and from the outside.

However the vendor says a very different thing, It was assumed by the owner that the external soil, overburden, seismic, and live loads would not be considered due to the fact that the steel host pipe was confirmed to be intact and would continue to act as the structural component of the pipe. [At 7]

It is clear from this document, from the vendor's own words, that the steel pipe, and not the liner, is the structural component of the pipe. The liner is not ductile, nor earthquake proof. It is

'.designed to keep the water in the pipe under normal service, not to withstand ground movement.

It is metal and can/will corrode and crack.

E. Entergy did not provide any documentation demonstrating a warranty from the various vendors involved in installing the CIP liners; however they claim it has an approximate 35 year life.

From reading the vendors report, it is clear that there were "too many fingers in the pie" for any company to provide a warranty. As a result of so many parties - fingers can point all around with no one party responsible and thereby no real warranty. Parties involved include at least the owner; the resin supplier/advisor; the supplier of the "sock' or CIPP tube; the installer; and the 6

testing lab.

6 Vendor said that, "The owner assumed full responsibility for the preparation and verification of the design calculations for the cured-in-place installation" [at 6]; "It was during the design phase that the owner added a third party resin specialist to the project team to make recommendations that would allow the contractor to use polyester resin in the place of epoxy and still meet design requirements" [at 7];and "Samples of the liner were collected from the upstream and downstream mouth of the pipe from HDPE pipe sections that contained the CIPP just outside of the host pipe to produce a sample representative of the inside diameter of the host pipe. These samples were then sent off for physical property testing at a third party lab" [at 9].

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F. Testing - there is no indication that samples from patched areas and elbows were tested Samples of the liner were collected from the upstream and downstream mouth of the pipe from HDPE pipe sections that contained the CIPP just outside of the host pipe to produce a sample representative of the inside diameter of the host pipe. These samples were then sent off for physical property testing at a third party lab" [Vendor at 9].

G. Entergy ignored the fact that properly installed CIP liners simply protect from interior

.corrosion The real issue is corrosion from the exterior attacking the metal which forms the structural component of the pipe - the focus in this discussion. We know, from Entergy's own disclosures and the vendor's paper, that coatings can deteriorate in months and cannot be relied upon.

II. The Board Should Strike Inaccurate and Misleading Testimony From the Record Regarding Coatings Entergy incorrectly stated at the hearing that the coating and liners will prevent corrosion.

For example, Transcript at 591, That salt water service system is protected externally by coatings and wraps and it's protected internally by a cured in place epoxy liner. Similarly, the condensate storage system lines are stainless steel and even though stainless steel is resistant to corrosion, those are also externally wrapped to prevent corrosion from occurring. Despite those protective features which will prevent corrosion from occurring, we also have committed to the opportunistic and periodic inspections to insure that those coatings remain -intact and remain effective in preventing degradation from occurring.

We know from Entergy's own disclosures that they are fully aware that this is not so. Pilgrim Watch submitted an Exhibit at the hearing that stated, PILLRO0000658, Entergy: Aging Management Review of the SSW (Draft 11/12/01) 7

(3.1) "The piping that is underground is protected by a coating, but since the coating does not have a specified life, the aging effects will be evaluated for carbon steel." [Emphasis added].

The Draft was replaced by Entergy by the final version of the document and entered as Exhibit 70 [Transcript, page 745, line 14-16]. The Text was the same in both documents. Pilgrim Watch stated at the hearing that, "... to have the record show that Entergy had provided.. three other documents that say the same thing" [Transcript page 753, line 15-16].

III. The Board Should Strike Incorrect and Misleading Testimony From the Record Regarding Cathodic Protection (CP) tPilgrim Watch's contention said that the AMP should be supplemented by requiring cathodic

.protection for buried components in accordance with GALL XI, M28 Buried Piping and Tanks

ý`Guidance so as to protect public safety.

Dr. James Davis, NRC Staff expert, explained the reasons that he and NRC walked away from M28 (Transcript 769-772). His statements are inaccurate and misleading. We request that his comments regarding cathodic protection be removed from the record along with an incorrect statement made by Mr. Cox, Entergy's expert.

Pilgrim Watch sent the Transcript to experts in the field of cathodic protection. John Henry Fitzgerald, a leading expert in this field, provided a declaration and CV, Exhibit 2. His comments are based on nearly 45 years of experience in cathodic protection engineering for underground and marine structures; and it includes work at several electrical generating plants, three of which were nuclear powered, as well as refineries, chemical plants and lai'ge industrial manufacturing plants. Following Mr. Fitzgerald, Pilgrim Watch attached replies from other cathodic protection experts.

Dr. Davis and Mr. Cox's comments and Mr. Fitzgerald's testimony are grouped according to subject in the following table.

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Dr. James Davis- NRC Mr. John Fitzgerald- Pilgrim Watch Mr. Cox - Entergy Rectifiers Rectifiers Transcript, Page 769, lines 24 & 25, and Page Cathodic protection is something like a battery 770, line 1 in that there is a current flow from an anode to a cathode. The protective current does not 22-23 CHAIR YOUNG: Explain rectifiers really supply a DC charge to the pipe as stated before you go on. by Dr. Davis in line 25. There is, however, a flow of electrons from the rectifier (power 24-25 DR. DAVIS: It's a battery -- like a source) through connecting cables and bonds battery. It supplies a DC charge to the pipe (not through the soil) to the protected structure.

through buried pipe. These electrons then take part in electrochemical cathodic reactions on the surface of the protected structures.

In lay terms, it can be said that corrosion is caused by DC currents that flow from one point to another on a structure because of voltage differences that exist between these points; cathodic protection current overcomes these corrosion currents and stops corrosion.

In electrochemical terms, cathodic protection neutralizes the voltage differences on the structure, thus eliminating the corrosion currents.'

No cathodes involved, just anodes; probably There always is an anode and a cathode in need just one groundbed. all cathodic protection circuits; more than one groundbed would be necessary.

Transcript, Page 770 lines 1 & 2: The statement that there are no cathodes involved is incorrect. There always is an 3 -4 MR. COX: They are alternatives. It. Is anode and a cathode in all cathodic protection not a requirement that you have both. It says circuits; The anode that Dr., Davis refers to is either one is acceptable. a series of ground rods (called a groundbed) that introduce the DC current from the 1-2 an anode. There's. no cathodes involved, rectifier into the earth. The cathode of the It' s just anodes. And you probably only need circuit is all the protected underground one. structures to which the cathodic protection is connected. This is why it is called cathodic protection - the structures become the cathode and the rectifier groundbed is the anode. In an 9

Dr. James Davis- NRC Mr. John Fitzierald- Pilgrim Watch electrochemical circuit, the anode corrodes, the cathode does not.

I infer from the statement "That you probably only need one.".in line 2 that "one" refers to the anode (rectifier groundbed). Protecting all the underground structures in a large, complex facility like a generating plant, be it nuclear or fossil fuel, cannot be done from just one groundbed. There are various arrays of groundbeds that can be used, and but using only one groundbed will not work.

Cathodic protection and plating Cathodic protection is not a plating process Transcript, Page 770 lines 5-9: The statement in these lines about plating is wrong. Cathodic protection is not a plating 5 DR. DAVIS: Yes, - and what you're doing process. While the electrochemical process that 6 basically is you're setting up so you're like takes place in cathodic protection is similar to plating plating, it is not the same because plating 7 the pipe sothat iron cannot go into solution involves the deposition of metal on the cathode 8 thermodynamically. It can only plate, if surface. This does not occur with cathodic there's any protection. In plating, the metal to be plated 9 iron -- it's possible, but it would stop comes from metal ions (charged particles) in corrosion the electrolyte (bath) in which the object to be plated is placed. The metal to be plated does not come from the anode of the circuit.

Page 770, 7-9: The statements in these lines are confusing and do not make sense.

Cathodic protection does prevent the iron (or other metal) from going into solution, but that prevention occurs electrically, as explained above under Page 769, lines 24 & 25. It has nothing whatsoever to do with plating.

If the rectifierswent down, the reactor There is no reason to have to shut down the would have to be shut down. plant if the rectifier should go off.

Transcript Page 770, lines 10-14 Unless there is a NRC rule requiring this, there

10. Dr Davis: They were concerned that if they is no reason to have to shut down the plant if used a the rectifier should go off. If the cathodic 11 rectifier or put the rectifier in a safety- protection system is properly maintained, each related and rectifier will be inspected every month. If one 10

Dr. James Davis- NRC Mr. John Fitzgerald- Pilgrim Watch 12 it went down for some reason they would should be found to be out of operation, it will go into a not have been out for more than 30 days. Even 13 limited condition of operation and they if it took a week or more to get it back in would have to service, only minute if any corrosion will occur 14 shut down the plant because the rectifier in that length of time. There are cathodic failed. protection rectifiers in the three nuclear power station in which I have works and no one at any of those stations had any concerns about this.

Cathodic protection is used very extensively Cathodic protection is used very extensively; none of the operators are concerned if rectifier is out of service for a short time.

Transcript, Page 770, line 25-Page 771 line 4 Cathodic protection is indeed used in the 25 Dr. Davis: And I might also add that applications noted. None of these operators are cathodic protection is used concerned if a rectifier is out of service for a

,4: very extensively, particularly on cross- short time for the very same reasons cited in country the paragraph above.

2 pipelines, oil and gas, slurry, all different kinds.

.3 It's. fairly easy to apply cathodic protection in that 4 situation.

