ML111140004
| ML111140004 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 04/24/2011 |
| From: | Lampert M Pilgrim Watch |
| To: | Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| References | |
| RAS 20021, 50-293-LR, ASLBP 06-848-02-LR | |
| Download: ML111140004 (5) | |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of Docket # 50-293-LR Entergy Corporation Pilgrim Nuclear Power Station License Renewal Application April 24, 2011 PILGRIM WATCH RESPONSE TO ENTERGYS APRIL 22, 2011 FILING REGARDING PROVEN TESTS TO DETECT CABLE INSULATION DEGRADATION Pilgrim Watch responds to Entergys Objection to Pilgrim Watchs Post-Hearing Memoranda filed April 22, 2011. Pilgrim Watchs memoranda referred to and provided a link to an archived video recording of Entergys presentations to the Massachusetts Joint Committees on the safety of the nuclear reactors that directly impact the Commonwealth.
Pilgrim Watch correctly stated that Pilgrims Director of Nuclear Safety Assurance, Mr.
Bethay, statements supports that there are no proven commercially available tests for cable insulation degradation currently available, contrary to what Entergys experts said in testimony and at the March 9, 2001 hearing in Plymouth1. Contrary to Entergys April 22, 2011 Response, 1
Declaration Of Vincent Fallacara And Roger B. Rucker In Support Of Entergys Answer Opposing Pilgrim Watchs Request For Hearing On A New Contention (Feb 14, 2011) Vincent Fallacara, Director of Engineering at Pilgrim, said in regard to the sufficiency of cable insulation test methods: 12. Mr. Blanch challenges the adequacy of the cable insulation test methods called for by the AMP. He contends that there is no proven test that will provide assurance that cables and splices that have been submerged will function when called upon. He claims to rely on findings from the NRC, the Electric Power Research Institute (EPRI),
Sandia National Laboratory (Sandia), and Brookhaven National Laboratory (Brookhaven). Blanch Affidavit ¶¶ 29, 32-35, 45-46. 13. These claims by Pilgrim Watch and Mr. Blanch are incorrectthere are many proven tests to determine the degradation of cable insulation from different aging mechanisms.
Emphasis added.
At the March 9, 2011 hearing, Mr. Lewis said that licensees should do these type of tests that are capable of detecting degradation (Transcript, pg., 881, lines 21-22, emphasis added), clearly implying that there were tests capable of detecting degradation.
the presentation by Mr. Bethay, Director Nuclear Safety Assurance, Pilgrim, does not in fact support[] the existence of a test capable of detecting cable insulation degradation. (Entergy Response, pg. 2)
The facts speak for themselves. Entergys panel presentation begins at 146.20 on the video2; the pertinent section on cable testing runs from 173-180. The following starts at 178 on the tape. Representative Anne Gobi asked what actual testing was there to make sure there was not cable degradation. Mr. Bethay responded:
We dont think we have had a lot that have been submerged for an extended period of time in the first place. So were talking about medium, fairly high voltage cables, that stay in the water, not that rains on them occasionally or that its in the damp air.
The concern is those medium voltage cables that are under water and theyre not designed to stay under water forever, so just to be clear on what the issue really is.
So, if we can see it, if we can verify that there is water or not, and we can remove it accordingly, thats one aspect of the program.
There is another electrical test called the Megger test that tests the insulation capabilities, but that only kinda tells you whats its condition right now, not necessarily a good predictor.
Theres a new testing comes out, and I may have to ask for some help on this, that is more predictive than being able to say whats the condition of insulation of the cable and do you anticipate a future failure.
Thats a technology that is evolving, and there are new types of testing developed to be more predictive and identify whats the longer term effects of this - so were active in the industry and trying to keep up with those efforts to develop better testing, figure out what, how we would implement that when it comes along, but right now we want to not let the cables stay under water.
There are no proven tests today. Mr. Bethay spoke of the future - Theres a new testing comes out [t]hats a technology thats evolving. As for the present, he concluded that right now we want to not let the cables stay under water.