-Backfitting cathodic protection IS Backfitting cathodic protection is NOT dangerous on a nuclear power plant dangerous on a nuclear power plant Transcript, Page 771, lines 5-15 and Page 772, These statements are blatantly untrue. There is lines 1-3. nothing at all dangerous about installing 5 Dr. Davis:-To backfit cathodic protection on cathodic protection in complex facilities like a power stations. It simply requires proper 6 nuclear power plant is a very dangerous design to ensure effective protection. It is practice important to realize that, with the possible 7 because of something that we call stray exception of buried or submerged piping or current tanks unique to nuclear power, the 8 corrosion. What happens is you have a underground structures at a nuclear plant are complete no different from those at fossil fuel plants.

9 circuit from the rectifier sends the current to the The statements in this section concerning the 10 anode, the anode sends it to the pipe, and flow of current are also untrue. The current then it's does flow from therectifier to the groundbed 11 got to somehow return back to the rectifier. and thence to the underground v

structures. It 11

Dr. James Davis- NRC Mr. John Fitzgerald- Pilgrim Watch And it 12 likes to take the path of least resistance, so returns to the rectifier on the buried structures, if it not through the soil, and will not put holes in 13 sees another pipe in the area it will go to the piping. The piping (The cathode!) does that pipe need to be electrically continuous, however, as 14 and it will put a hole right through that pipe discussed immediately below.

in a 15 matter of weeks.

1 through the lead. So to backfit and use cathodic 2 protection is -- can be extremely dangerous.

You have 3 to be extremely careful when you do that.

Achieving electrical continuity among the Achieving electrical continuity among the plant piping IS necessary and extremely plant piping is necessary and NOT

.difficult in a nuclear plant extremely difficult in a nuclear plant Transcript Page 771, lines 16-25. This is basically true, although it is presented in a manner that not only gives the impression 16 Dr. Davis: And so what you have to do that achieving electrical continuity among the when you plant piping is extremely difficult, but that 17 originally design the cathodic protection cathodic protection is actually dangerous, as system, you erroneously stated on Page 771, line 6. In fact, 18 have to take all that into consideration. You the most difficult task when designing cathodic have to protection for complex facilities is achieving 19 know where every single pipe is on your electrical isolation of a piping or tank system facility and when such isolation is desired. There are so 20 then you haveto bond those together and many electrical grounds, piping that's interconnections and other contacts, that 21 extremely difficult to do - electrical continuity of the entire underground plant is essentially ensured. As mentioned in 22 CHAIR YOUNG: Bond what together? line 20, bonds (electrical cables or wiring from 23 DR. DAVIS" You have to have an electrical one structure to another) are sometimes needed 24 bond between the pipes so that the current to achieve electrical continuity among won't go structures. The term electrical continuity 25 through. the soil and cause corrosion. means simply that all the underground structures are connected together, through either piping interconnections or bond cables and wires.

Transcript Page 771, lines 23-25 & Page 772, Dr. Davis is partially correct in saying that line 1, bonding, that is, electrical continuity, is 23 DR. DAVIS: You have to have an electrical necessary. Line 24 & 25 are misleading Mr.

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Dr. James Davis- NRC John Fitzgerald- Pilgrim Watch 24 bond between the pipes so that the current because the protective current still flows won't go through the soil to the underground structures.

25 through. the soil and cause corrosion. It will What really happens here is that if the current go encounters an structure that is not electrically I through the lead. So to backfit and use continuous with the protection system, the cathodic current can flow along the discontinuous 2 protection is -- can be extremely dangerous structure and discharge back into the soil. At the point of discharge, corrosion will indeed occur; this is called stray current corrosion.

The strong impression that one gets from lines 16-25 is that achieving electrical continuity of underground structures in a complex facility is extremely difficult. It is not. What is difficult is trying to isolate specific structures from everything else in the plant.

In all my experience in generating stations, refineries, chemical and large industrial plants I have not found it difficult to achieve electrical continuity among the underground structures. I have found this to be especially true in the nuclear power stations where I have worked. If fact, in the nuclear facilities I have found everything to be connected to the plant grounding grid.

Chain link fencing is bonded to the posts which in turn are bonded to the grid. Metal doors in buildings are bonded to the buildings and thence to the grid. All this bonding makes retrofitting of cathodic protection economical and relatively easy to accomplish. Again, there is nothing dangerous about retrofitting cathodic protection to a facility like the Pilgrim plant.

Along these same lines, I have found in that in many of the generating plants, both nuclear and fossil fuel where I have worked, the cathodic protection rectifier is connected to the anode groundbed and also to the structural steel of the plant itself. The electrical continuity of the underground plant is so good that it often is not even necessary to excavate to tanks or piping to connect the rectifier to them.

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It is clear from Mr. Fitzgerald's declaration that Dr. Davis testimony was inaccurate or misleading. Backfitting cathodic protection is not dangerous; stray currents are a design issue, not a design constraint; backfitting is not difficult to install because reactors' electrical systems are typically all tied together. Therefore his testimony should be deleted from the transcript, along with Mr. Cox's statement, or a new hearing scheduled.

In addition, Pilgrim Watch suggests that the board perform a simple GOOGLE search for "cathodic protection;" "corrosion control engineering;" "retrofitting cathodic protection;" stray current specialists." It will turn up countless, instructive hits. For example: MATCOR, a major company, advertises that "MATCOR's certified cathodic protection specialists will provide testing procedures and acceptance criteria and resolution of stray current and interference problems thatyou may experience in your underground/waterfacilities." 7 [Emphasis added].

Last, Pilgrim Watch sent to the major CP corporations the Transcript and asked them specifically if cathodic protection could be retrofitted at nuclear power plants. Their responses are below and attached, Exhibit 3.

8 A.', Graham E.C. Bell, Schiff Associates From: Graham E.C. Bell [1]

Sent: Monday, May 05, 2008 11:43 AM To: 'Mary Lampert'

Subject:

RE: retrofitting cathodic protection at nuclear reactors - question You are correct. Stray current can be minimized by engineering and nuclear power plants are no different from other power or processing plants that have cathodic protection on plant piping.

7 http://www.matcoinc.com/cathodic protection.html 8 Dr. Bell's CV is available on line at http://schiffassociates.net/pdf/GECB-CV-06.pdf. PROFESSIONAL REGISTRATIONS AND CERTIFICATIONS: Professional Engineer - State of California - Corrosion -

1994;Professional Engineer - State of Tennessee - Mechanical - 1993,Professional Engineer - State of Nevada -

Mechanical - 1996;Professional Engineer - State of Arizona - Mechanical - 1998;NACE International Certificated Cathodic Protection Specialist - 1996;NACE International Certificated Corrosion Specialist P - 1996.

EDUCATION: Doctor of Philosophy (1988);Nuclear Engineering; Mechanical, Aerospace and Nuclear Engineering Department; University of California, Los Angeles. Master of Science (1983) Engineering Chemical, Nuclear and Thermal Engineering, Department University of California, Los Angeles. Bachelor of Science, Magna cum Laude (198 1)Engineering School of Engineering and Applied Science University of California, Los Angeles 14

Several nuclear power plants on the west coast have cathodic protection systems on plant piping (Palo Verde and San Onofre).

You might be interested to know that there is cathodic protection on the majority of the nuclear waste transfer lines at Hanford Nuclear site in eastern Washington state.

The other way to protect is through redundancy so that if safety systems are needed, they have a back-up which takes over if corrosion or some other malfunction occurs.

Hope this helps.

Graham E.C. Bell, Ph.D., P.E., Schiff Associates 431 W Baseline Road -Claremont, CA 91711 Email: gbell(Tschiffassociates.com;Web: www.schiffassociates.com B. William P. Carlson -President, Cathodic Protection Management, Inc.

From: billcpm007(@aol.com To: mary.lampertcomcast.net

Subject:

Re: FW: retrofitting CP at nuclear reactors - question Mary:

Congratulations, you understand the issues and not the smoke and mirrors.

Many, if not all power plants were fitted with cathodic protection as part of the original construction. Since cathodic protection components are consumed in the process of protecting structures, by the shear nature of the process plants are constantly retrofitted or upgraded as required. The cathodic protection installed at local nuclear plants owned by Exelon are constantly monitored and the cathodic protection upgraded.

Stray currents can and do cause corrosion only if they are not identified and the proper measures taken to insure that they do not cause premature failure.

Hope this helps and if you have any questions, feel free to contact me.

William P. Carlson President, Cathodic Protection Management, Inc.

email billc(acorrosionspecialists.com 15

C. Larry Brandon, President CorPreTek, Inc.

From: Larry Brandon [2]

Sent: Monday, May 05, 2008 3:45 PM To: Mary Lampert Mary, Whether nuclear, gas or coal fired, many power plants across the country have cathodic protection systems.

Certainly some of those systems were installed at the time of the building of the plant, but many are newer installations.

We just installed a retrofit system in Indiana two years ago, a system in Michigan three years ago, and are currently bidding a project to add CP in Ohio, at a nuclear plant.

It is true that impressed current cathodic protection can cause stray current. Many systems that are designed and/or installed improperly. can cause damage.

,The key is to have any system designed and installed by qualified and certified personnel in that line of work.

If you would like to pursue this further, I would be happy to explore. the feasibility of adding CP

  • tothe Pilgrim Plant. My credentials have been included for your review.
  • Thanks in advance, Larry Brandon, President CorPreTek, Inc.

An NRC ADAMS search shows other. nuclear reactors have installed cathodic protection including, for example, HB Robinson, Unit 2; Catawba Nuclear Stations; Hope Creek Generating Station; Wolf Creek; Susquehanna. Because "the typical design life of a CP system ranges from 15-30 years so every nuclear facility with CP installed during initial construction should have or should need replacement of their CP systems since initial commissioning" [Ted Huck, VP MATCOR, Exhibit 3]. Therefore reactors with CP have already retrofitted CP or will do so in the future.

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CONCLUSION For the forgoing reasons, it is clear that the steel pipe, not the liner or coating, is the structural component of the pipe; and neither the liner nor coating are ductile or earthquake proof. The liner is there to keep water inside under normal service, as long as it maintains its integrity. It is not there to withstand abnormal circumstances. The real issue is corrosion from the exterior. The steel pipe itself must be protected, maintained and properly inspected to protect against corrosion.

The ASLB should grant Pilgrim Watch's Motion to Strike. In the alternative, the board should use its discretion to reopen the record and hear further testimony on the cured-in-place lining, coating and cathodic protection issues.

'Respectfully submitted, Mary Lampert Pilgrim Watch, pro se 148 Washington Street Duxbury, MA 02332 17

EXHIBITS

1. Pilgrim Nuclear Power Station: Salt Water DischargePiping Trenchless Rehabilitation Challenges, Jonathan Raymer, Miller Pipeline Corporation, Indianapolis, IN March 22-24, 2004, North American Society for Trenchless Technology (NASTT) No-Did 2004
2. John H. Fitzgerald III, P.E., Retrofitting Cathodic Protectionat Pilgrim Station and CV
3. Cathodic Protection, Email Correspondence: Graham E.C. Bell, Ph D.,P.E., Schiff Associates; William Carlson, Cathodic Protection management Inc., President; Larry Brandon, CorPre Tek, President; Ted Huck, MATCOR, Vice President 18

EXHIBIT 1 Pilgrim Watch, Exhibit 1 [Docket No. 50-293-LR]

North American Society for Trenchless Technology (NASTT)

NO-DIG 2004 New Orleans, Louisiana March 22-24, 2004 PILGRIM NUCLEAR POWER STATION: SALT SERVICE WATER DISCHARGE PIPING TRENCHLESS REHABILITATION CHALLENGES Jonathan Raymer Miller Pipeline Corporation, Indianapolis, IN ABSTRACT: Miller Pipeline Corporation, an international gas and utility construction company with over 50 years of experience, was contracted by Entergy's Pilgrim Nuclear Power Station to rehabilitate 240' of 22" nominal diameter standard weight carbon steel piping with an existing 3/16" natural rubber lining.

The subject piping contained three 45-degree elbows, one 90-degree long radius elbow, and an elevation change of over 22 feet. Other site conditions further complicated this installation. After removing a vault cover and piping spool located under the main reactor building, the upstream mouth of the pipe was accessed 8' below grade, 6' off the bottom of the vault, and offset 10' horizontally under the building exiting the vault away from the building. This piping configuration required that the liner be turned a total of 270-degrees before entering the mouth of the pipe. The submerged downstream outlet of the pipe presented other unique access challenges. Prior to lining the pipe, Miller personnel visually inspected the pipe and any sections of the existing natural rubber lining that displayed damage were removed and the thickness of the host pipe was determined using an ultrasonic measurement device.

The project was scheduled to be completed during an April 2003 plant refueling outage, in which time was of the essence. Miller assembled a team to work a continuous 24 hour/day schedule to complete the work in the allotted time. The project was completed on time and within budget.

INTRODUCTION Entergy's Pilgrim Nuclear Power Station (PNPS) has the ongoing challenge and responsibility of securing and maintaining a state of the art power production facility. Their team of in house engineers and technicians constantly monitor the facility in order to design solutions to maintain ideal operating conditions and allow for growth and improvement where it is determined necessary. The fact that this facility produces energy using nuclear fuel makes this responsibility ever more critical. Homeland security and public health are of the utmost importance and take priority over all other operations at this and other nuclear power plants. In addition to security concerns, it is important that the plant provide uninterrupted service except during certain planned activities. This important responsibility was brought to the forefront of intemational news during the power outages that took place in the northeastern United States in the latter days of August, 2003. Non-emergency construction activity is typically completed during refuel outages to minimize the amount of time that the station is not producing electricity. For this reason the refueling schedule dictates the amount of time allotted for inspection, maintenance, and construction activities taking place throughout the plant.

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Pilgrim Nuclear Power Station falls under the authority of the U.S. Nuclear Regulatory Commission (NRC)1 , which maintains a constant presence at the plant. The NRC is an independent agency established by the Energy Reorganization Act of 1974 to regulate civilian use of nuclear materials. The plant maintains a Nuclear Quality Assurance program in accordance with Appendix B to Part 50 of Title 10 of the Federal Regulations. It is from this program that the subject work was discovered and designed for construction. The subject *project inspection, design, materials, installation, testing, and documentation were performed and accepted under this program.

The project studied in this paper consisted of the installation of a cured-in-place pipe liner in Loop "A" of the Salt Service Water(SSW) Piping at PNPS. The installation of the pipe required extensive preparation work consisting of construction activities performed by multiple trades to support this task. The power station had utilized trenchless technology in the past with mixed results. There was a clear challenge going into the work that was addressed by the project team with thorough planning and teamwork.

Given the history and location of the project, it was essential that this work be completed on time and as planned.

CURED IN PLACE PIPE - WHAT IS IT?

Cured in Place Pipe is made up of a resin-impregnated tube engineered from non-woven polyester needle-punch material which is specifically designed for bonding with chemical resistant resin systems.

The needle-punch materials inner surface is coated with a clear geo-membrane that allows for the resin

  • Vý to be encapsulated within the felt layers to ensure non-contamination of the resin. Various different resin

. selections are available including polyesters, vinylesters and epoxies, all of which are formulated by several manufacturers throughout the world. CIPP is most commonly specified and tested in accordance with ASTM F-1216 3, ASTM D638 4, ASTM D7905 and other relevant standards applicable to the installation of CIPP in wastewater, storm water, and industrial systems.

The lining process is accomplished by either inverting or pulling the tube into the host pipe made of virtually any material. Almost always, CIPP is installed from one manhole or access structure to another so the process is completely trenchless which significantly reduces surface congestion and is generally less expensive compared to typical open cut methods. Each installation method has its specific application depending on a variety of circumstances. Once the resin impregnated tube has been fully

  • installed, it is cured by circulating hot water or steam inside the liner. During the cure process, the tube is held tightly against the host pipe by internal pressure. After the tube has cured into a monolithic structure, any laterals are reopened robotically or by man-entry depending on the size of the liner. The finished product molds to the host pipe and leakage at pipe joints and cracks are eliminated. Due to the smooth interior surface of the liner, flow in the line is often enhanced.

HISTORY The Salt Service Water Discharge piping was originally designed and built using 22" nominal diameter standard weight carbon steel pipe (0.375" wall thickness). Flange connections in the piping are rubber lined Pressure Class 150ýflat-faced slip-on flanges. This piping was initially protected using a 3/16" thick natural rubber lining to prevent deterioration due to corrosion from the constant flow of aerated salt water.

The discharge piping has been routinely inspected and spot repairs in the pipe have been made using weld overlays and Belzona 1311 Ceramic R-Metal epoxy compound. In 1999, new 40 ft pipe spools were installed in pipe vaults next to and under the Auxiliary Building. The replacement spools were

'Learn more about the U.S. Nuclear Regulatory Commission at www.nrc.gov 2 IOCFR50 Appendix B: www.nrc.gov/reading-rrrndoc-collections/cfr/partO5O/partO5O-appb.html

' ASTM F1216 "Practice for Rehabilitation of Existing Pipelines and Conduits by the Inversion and Curing of Resin-Impregnated Tube" 4ASTM D638 "Standard Test Methods for Tensile Properties of Plastics" ASTM D790 "Standard Test Methods for Flexural Properties of Unreinforced and Reinforced Plastics and Electrical Insulation Materials" Paper F-3 2

constructed of 22" nominal diameter standard weight carbon steel pipe coated with Duromar EAC-FE epoxy with a minimum 1/32" thickness, and included elastomeric internal joint seals commercially know as WEKO-SEALS that acted as expansion seals on both end flange joints of the replacement spool.

In April 2001, PNPS developed a specification for lining Loop "A" and Loop "B" from the last flange connection at the Auxiliary Building piping vault to the end of the discharge pipe at the outfall. The Loop "A"discharge piping is 240 ft with three 45-degree elbows and one 90-degree long radius elbow. The Loop "B" discharge piping is approximately 225 ft with four 45-degree elbows and one 90-degree long radius elbow.

Construction was completed on Loop "B" during the refuel outage in 2002. Loop "A" was to be completed during the same refuel outage, but was postponed for one year due to unexpected delays.

These delays were later attributed to decisions to use an onsite wet-out, the decision to use epoxy resin and hardener, and using a steam cure as opposed to heated water. Althoughthese are proven methods and solutions throughout the industry they were not the right fit for this application. The liner in Loop "B" was allowed to reach excessive temperatures during the steam cure of the epoxy resin that caused noted concern in the plant, and the liner split upon cool down at each of the bends. Belzonaw and WEKO-SEALS@ were utilized to repair these areas before putting the piping back into service, but a goal was set for the installation in Loop "A" to eliminate the cracks at the bends in the pipe. A procedure was set up for the forthcoming lining of "Loop A" to initiate cracks at each of the bends by cutting the liner to allow stress totbe relieved and then initiating repairs at each crack. It was important to the owner that they have the opportunity to repair any cracks that might form while the piping was out of service instead of having to repair it at an unexpected time. The design team for Loop. "A" saw this as an unnecessary step and it was later agreed to cut and observe the liner at the first 45-degree bend and then determine if there was a need to repeat this procedure at each of the remaining bends. The resin selection and curing procedures were to be carefully considered to determine movement of the liner within the host pipe during installation, cure, cool down, and operation in order to accurately predict the characteristics of the liner.