The lead editorial in todays (April 24, 2011) Boston Globe was largely focused on Entergys promises to Vermont, but its concluding sentence was directed to Pilgrim:
Permission to run a nuclear plant is a public trust. Vowing to run Pilgrim safely, the company has applied for federal permission to keep it open for another 20 years. But as the Nuclear Regulatory Commission reviews the companys application, it should keep in mind what promises from Entergy are worth.
Respectfully submitted, Electronically signed Mary Lampert Piglrim Watch, pro se 148 Washington Street Duxbury, MA 02332 Tel. 781-934-0389 Mary.lampert@comcast.net 3
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of Docket # 50-293-LR Entergy Corporation Pilgrim Nuclear Power Station License Renewal Application April 24, 2011 CERTIFICATE OF SERVICE I hereby certify that Pilgrim Watch Response To Entergys April 22, 2011 Filing Regarding Proven Tests To Detect Cable Insulation Degradation was served April 24, 2011 in the above captioned proceeding to the following persons by the Electronic Information Exchange and that complimentary copies provided via email to the service list Secretary of the Commission Office of Commission Appellate Attn: Rulemakings and Adjudications Adjudication Staff Mail Stop 0-16 C1 Mail Stop 0-16 C1 US NRC Washington, DC 20555-0001 United States Nuclear Regulatory Commission Administrative Judge Washington, DC 20555-0001 Ann Marshall Young, Chair Atomic Safety and Licensing Board Atomic Safety and Licensing Board Mail Stop - T-3 F23 Mail Stop T-3 F23 US NRC Washington, DC 20555-0001 United States Nuclear Regulatory Commission Administrative Judge Washington, DC 20555-0001 Paul B. Abramson Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Mail Stop T-3 F23 Office of Commission Appellate US NRC.Washington, DC 20555-0001 Adjudication Mail Stop: 0-16C1 Administrative Judge Washington, DC 20555-0001 Richard F. Cole Atomic Safety and Licensing Board Mail Stop -T-3-F23 US NRC, Washington, DC 20555-0001
U.S. Nuclear Regulatory Commission Mark Stankiewicz Office of General Counsel Town Manager, Town of Plymouth Mail Stop: 0-15 D21 11 Lincoln Street Washington DC 20555-0001 Plymouth MA 02360 Susan L. Uttal, Esq.
Andrea Jones, Esq. Sheila Slocum Hollis, Esq.
Brian Harris, Esq. Town of Plymouth MA Michael Dreher, Esq. Duane Morris, LLP Brian Newell, Paralegal 505 9th Street, N.W. 1000 Washington D.C. 20004-2166 U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Richard R. MacDonald Mail Stop: 011-F1 Town Manager, Town of Duxbury Washington, DC 20555-0001 878 Tremont Street Duxbury, MA 02332 Lisa Regner, Project Mgr. Plant Lic.
Branch 1-1, Operator Reactor Licensing Fire Chief & Director DEMA, Washington, DC 20555-0001 Town of Duxbury 688 Tremont Street Paul A. Gaukler, Esq. P.O. Box 2824 David R. Lewis, Esq. Duxbury, MA 02331 Jason B. Parker, Esq.
Pillsbury, Winthrop, Shaw, Pittman, LLP - Terence A. Burke, Esq.
2300 N Street, N.W. Entergy Nuclear Washington, DC 20037-1128 Mail Stop M-ECH-62 Jackson, MS 39213 Martha Coakley, Attorney General Matthew Brock, Assistant Attorney General Katherine Tucker, Esq.
Commonwealth of Massachusetts Law Clerk, Atomic Safety and Licensing Office of Attorney General Board Panel One Ashburton Place U.S. Nuclear Regulatory Commission Boston, MA 02108 11545 Rockville Pike, Mail Stop T3-E2a Rockville, MD 20852 Signed (electronically) by Mary Lampert Pilgrim Watch, pro se 148 Washington St.
Duxbury, MA 023332 Tel: 781-934-0389 Email: mary.lampert@comcast.net April 24, 2011