The construction on Loop "B" provided the planning team with many lessons learned that allowed for an improved plan to be implemented for the construction of Loop "A" in April, 2003.

THE CHALLENGE The challenges of this particular installation were plentiful. The site specific challenges included access to the pipe, bends in the pipe, and grade. Figure 1 is the "As Built" drawings of Loop "A" as provided by PNPS. This drawing illustrates the multiple bends and grade associated with the -piping. Material challenges included determining felt thickness, resin type, cure schedule, and cool down schedule.

Other challenges were present due to the fact this installation was in a facility regulated by the NRC.

Some examples of these challenges included disposal of cure water, security clearance for the construction team and equipment, and nuclear specific safety training for the construction team.

Access to both the upstream and downstream openings provided unique challenges. The dotted line to the lower right corner of Figure 1 represents the 40' spool that was removed to provide an opening into.

the pipe to begin the lining. Figure 2 shows an isometric view of the access vault at the upstream mouth of the pipe. Figure 3 is a photograph showing the alignment of the pipes in the vault. The pipe to the right in Figure 3 is the discharge pipe for Loop "A" and the opening is immediately out of the picture to the right. To begin inversion of the liner in the pipe required turning the material 90-degrees vertically to access the vault under the building and then turning 180-degrees degrees horizontally to enter into the pipe with limited room to make the turns within the vault. The liner would need to be routed over the pipe on the left of Figure 3 to reach the staging from where this picture was taken. The client did not consider it an option to cut the pipe near the wall of the vault to allow for the liner to make a single 90-degree turn into the pipe. Access to the downstream mouth of the pipe was equally challenging.

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Loop "A" - Route of Piping Figure 1. As Built Drawing of Loop "A" Edge of Bu din .......

Bottom ofVault Figure 2. Isometric Vault View: not to scale.

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+-;Figure3. Vault Access at Upstream: view from staging inside vault.

';-';'The downstream mouth of the pipe was set in a discharge channel that exited to the Cape Cod Bay.

  • t!Depending on tide conditions the downstream mouth of the pipe remains approximately six to ten feet below sea level. A cofferdam was constructed to be fastened to the walls of the discharge channel. This was installed by divers and dewatered and maintained by sump pumps in the invert of the cofferdam.

Staging was built into the top of the cofferdam to allow for personnel to access the mouth of the pipe for inspection and construction. Sand bags were utilized in the invert of the dam to provide a surface level with the mouth of the pipe.

Figure 4 shows two cofferdams and associated staging prior to installation in the discharge channel. The cofferdams were constructed out of steel and were fastened to the walls using a series- of bolts that secured a rubber gasket keeping the water out of the work space. When each dam was installed it allowed for a work space of four feet square at the mouth of the pipe.

IDENTIFICATION It had been determined through annual inspections of Loop "A"that it was in need of repair. A procedure was developed to inspect the piping prior to installation of the liner using man entry that included utilizing a hand held camera system to record the findings of the inspection. Areas of the rubber coating that were bubbled or missing would be cut out and inspected using an ultrasonic measurement device to determine the thickness of the carbon steel host pipe. Weld overlays were to be used to repair the pipe prior to lining to assure the full original thickness of the host pipe prior to lining. Since Loop "A" could not be taken offline for inspection prior to mobilization for lining, it was determined to complete this work immediately before the installation of the cured-in-place liner.

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i i , ij ..j~ .;. I

-ý.F igure 4. Cofferdams and Staging: prior to placement by divers.

SPECIFICATION AND DESIGN

,The owner assumed full responsibility for the preparation and verification of the design calculations for the cured-in-place installation6 . The minimum required thickness was determined by taking the larger of the 1:external load or internal pressure analysis. The design thickness was then increased by 10% to allow for t*variations in the material during manufacturing and installation. A Factor of Safety of 2 was used in L;design calculations. External design calculations were based on Partially Deteriorated Gravity Pipe

.Condition. The vacuum that is formed in the pipe during usage was accounted for in the design by

  • xconverting the vacuum (negative) pressure to an external hydrostatic pressure and adding this to the

";gravity pipe design. The internal pressure analysis was designed based on the Fully Deteriorated Pressure Pipe Condition since the host pipes structural properties would not be a factor that would influence the pressures exerted on the cured-in-place liner internally. The design used the long-term flexural strength and tensile strength equal to one-third of the rated short-term strength listed in Table 1.

Table 1. Short Term Design Values.

Rated Short-Term Value (PSI)

Physical Property Flexural Modulus = 300,000 Flexural Strength = 4,000 Tensile Strength. = 4,000 The Maximum External Differential Pressure of 25 ft w.g. shown in Table 2 was based on the highest negative operating pressure for the discharge piping plus an accounting for groundwater pressure acting 6 Harizi, P.D. (2003). PNPS Specification for CIPP Lining for SSW Discharge Piping Paper F-3 6

externally. It was assumed by the owner that external soil, overburden, seismic, and live loads would not be considered due to the fact that the steel host pipe was confirmed to be intact and would continue to act as the structural component of the pipe.

Table 2. Design Loadings.

Design Parameter Design Value Maximum Internal Pressure/Temperature = 30 PSIG @ 100oFahrenheit Minimum Operating Temperature = 300 Fahrenheit Maximum External Differential Pressure (Minimum Internal Pressure) = 25 ft w.g. (-11 PSIG Internal)

It was during the design phase that the owner added a third party resin specialist to the project team to make recommendations that would allow the contractor to use polyester resin in place of epoxy and still meet the design requirements. Movement of the liner upon curing, cool down, and during variations of temperature during use was of noted concern. This movement is what was determined to have caused

<;the cracks in the liner installed in Loop "B"in 2002.

'The design for the liner in Loop "A" called for a minimum liner thickness of 1-1/2" and a diameter of 20.875".

MANUFACTURING WET OUT AND DELIVERY It was determined that Vipel L704-AAP-12, an isophthalic polyester resin would be used as the resin component of the cured-in-place pipe. The catalyst was specified as Perkadox 16 and Trigonox C. The felt tube was custom manufactured using nonwoven needle-punched polyester felt coated on one side by

-a polyurethane coating.

It was determined by the design and planning team that an offsite wet out would be utilized to limit space consumption onsite, allow for greater quality control, and reduce unnecessary risks in sensitive areas.

The owner assembled an inspection team as part of the Quality Assurance program that traveled to the manufacturing and wet-out facility. The team spent several days performing quality assurance inspections and reports to confirm that the materials conformed to specifications. Material source confirmation, shelf life verification, and temperature and control monitoring were vital parts of the inspection.

The wet out liner was loaded on a refrigerated truck, packed in ice for redundant cooling, and transported to a holding area near the site one day prior to installation.

PREPARATION AND INSTALLATION The schedule was dictated by the own!er and corresponded with other activities associated with the refuel outage. The contractor was allowed access to the site starting on April 21't. Access authorization, radiation protection, medical and psychological testing were completed in a separate trip prior to mobilizing for construction. However, last minute security clearance and training was completed as tradesmen began preparations to provide access to the pipe. The schedule was set up for work to be performed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day until the work was complete. The date that SSW Service Line Loop "A" was

.required to go back into service was May 2 nd allowing 315 hours0.00365 days <br />0.0875 hours <br />5.208333e-4 weeks <br />1.198575e-4 months <br /> for all construction to be completed..

The preparation which included opening the vault, removing pipe spools, erecting the staging, and installing the cofferdam were completed by tradesmen with direction from the planning and construction Paper F-3 7

team. Personnel from the construction team began the inspection of the pipe following the preparations.

Safety concerns were jointly addressed with representatives of PNPS and the contractor.

The inspection followed preparation activity and revealed some areas where the rubber coating had bubbled and required removal. These areas were tested for appropriate thickness in the host pipe using an ultrasonic measurement device, which showed the host pipe did not require weld overlay repairs to reach minimum thickness as specified. The owner had determined that the rubber coating would not be repaired since the liner wo'uld serve the purpose of protecting the host pipe from the flow of aerated salt water. The inspection personnel made a video tape for review by the design team above ground prior to installation.

Figure 5 is a top view showing the orientation of the pipes in the vault and the turns that were required once the liner entered the pit. The liner was required to turn 90-degrees vertically and 180-degrees horizontally to reach the mouth of the pipe. This was accomplished using a ramp into the pit, walls attached to the staging, and ropes to direct the liner to the mouth of the pipe.

The installation head pressure was carefully monitored during this installation. The decision was made to install the liner without the use of a pull rope, which can be installed in a liner prior to wet out and assists in the inversion process of a liner. The turn rope was initially considered for this installation due to the turns, but because of the diameter it was determined to be unnecessary. Generally as liners increase in diameter, the amount of pressure to make them invert decreases given that the thickness remains the same. The thickness of a liner limits how much pressure the liner can withstand before there is a chance ofithe felt or a seam separating. Figures are specified by felt manufacturers by testing and historical installation data for ideal installation head, minimum inversion head, maximum cold head, and maximum hot head. These figures are used as a guideline for successful installation and curing. The liner was contained in a cap fabricated from high density polyethylene pipe. This assured that the exposed areas of the liner at the downstream mouth of pipe would remain intact during curing.

. .. . .... I...-.-.-.-.--.. . . . '.'.'.'. . .

. . . . i... . . .

... IPafr .. .. o Cured in Place Uner 1 ,........

  • ' ' ' ' ' ' ',I ' ' I ". . . . . . . .

" ' . . .' 1I. ' ' ' ' '. --'-'.". .. '.'...-'.'.'-

.~~ .... . . .... ...

Building Edge VaultUnder Building I

.,rounu Eevation 7IiIi Figure 5. Top View of Vault: not to scale.

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The liner navigated the 270-degrees prior to entering the pipe and then moved through the 225-degrees inside of the host pipe by utilizing a slug of water in the pipe used to make the turns. Radio contact was maintained at the upstream and downstream access points to control the rate of inversion and assuring the liner was properly contained in the cap fabricated for containing the liner at the downstream mouth of the pipe.

The water was immediately heated using a diesel fired water heater following the successful inversion.

The cure schedule was specified by the resin consultant and temperatures were monitored throughout the processing of cured in place pipe using thermocouple wires and temperature measurement devices.

The temperatures were monitored and recorded at the upstream mouth of the pipe, downstream mouth of the pipe, at piping entering the water heater, and at piping exiting the water heater. A water temperature of 180-degrees was targeted throughout the cure. Following the cure, the water in the liner was allowed to circulate to assist in cooling the water and liner prior to removing the cure water. A length of flexible hose was set up to as part of the piping system to act in conjunction with cool water to remove heat from the cure water. PNPS had made the decision to capture, transport, and treat the cure water at an offsite facility so it was essential to minimize the amount of water used during the cool down process. The cure water was recovered upon cutting the downstream end of the liner in the cofferdam. This was successfully completed by using a tanker fitted with pumps to collect the water.

The ends were cut on the liner providing access for a man entry cut at the first 45-degree bend to test for separation. The cut at the bend was observed over a two hour period and no additional separation occurred. The results of observing the initial cut gave the confidence to the client that the liner would.not expand or contract causing any additional cracks at bends. The existing cut was repaired using Belzona and a WEKO-SEAL.

The final inspection revealed that the cured in place pipe liner fit tight to the interior surface of the host pipe: The tight fit was maintained through the long radius of the bends, and wrinkling at the interior bends was minimal. These favorable results can be attributed to the controlled inversion pressure and rate of inversion.

TESTING Samples of the liner were collected from the upstream and downstream mouth of the pipe from HDPE pipe sections that contained the CIPP just outside of the host pipe to produce a sample representative of the inside diameter of the host pipe.. These samples were then sent off for physical property testing at a third party lab. The testing procedure was specified as part of the quality assurance program at PNPS and in conjunction with ASTM standards. The results of the testing were used to confirm compliance with physical property specifications.

COST SAVINGS Excavation alternative costs to this trenchless repair are difficult to calculate due to the specific usage of the host pipe. The construction would have been difficult to complete during a refuel outage, and could have resulted in lost production for the facility that exceeds one million dollars per day. In addition, the disruption of the construction site would have hindered other construction activities taking place at the plant.

CONCLUSION Entergy's Pilgrim Nuclear Power Stations engineering team successfully defined their needs and assembled a project team capable of completing the work in a safe and predicable manner. Challenges were identified early in the design phase and were addressed in detail during project planning..

Teamwork, thorough preparation, and organized execution of the plan proved to be essential in completing this work on time and as planned.

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REFERENCES ASTM F1216 (1998). "Practice for Rehabilitation of Existing Pipelines and Conduits by the Inversion and Curing of Resin-Impregnated Tube", American Society for Testing and Materials.

ASTM D638 (1998). "Standard Test Methods for Tensile Properties of Plastics", American Society for Testing and Materials.

ASTM D790 (1998). "Standard Test Methods for Flexural Properties of Unreinforced and Reinforced Plastics and Electrical Insulation Materials", American Society for Testing and Materials.

Harizi, P.D. (2003). "PNPS Specification for Cured-In-Place (CIPP) Lining for SSW Discharge Piping",

M-624, March MPC (2003). "CIPP", http://www.millerpipeline.com/cipp.html NRC 10CFR50 Appendix B (2003). httpl//www.nrc.gov/reading-rm/doc-collections/cfr/partO5O/partO5O-appb.html Paper F-3 10

EXHIBIT 2 Pilgrim Watch, Exhibit 2 [Docket No. 50-293-LR]

Jon M Fig ld EMI, P.E.

1350 Berkshire Grasse Pointe Park, Michigan 48230 Tel: 313-640-9424 Fax: 313-640-9419 May 12, 2008 MS. Mary Lampert 148 Washington Street Duxbury, Massachusetts 02332

Subject:

Retrofitting Cathodic Protection at Pilgrim Nuclear Power Station Dear Ms. Lampert Thank you for sending me the dom ntation cerning the proposed retrofitting of cathodic protection at Pilgrim Nuclear Power Station. I appreciate receiving the information.

This is my response to the points brought forward by Dr. James Davis concerning retrofitting cathodic protection in the transcript [ASLBP Numnber: 50-293-LR, April 10, 2008]. My comments are based on forty nine years of experience in cathodic protection engineering for underground and marine structures. My experience includes work at several electrical generating plants, three of which were nuclear powered, as well as refineries, chemical plants and large industrial manufalcturing plants My resume including applicable experience is attached as TabA.-

Pane 769. lines 24 & 25. and Page 770. line 1: Cathodic protection is something like a battery in that there is a current flow from an anode to a cathode. The protective current does not really supply a DC charge to the pipe as stated by Dr. Davis in line 25. There is, however, a flow of electrons fiom the rectifier (power source) through connecting cables and bonds (not through the soil) to the protected structr. These electrons then take part in electrochemical cathodic reactions on the surface of the protected structures.

In lay terms, it can be said that corrosion is caused by DC currents that flow from one point to another on a structure because of voltage differences that exist between these points; cathodic protection current overcomes these corrosion currents and stops corrosion. In electrochemical terms, cathodic protection neutralizes the voltage differences on the structure, thus eliinating the corrosion currents.

Page 770 lines 1 & 2: The statement that there are no cathodes involved is incorrect. There always is an anode and a cathodic in all cathodic protection circuits. The anode that Dr., Davis refers to is a series of ground rods (called a groundbed) that introduce the DC current from the rectifier into the earth. The cathode of the circuit is all the protected underground structures to which the cathodic protection is connected. This is why it is called cathodic protection - the structures become the cathode and the rectifier groundbed is the anode. In an electrochemical circuit, the anode corrodesý the cathode does not.

I infer from the statement "That you probably only need one." in line 2 that "one" refers to the anode (rectifier groundbed). Protecting all the underground structures in a large, complex facility like a generating plant, be it nuclear or fossil fuel, cannot be done from just one groundbed. There are various arrays of groundbeds that can be used, and but using only one groundbed will not work.

Page 770. lines 5 & 6: The statement in these lines about plating is wrong. Cathodic protection is not a plating process. While the electrochemical process that takes place in cathodic protection is similar to plating, it is not the same because plating involves the deposition of metal on the cathode surface. This does not occur with cathodic protection. In plating, the metal to be plated comes from metal ions (charged particles) in the electrolyte (bath) in which the object to be plated is placed. The metal to be plated does not come from the anode of the circuit.

Page 770, 7-9: The statements in these lines are confusing and do not make sense. Cathodic protection does prevent the iron (or other metal) from going into solution, but that prevention occurs electrically, as explained above under Page 769, lines 24 & 25. It has nothing whatsoever to do with plating.

Page 770, lines 10-14: Unless there is a NRC rule requiring this, there is no reason to have to shut down the plant if the rectifier should go off. If the cathodic protection system is properly maintained, each rectifier will be inspected every month. If one should be found to be out of operation, it will not have been out for more than 30 days. Even if it took a week or more to get it back in service, only minute if any corrosion will occur in that length of time. There are cathodic protection rectifiers in the three nuclear power station in which I have worked and no one at any of those stations had any concerns about this.

Page 770, line 25-Page 771 line 4. Cathodic protection is indeed used in the applications noted.

None of these operators are concerned if a rectifier is out of service for a short time for the very same reasons cited in the paragraph above.

Page 771, lines 5-15 and Page 772, lines 1-3. These statements are blatantly untrue. There is nothing at all dangerous about installing cathodic protection in complex facilities like power stations: It simply requires proper design to ensure effective protection. It is important to realize that, with the possible exception of buried or submerged piping or tanks unique to nuclear power, the underground structures at a nuclear plant are no different from those at fossil fuel plants.

The statements in this section concerning the flow of current are also untrue. The current does flow from the rectifier to the groundbed and thence to the underground structures. It returns to the rectifier on the buried structures, not through the soil, and will not put holes in the piping.

The piping (The cathode!) does need to be electrically continuous, however, as discussed immediately below.

Page 771, lines 16-25. This is basically true, although it is presented in a manner that not only gives the impression that achieving electrical continuity among the plant piping is extremely difficult, but that cathodic protection is actually dangerous, as erroneously stated on Page 771, 2

line 6. In fact, the most difficult task when designing cathodic protection for complex facilities is achieving electrical isolation of a piping or tank system when such isolation is desired. There are so many electrical grounds, piping interconnections and other contacts, that electrical continuity of the entire underground plant is essentially ensured. As mentioned in line 20, bonds (electrical cables or wiring from one structure to another) are sometimes needed to achieve electrical continuity among structures. The term electrical continuity simply means that all the underground structures are connected together, through either piping interconnections or bond cables and wires. In lines 23-25 & Page 772, line 1, Dr. Davis is partially correct in saying that bonding, that is, electrical continuity, is necessary. Line 24 & 25 are misleading, however, because the protective current still flows through the soil to the underground structures. What really happens here is that if the current encounters a structure that is not electrically continuous with the protection system, the current can flow along that structure and discharge back into the soil. At the point of discharge, corrosion will indeed occur; this is called stray current corrosion.

The strong impression that one gets from lines 16-25 is that achieving electrical continuity of underground structures in a complex facility is extremely difficult. It is not. What is difficult is trying to isolate specific structures from everything else in the plant. In addition, if the electrical continuity is in question, tests can easily be made to locate any non-continuous structures.

In all my experience in generating stations, refineries, chemical and large industrial plants I have not found it difficult to achieve electrical continuity among the underground structures. I have found this to be especially true in the nuclear power stations where I have worked. If fact, in the nuclear facilities I have found everything to be connected to the plant grounding grid. Chain link fencing is bonded to the posts which in turn are bonded to the grid. Metal doors in buildings are bonded to the buildings and thence to the grid. All this bonding makes retrofitting of cathodic protection economical and relatively easy to accomplish. Again, there is nothing dangerous about retrofitting cathodic protection to a facility like the Pilgrim plant.

Along these same lines, I have found in that in some of the generating plants, both nuclear and fossil fuel where I have worked, the cathodic protection rectifier is connected to the structural steel of the plant itself as well as to the anode groundbed. The electrical continuity of the underground plant is so good that it often is not even necessary to excavate to tanks or piping to connect the rectifier to them.

If you have any questions or would like additional information, please call.

Thank you for this opportunity to be of service to you.

My best regards.

Sincepe_

  • -Johan H. Fitzgem Ed,FNAC 6IENACE CertfdCroi A Specialst 16 NACE Certified Corrosion Specialist # 166 3

TABA John H. Fitzgerald I1I, P.E.

Resume 6/55 Graduated from Yale University School of Engineering 9/55-12/55 Junior Engineer, Columbia Gas System, Columbus Ohio 1/56-7/58 US Air Force pilot training and subsequent helicopter pilot service 9/58-12/63 Engineer, Columbia Gas of Ohio, Columbus, Ohio. Began cathodic protection work 3/59.

1/64-4/00 Corrpro (and predecessors) Company, Detroit, Michigan. Surveys, investigations, design, commissioning and inspections of cathodic protection, development and presentation of training programs. Extensive work also in areas other than underground structures.

5/00-present Consultant for Corrpro Company. Technical Editor Materials Performance Magazine for NACE International (National Association of Corrosion Engineers)

Instructor for Gas Technology Institute, Chicago, in gas distribution and transmission piping.

Professional Activities Registered Professional Engineer.

NACE Certified Corrosion Specialist.

Instructor at Appalachian, Purdue University, Omaha, Minneapolis and several other corrosion short courses.

2006 recipient of NACE International T.J. Hull Award for excellence in publications Fellow of NACE International Author of about 60 publications on corrosion control, mostly involving cathodic protection of underground structures President of NACE International 1990-1991 Experience related to the Pilgrim Nuclear Power Station Nuclear Plants Dresden Nuclear Generating Station, Commonwealth Edison Co., Morris, IL - Evaluation of existing plant wide cathodic protection for underground structures and design of system rehabilitation.

Fort Collins Nuclear Power Station Nebraska Public Power Co, Fort Collins, NE Evaluation of existing plant wide cathodic protection for underground structures and preparation of recommendations for system repairs and rehabilitation.

Palisades Nuclear Power Station, Consumers Energy, Inc., South Haven, MI - Evaluation of plant wide cathodic protection for underground structures and water inlet and outlet structures and preparation of recommendations for repairs and upgrading.

Fossil Fuel Plants Lansing Generating Station, Board of Water and Light, Lansing, MI - Evaluation of existing plant wide cathodic protection for underground structures and design of new system to replace the inoperative existing one.

Springfield Generating Station, Illinois Power Company, Springfield, IL - Same scope of as at Palisades.

Meramec Power Plant, Union Electric Co., Arnold, MO - Commissioning of rehabilitated Plant wide cathodic protection for underground structures.

Refineries Wood River Manufacturing Complex, Shell Oil Co., St. Louis, MO - Design of cathodic protection for underground pipelines and barge off loading facility.

Cape Girardeau Refinery. Shell Oil Co., Cape Girardeau, MO - Annual inspection of facility wide cathodic protection for underground structures and preparation of recommendations for continued maintenance.

RESUME OF JOHN H. FITZGERALD III, P.E.

Graduated from Yale University School of Engineering June, 1955 Summer/55 Summer Stock Theater, Assistant Technical Director, Sharon Playhouse - Sharon, Connecticut 9/55-12/55 Junior Engineer, Columbia Gas System Service Corporation, Columbus, Ohio. 'Preliminary training in gas engineering, mostly in compressor section.

1/56-7/58 USAF. Pilot training and subsequent service as helicopter pilot with 54th Air Rescue Service, Goose Bay, Labrador.

8/58 Married Beverly Byrne, New York, Childhood Sweetheart.

9/58-3/59 Junior Engineer, Columbia Gas System Service Corporation. General experience training in various phases of gas engineering.

4/59 - 12/60 Worked in corrosion laboratory, Columbia Gas System Service Corporation. Prepared coating samples for testing, conducted tests on samples, assisted in cathodic protection for operating companies of Columbia Gas. Gained further understanding of corrosion engineering.

1/61-12/63 Corrosion Engineer for Central District, Ohio Fuel Gas Company, Columbus, Ohio. Responsible for setting up and operating corrosion control program for gas distribution system. Considerable involvement in cathodic protection engineering, interference testing and routine surveys. Trained and supervised corrosion technicians.

1/64 - 12/65 Project Manager, Hinchman Company. Responsible for consulting engineering work involving surveys, design and field engineering on a wide variety of projects. Specialized in cathodic protection and investigation of corrosion problems on underground structures.

1/66-12/73 Vice President, Hinchman Company. Continued responsibilities in consulting corrosion engineering. Project manager for work on the Washington, D.C. transit system. Expanded experience into several fields of corrosion. Transitioned in marketing responsibilities late in 1968. Developed additional marketing techniques to assist in company expansion.

1/74-12/75 responsibilityVice Executive President, Hinchman Company. Continued for marketing and further responsibility for company management. Continued active participation in technical work and engineering supervision.

................ n.-. , ,*,r'A Te-. 1l1-64(-Q*0424 Fnx: 313-640-9419

2 1/76 - 12/87 President, Hinchman Company. Responsible for all phases of company operation. Directly active in marketing, certain phases of the actual consulting work and in engineering supervision.

1/98 - 12/94 Vice President, PSG Corrosion Engineering - Corrpro Companies.

Responsible for company operation; regularly engaged in active corrosion engineering.

1/95 - 4/00 Principal Engineer, Corrpro Companies. Engaged in active corrosion engineering 5/00 - Present Consultant, Corrpro Companies. Engaged in active corrosion engineering.

Professional Activities Registered Professional Engineer.

Accredited by NACE as a Corrosion Specialist.

President National Association of Corrosion Engineers (NACE) 1990 Member of Michighn Society of Professional Engineers Held all the chairs of the Appalachian Underground Corrosion Short Course and was General Chairman in 1976. Prior to that served as Basic Course Chairman. Subsequently served as Intermediate Course and Curriculum Chairman.

Lecturer at Appalachian Underground Corrosion Short Course (1960 to Present), Purdue Corrosion Short Course (1965 to Present), USAF Civil Engineering School (1963 to 1990) and Institute of Gas Technology (1969 to Present).

Spoken at many technical and professional society meetings, notable American Gas Association, American Water Works Association, NACE, Consulting Engineering Council and American District Heating Association.

Recipient of Citation of Recognition for Outstanding Contribution to NACE, 1976.

Recipient of CoL George C. Cox Award, 1978.

Other Interesting Facts Hobbies Model railroading, model aircraft construction, sailing.

Activities Ordained Deacon, Episcopal Church Square Dance Caller Community Theatre participation Member. Mystic Seaport (Connecticut)

Advanced Pilot, United States Power' Squadron - Active in educational program in Grosse Pointe Power Squadron

3 Experience related to the Rigrm Nuclear Power Station Nuclear Plants Dresden Nuclear Generating Station Commonwealth Edison Co., Morris, IL - Evaluation of existing plant wide cathodic protetion for underground structures and design of system rehabilitation.

Fort Collins Nuclear Power a n Nebraska Public Power Co, Fort Collins, NE Evaluation of existing plant wide cathodic protection for underground structures and preparation of recommendations for system repairs and rehabilihttion.

PalisadesNuclear Power Station.Cn ers Bnerarv. Inc., South Haven, MI - Evaluation of plant wide cathodic protection for underground structures and water inlet and outlet structures and preparation of recommendations for repair and upgrading.

FossilFuelPlants Lansing Generating Station Board of Water and Light, Lansing, MI - Evaluation of existing plant wide cathodic protection for underground structures and design of new system to replace the inoperative existing one.

Sprinaield Generating Station Illinois Power Company, Springfield, IL - Same scope of as at Palisades Meramec Power Plant Union Electric Co., Arnold, MO - Commissioning of rehabilitated Plant wide cathodic protection for underground strucnues.

Refineries Wood River Manuacgtrina Complex. Shell Oil Co., St Louis, MO - Design of cathodic protection for underground pipelines and barge off loading facility.

Cae Girardeau ery. Shell Oil Co, Cape Giradeau, MO - Annual inspection of facility wide cathodic protection for underground structures and preparation of recommendations for continued maintenance.

Additional Cathodic Protection Experience Extensive experience with gas company corrosion control going back to 1961. Served as Central District Corrosion Engineer for Columbia Gas of Ohio (formerly Ohio Fuel Gas Company); responsible for establishing and operating corrosion control program for distribution piping throughout the district. As part of this work designed cathodic.

protection for two, 20-inch bare inter-station mains as well as both coated and bare distribution piping.

Over the years, served several gas companies in evaluating corrosion control programs, designing cathodic protection, performing field investigations, solving interference problems, testing cathodic protection and providing training for corrosion control personnel.

In 1975, reviewed the corrosion control program for Southeast Michigan Gas Company, evaluated the effectiveness of the program and presented the economic and safety benefits of the program to management. Over the ensuing five years designed cathodic protection for several transmission lines and oversaw its installation and testing.

Beginning about 1970, designed and performed annual inspections of cathodic protection for distribution and transmission piping, and storage field piping and well casings for Indiana Gas Company. Continued in responsible charge of this program until about 1995. In 1992, led a team of eight engineers in an audit program of the company's corrosion control reviewing work orders to determine if the records reflected what had actually been installed. In 1995, performed an independent audit of the company's program, assessing corrosion control standard procedures, drawing's and instrumentation.

In 1985, assisted East Ohio Gas Company with an evaluation of their cathodic protection program for bare gas distnibution piping.

In 1990, undertook an analysis of corrosion leak records of bare cast iron distribution mains for Peoples Gas Company in Chicago. This led to recommendations for phased replacements. From 1996 to 1999, provided engineering services for stay current mitigation due to the rail transit system on several high pressure 24" - 42" inter-station mains in Chicago and designed and tested several strategically placed cathodic protection installations for these mains. Also performed alternating current mitigation studies for two transmission lines in Commonwealth Edison rights of way.

Since 1968, provided expert testimony on eight cases in behalf of various gas companies.

Two of these involved showing that alleged stay voltage problems on farms were not due to nearby cathodic protection on distribution pipe, but rather to poor grounding on the farms themselves. Has also testifies before the Federal Energy Regulatory Commission in behalf of Columbia Gas.

PUBLICATIONS Corrosion as a Primary Cause of Cast Iron Main Breaks AWLA,*

Journal August 1968 Corrosion"Problems in URD, Electrical South, July 1969-Visual Corrosion Training Aids, Pipeline News Proceedings of AGA Distribution Conference, 1964 What Can the Small Gas Company Do to Establish a Cor osion Control Program?, PipelineNews. Proceedings of AGA Distribution Conference, 1970 Problems Involved in Implementing Cathodic ProteciQrn in Large Cities, Pipeline News- Proceedings of AGA Distribution Conference, 1970 Corrosion Problems Associated with Rapid Transit Systems (Co-Author L I-L West, PE.) Procdings of AGA Distribution Conference, 1968 Demonstration of the Theory of Cathodic Protection Proceedings of the Fifth (1960) through Twenty-First (1976) Annual Appalachian Underground Corrosion Short Course Methods and Instrumentation for Underground Corrosion Testing, Proceedings of the Ilberty Bell Corrosion Short Course, 1968 and 1969 Practical Approach to Counteracting Corrosion of Bridge Structures (Co-Author R.P. Brown) !blic ~ rb, November 1971 Cathodic Protection of Miscellaneous Underground Structures, Proceedings of the Seventeenth (1972) through Twenty-First (1976)

Annual Appalachian Underground Corrosion Short Course Experience and Case Histories with Corrosion and Cathodic Protection of Buried Utilities, Proceedings of the International District Heating Association, 1972 Suggested Criteria for Cathodic Protection in Gas Distribution Systems, Proceedings of AGA Distribution Confereuce, 1973 Fundamentals of Galvanic Corrosion, Proceedings of the Eighteenth (1973) through Twenty-First (1976) Annual Appalachian Underground Corrosion Short Course Design Criteria of Underground Heat and Chijled. Water Distribution Systems for Corrosion Protection (Co-Author KJ. Moody)

Proceedings of NBS-BRI-ASHRAE Symposium, 1973 Corrosion Control for Buried Piping, Heating. Piping. Air Condi March 1974

7 Sidebar Information on Cathodic Protection, CM lBW~ine March 1974 Fundamentals of Underground Corrosion: Setting Up a Program -

Mechanisms of Corrosion - Methods of Control (Co-Author A.L.

Claes) Plant Engineering. June 1975, September 1975, November 1975, February 1976 Corrosion Control for Buried Service Station Tanks, Paper Presented at 1975 National Meeting of National Association of Corrosion Engineers Cathodic Protection Performance May 1972of Stationary Marine Structures, Materials How Good Plant Construction Inspection Facilitates Corrosion Control, Proceedings of Liberty Bell Short Course, 1975 Corrosion Control for Concrete Pipe, Proceedings of Liberty Bell Short Course, 1976 Cathodic Protection for Wharf Foundation Piles at the Port of Anchorage, Alaska; (Co-Author J. Wagner, PRE.) Presented at 1979 National Meeting of National Associaton of Corrosion Engineers Corrosion Control for Foundation Piles (Co-Author A-L Claes, P.E.)

Proceedings of the EILETALK, Seminar 1978 Corrosion Control Guidelines for D.C. Operated Rapid Transit stems. Proceedings of the 24th Appalachian Underground UorrosionShort Course, 1979 Fundamentals of Corrosion, Proceedings of the 25th Appalachian Underground Corrosion Short Course, 1980 Stray Ear Current Control, Washington D.C. Metro System (Co-Author R.E. Shaffer, PE.) Presented at 1980 National Meeting of the National Association of Corrosion Engineers M o What Causes Underground Corrosion and How Can It be Prevented?,

Proceedings of the 25th Appalachian Underground Corrosion Short Course, 1980 Corrosion Control for Underground Structures, Pumbi Engneer, December 1980 URD Concentric Neutral Corrosion and its Control (Co-Author J.

Wagner) Proceedings of- the 25th Appalachian Underground Corrosion Short Course, 1980 Cathodic Protection of Underground Hydraulic Cylinders, Annual Conference, National Association of Corrosion Engineers, 1982

CORRPRO COMPANWA [NC 9

Evaluating Cafthc Protection on the Exterior Bottoms of Two Asphalt Storage Tanks Using Corrosion Rate Measurement Probes, Paper Presented at Corrosion 98 Buiding Stray Current Control into the Rehabilitation of an Old Transit Yard and Shop in a Large Urban Area, Papr sen at Corrosion Cathodic Protection Monitoring, Installation and Leak Detection Under Fxisting Above Ground Storage Tanks, Materials Protection. October 1999 Designing Cathodic Protection for 2000 Mides of a Eigh Pressure Gas Transmission Line Using Computer Aided Technology, AMaterials Perfvruwnce, June 2000 Using Visual Training Aids in Teaching Cathodic inrference Mitigto, Paper presented at Corrosion 2001, Houston, Texas Using the lOOrm drop Cathodic Protection CrIterion in Industrial and Similar Environments, Paper psented At Corrosion 200 1, EHon, Texas Preparing gas Distribution Piping for the Construction of a Light Rail Transit System MaterialsPotton. June 2002 Cathodic Protection Design for 1900 Miles of Natural Gas Pipeline, Materials Performance,August 2001, Co-authored with Lome Carlson & David Webster Preparing Gas Distribution Piping Stray Current Control Prior to Construction of a New Light Rail Transit System, MaterialsPerformance, June 2003, Co-authored with Joel Beggs, Stray Current Testing on Gas Distribution Piping After Start Up of a New Light Rail Rapid Transit System, Materials Performane, June 2005. Co-authored with Joel Beggs Troubleshooting Cathodic Protection, MaterialsPerformance,February 2006 Failure to Follow Corrosion Control Recommendations Leads to Structure Failures,MaterialsPerformance,March 2007 Graphitization Leads to Long Cast iron Pipe Life, Materials Performance, May 2007

EXHIBIT 3 Pilgrim Watch, Exhibit 3 [Docket No. 50-293-LR]

Mary Lampert From: Graham E.C. Bell [gbell@schiffassociates.com]

Sent: Monday, May 05, 2008 11:43 AM To: 'Mary Lampert!

Subject:

RE: retrofitting cathodic protection at nuclear reactors - question You are correct. Stray current can be minimized by engineering and nuclear power plants are no different from other power or processing plants that have cathodic protection on plant piping. Several nuclear power plants on the west coast have cathodic protection systems on plant piping (Palo Verde and San Onofre).

You might be interested to know that there is cathodic protection on the majority of the nuclear waste transfer lines at Hanford Nuclear site in eastern Washington state.

The other way to protect is through redundancy so that if safety systems are needed, they have a back-up which takes over if corrosion or some other malfunction occurs.

Hope this helps.

Graham E.C. Bell, Ph.D., P.E.

Schiff Associates 431 W Baseline Road Claremont, CA 91711 Cell: 909-841-6729 Ph: 909.626-0967 Fx 909.626.3316 Email: .bell(,schiffassociates.com; Web: www.schiffassociates.com Statement of Confidentiality: This message and any attachments may contain confidential information. It is solely for the use of the intended recipient. If you are not an intended recipient, you are hereby notified that you received this email in error. The Information may also be confidential and/or legally privileged. Any use, review, disclosure, reproduction, distribution, copying of, or reliance on, this email and any attachment is strictly prohibited. If you are not the Intended recipient, please immediately notify the sender by reply email and delete this message and any-attachments. Thank you for your cooperation. Email is covered by the Electronic Communications Privacy Act, 18 USC SS 2510-2521 and is legally privileged.

From: Mary Lampert [3]

Sent: Monday, May 05, 2008 8:16 AM To: gbell@schiffassodates.com

Subject:

retrofitting cathodic protection at nuclear reactors - question Hello:

I direct an unfunded public interest group in Massachusetts. We are intervening in the license extension application of the Pilgrim Nuclear Power Station; located on the shores of Cape Cod Bay. Our focus is on buried safety-related piping; and we are asking that the aging management program be supplemented to include various measures - a base line inspection; more frequent inspections than once in ten years of an unspecified sample; and retrofitting cathodic protection.

The licensee and NRC Staff oppose our motion.

Atthe hearing, NRC Staffs expert stated that " To backfit cathodic protection on a nuclear power plant is a very dangerous practice because of something we call stray current corrosion."

From our reading stray currents are an issue but not something that cannot be dealt with by a CP designer.

if you have the time, we would appreciate your comment on this and whether you know what nuclear reactors have retrofitted cathodic protection.

1

Thank-you for your time, Mary Lampert Duxbury MA 781-934-0389 2

Mary Lampert From: billcpm007@aol.com Sent: Monday, May 05, 2008 3:22 PM To: mary.lampert@comcast.net

Subject:

Re: FW: retrofitting CP at nuclear reactors - question Mary:

Congratulations, you understand the issues and not the smoke and mirrors.

Many, if not all power plants were fitted with cathodic protection as part of the original construction.

Since cathodic protection components are consumed in the process of protecting structures, by the shear nature of the process plants are constantly retrofitted or upgraded as required. The cathodic protection installed at local nuclear plants owned by Exelon are constantly monitored and the cathodic protection upgraded.

Stray currents can and do cause corrosion only if they are not identified and the proper measures taken to insure that they do not cause premature failure.

Hope this helps and if you have any questions, feel free to contact me.

William P. Carlson President Cathodic Protection Management, Inc.

email billc@corrosionspecialists.com Phone 630.313.5784 Fax 630.313.5788 Cell 224.588.6760 Mary Lampert [mailto:mary.lampertLcomcast.net1 Sent: Monday, May 05, 2008 10:42 AM To: Info

Subject:

retrofitting CP at nuclear reactors - question Hello:

I noted that your website lists nuclear reactors.

I direct an unfunded public interest group in Massachusetts. We are intervening in the license extension application of the Pilgrim Nuclear Power Station; located on the shores of Cape Cod Bay. Our focus is on buried safety-related piping; and we are asking that the aging management program be supplemented to include various measures - a base line inspection; more frequent inspections than once in ten years of an unspecified sample; and retrofitting cathodic protection.

I

The licensee and NRC Staff oppose our motion.

At the hearing, NRC Staff's expert stated that "To backfit cathodic protection on a nuclear power plant is a very dangerous practice because of something we call stray current corrosion."

From our reading stray currents is an issue; but not something that cannot be dealt with by a CP specialist.

If you have the time, we would appreciate your comment on this and whether you know what nuclear reactors have retrofitted cathodic protection.

Thank-you for your time, Mary Lampert Duxbury MA 781-934-0389 Wondering What's for Dinner Tonight? Get new twists on family favorites at AOL Food.

2

Mary Lampert From: Larry Brandon [larrybrandon@cmsinter.net]

Sent: Monday, May 05, 2008 3:45 PM To: Mary Lampert

Subject:

stray currents -question Attachments: CorPreTek Credentials 2007.pdf

Mary, Whether nuclear, gas or coal fired, many power plants across the country have cathodic protection systems.

Certainly some of those systems were installed at the time of the building of the plant, but many are newer installations.

We just installed a retrofitsystem in Indiana two years ago, a system in Michigan three years ago, and are currently bidding a project to add CP in Ohio, at a nuclear plant.

It is true that impressed current cathodic protection can cause stray current. Many systems that are designed and/or installed improperly can cause damage..

The key is to have any system designed and installed by qualified and certified personnel in that line of work.

If you would like to pursue this further, I would be happy to explore the feasibility of adding CP to the Pilgrim Plant, My credentials have6been included for your review.

Thanks in advance, Larry Brandon President CorPreTek, Inc.

Original Message -----

To: larrybrandon(Dcmsinter.net Sent: Monday, May 05, 2008 11:22 AM

Subject:

stray currents -question Hello:

I direct an unfunded public interest group in Massachusetts. We are intervening in the license extension application of the Pilgrim Nuclear Power Station; located on the shores of Cape Cod Bay. Our focus is on buried safety-related piping; and we are asking that the aging management program be supplemented to include various measures - a base line inspection; more frequent inspections than once in ten years of an unspecified sample; and retrofitting cathodic protection.

The licensee and NRC Staff oppose our motion.

At the hearing, NRC Staffs expert stated that "To backfit-cathodic protection on a nuclear power plant is a very dangerous practice because of something we call stray current corrosion."

From our reading stray currents is an issue; but not something that cannot be dealt with by a CP specialist.

If you have the time, we would appreciate your comment on this~and whether you know what nuclear reactors have retrofitted cathodic protection.

' 1

Thank-you for your time, Mary Lampert Duxbury MA 781-934-0389 2

41 Mary Lampert From: Ted Huck [thuck@matcor.com]

Sent: Monday, May 05, 2008 2:41 PM To: Mary Lampert

Subject:

RE: Power Article We bid on a project for PPL Susquehanna NPS several years ago to replace their CP system as it had fully depleted.

Corrpro won that project. Other than that we have not done very much with Nuclear facilities. Typical design life of a CP system ranges from 15-30 years so every nuclear facility with CP installed during initial construction should have or should need replacement of their CP systems since initial commissioning. Whether or not this has been done I cannot say.

Ted From: Mary Lampert [4]

Sent: Monday, May 05, 2008 10:28 AM To: Ted Huck

Subject:

RE: Power Article Ted:

I just finished your article in November 2005 Materials Performance Designing Cathodic Protectionfor Power Plant Applications.

Has MATCOR retrofitted any nuclear plants; and if so which ones and approximate date. And, by any chance do you know if CORRPRO has?

i., know, for example, that Robinson, Catawba and Hope Creek NPS have CP but no information of where and when installed.

The issue here that I am concerned with is retrofitting buried piping and tanks specifically in nuclear reactors.

I understand, but have no facts, that it actually may be easier at a nuclear reactor because the electric system is all tied together for electric grounding - when everything is not electrically connected more difficult but doable.

Thanks, Mary From: Ted Huck [5]

Sent: Friday, April 18, 2008 11:19 AM To: mary.lampert@comcast.net

Subject:

Power Article Mary It was a pleasure talking to you today. Please feel free to pass along my contact information as you see fit. Our company is very engaged in the application of Cathodic Protection in Power plants. The attached link takes you to my most recent article on the subject for Natural gas fired powered plants.

http://www.powermag.com/ArchivedArticleDisplay.aspx?V=2008&m=Februarv&a=51-F GPS.xml 1

A~ A I've also attached some articles that I've published.

Best Regards, MMATCOR No 5,1oionipw in enwa~orn potk, TED HUCK Vice President, Sales & Marketing c 267.251.7608 e thuck(amatcor.com HEADQUARTERS/ EAST COAST 301 Airport Boulevard, Doylestown, PA 18902 USA 215.348.2974 or 800.523.6692 f 215.348.2699

  • www.matcor.com 2

, 9ý q

DOCKETED USNRC May 15, 2008 1:04 pm UNITED STATES OF AMERICA OFFICE OF SECRETARY RULEMAKINGS AND NUCLEAR REGULATORY COMMISSION ADJUDICATIONS STAFF BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the matter of Docket # 50-293-LR Entergy Corporation Pilgrim Nuclear Power Station License Renewal Application May 15, 2008 CERTIFICATE OF SERVICE I hereby certify that the following was served May 15, 2008 by electronic mail and by U.S. Mail, First Class to the Service List: Pilgrim Watch Motion to Strike Incorrect and Misleading Testimony from the Record Administrative Judge Secretary of the Commission Ann Marshall Young, Chair Attn: Rulemakings and Adjudications Atomic Safety and Licensing Board Staff Mail Stop - T-3 F23 Mail Stop 0-16 C I

.United States Nuclear Regulatory US NRC Washington, DC 20555-0001 Commission [Two Copies]

Administrative Judge Office of Commission Appellate Paul B. Abramson Adjudication Atomic Safety and Licensing Board Mail Stop 0-16 Cl Mail Stop T-3 F23 United States Nuclear Regulatory US NRC Commission Washington, DC 20555-0001 Washington, DC 20555-0001 Administrative Judge Atomic Safety and Licensing Board Richard F. Cole Mail Stop T-3 F23 Atomic Safety and Licensing Board United States Nuclear Regulatory Mail Stop -T-3-F23 Commission US NRC Washington, DC 20555-0001 Washington, DC 20555-0001

A4 1, ý Susan .L. Uttal, Esq. Town of Plymouth MA James Adler, Esq. Duane Morris, LLP David Roth, Esq. 505 9 th Street, N.W. 1000 Office of General Counsel Washington D.C. 20004-2166 Mail Stop-O-15 D21 United States Nuclear Regulatory Richard R. MacDonald Commission Town Manager, Town of Duxbury Washington, DC 20555-0001 878 Tremont Street Duxbury, MA 02332 Paul A. Gaukler, Esq.

David R. Lewis, Esq. Fire Chief & Director DEMA, Pillsbury, Winthrop, Shaw, Pittman, Town of Duxbury LLP 688 Tremont Street 2300 N Street, N.W. P.O. Box 2824 Washington, DC 20037-1138 Duxbury, MA 02331 Mr. Mark Sylvia Town Manager, Town of Plymouth 11 Lincoln Street Plymouth MA 02360 Mary Lampert Pilgrim Watch, pro se 148 Washington St.

Duxbury, MA 023332 Sheila Slocum Hollis, Esq.

2