ML12181A095
| ML12181A095 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 06/06/2012 |
| From: | Duquette D State of NY, Office of the Attorney General |
| To: | Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| Shared Package | |
| ML12180A642 | List: |
| References | |
| RAS 22858, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01 | |
| Download: ML12181A095 (22) | |
Text
NYS000399 Submitted: June 29, 2012 1 UNITED STATES 2 NUCLEAR REGULATORY COMMISSION 3 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4 -----------------------------------x 5 In re: Docket Nos. 50-247-LR; 50-286-LR 6 License Renewal Application Submitted by ASLBP No. 07-858-03-LR-BD01 7 Entergy Nuclear Indian Point 2, LLC, DPR-26, DPR-64 8 Entergy Nuclear Indian Point 3, LLC, and 9 Entergy Nuclear Operations, Inc. June 6, 2012 10 -----------------------------------x 11 PRE-FILED WRITTEN REBUTTAL TESTIMONY OF 12 DR. DAVID J. DUQUETTE 13 REGARDING CONTENTION NYS-5 14 On behalf of the State of New York (NYS or the State),
15 the Office of the Attorney General hereby submits the following 16 rebuttal testimony by Dr. David J. Duquette, Ph.D., regarding 17 Contention NYS-5.
18 Q. What documents did you review in preparation for this 19 rebuttal testimony?
20 A. I read Entergys Statement of Position Regarding 21 Contention NYS-5 (Buried Piping and Tanks); the Testimony of 22 Entergy Witnesses Alan Cox, Ted Ivy, Nelson Acevedo, Robert Lee, 23 Stephen Biagiotti, and Jon Cavallo Concerning Contention NYS-5 Rebuttal Testimony of David J. Duquette Contention NYS-5 1
1 (Buried Piping and Tanks) and the exhibits thereto (Entergy 2 Testimony). I also read NRC Staffs Statement of Position on 3 Contention NYS-5 (Buried Pipes and Tanks) and the Testimony of 4 Kimberly J. Green and William C. Holston Concerning Contention 5 NYS-5 (Buried Pipes And Tanks) and the exhibits thereto (NRC 6 Staff Testimony). None of those documents have changed my 7 opinions related to the management of the buried pipelines at 8 IPEC.
9 Q. As an initial matter, Entergy states on page 6 of its 10 Statement of Position that you appear to have no prior 11 experience with respect to the aging management of buried piping 12 at a nuclear power plant. Is this correct?
13 A. No.
14 Q. Please describe your experience with respect to the 15 aging management of buried piping at a nuclear power plant.
16 A. My experience with corrosion issues at nuclear plants 17 includes consultation at Three Mile Island (TMI-1 and TMI-2),
18 Diablo Canyon, all of the pressurized water reactors and boiling 19 water reactors formerly operated by Commonwealth Edison (these 20 include Byron, LaSalle, Braidwood, Dresden, Quad Cities, 21 Clinton), and Seabrook. I have served on EPRI panels for 22 corrosion control in nuclear power systems, and I was funded by 23 EPRI for 5 years and by the Department of Energy for 11 years Rebuttal Testimony of David J. Duquette Contention NYS-5 2
1 for corrosion research in nuclear systems. I have supervised 2 Ph.D. students performing research on nuclear systems for U.S.
3 Navy applications at the Knolls Atomic Power Laboratory. I have 4 also had personal tours of numerous reactors because of my 5 service on the Nuclear Waste Technical Review Board including 6 Dresden, Savannah River, Hanford, several French plants and 7 plants in England, Germany, Spain, and Argentina. In each of 8 those tours I discussed high level aspects of technical 9 management of the facilities, including aging and maintenance of 10 the infrastructures, in detail. As indicated below, I have also 11 had considerable experience in the management of corrosion of 12 underground piping systems.
13 A. Why was this information not included on the CV you 14 provided in your earlier testimony?
15 A. I provided my academic CV with my prior testimony, 16 which does not include these or other consulting engagements.
17 It is my opinion that my academic CV, without these engagements, 18 qualifies me as an expert in the matter of NYS-5 (Buried Pipes 19 and Tanks). However, I have also had considerable experience in 20 assessing corrosion of numerous structures including other 21 buried structures such as oil and natural gas lines, buried 22 tanks and other underground infrastructure. Any of these 23 experiences would have qualified me as an expert in the area of Rebuttal Testimony of David J. Duquette Contention NYS-5 3
1 buried metallic components. There is nothing specifically 2 nuclear about the buried pipes at Indian Point except that 3 release of material from those piping systems could have very 4 deleterious effects on populations near those structures.
5 Q. In response to your position that Entergy should 6 assume that pipes were defectively coated and that pipes were 7 improperly backfilled, Entergy emphasizes that the 8 specifications in place at the time of plant construction (that 9 is, in the 1960s, before Entergy owned the facility) contained 10 procedures for installing and inspecting coatings installed by 11 the piping manufacturer (Entergy Testimony, Q65-71). Have you 12 seen any evidence from Entergys disclosures that indicate 13 whether those specifications were in fact met?
14 A. No. Entergy has provided the specifications, but in 15 the material I reviewed, I have not seen any indication that 16 they were met.
17 Q. Do you have reason to believe the specifications were 18 not met at the time of construction?
19 A. Yes. The corrosion problem Entergy identified in 2009 20 at the Indian Point Unit 2 condensate storage tank return line 21 was caused by improper backfill, which in turn resulted in a 22 coating failure. This is irrefutable evidence that the 23 specifications were not met 100% of the time at this site at the Rebuttal Testimony of David J. Duquette Contention NYS-5 4
1 time of construction.
2 Q. NRCs experts state that follow-up inspections in 2009 3 on 28 feet of city water line and 8 feet of fire protection line 4 revealed no coating defects or potentially damaging backfill 5 (NRC Staff Testimony, A28). Does this alleviate your concern?
6 A. No. The admitted use of improper backfill leading to 7 corrosion of such severity that the pipe was compromised 8 suggests that there are other sites that may have been 9 inadequately or improperly assessed. Since at least one site 10 was either overlooked or improperly characterized, barring 11 complete inspection of all of the underground piping, there can 12 be no assurance that other areas have not been improperly 13 characterized. A sampling of 28 feet of city water line or of 14 only 8 feet of fire protection line hardly constitutes a 15 significant fraction of the entire underground piping system at 16 IPEC. There is no known method for assessing the depth of 17 localized corrosion at any other piping location at the site 18 based on these limited inspections. For example, given the 19 level of inspection and analysis that has been performed, there 20 is no way to know if there are sites where corrosion may have 21 penetrated though 90% of the pipe wall. To reiterate some of my 22 previous testimony, the use of a remote inspection technique, 23 guided wave technology, failed to detect the extent of corrosion Rebuttal Testimony of David J. Duquette Contention NYS-5 5
1 damage at the leak location at IPEC.
2 Q. The NRC Staff takes the position that although the 3 Applicants in-scope buried pipe plant-specific operating 4 experience has revealed locations where coatings have been 5 damaged, the current licensing basis functions of the affected 6 systems were maintained (NRC Staff Testimony, A30). Does this 7 alleviate your concern?
8 A. No. The fact that a failure has not yet occurred is 9 no indication that a failure will not occur in the renewed 10 licensing period. It has been stated that the function of the 11 buried piping system is to maintain a pressure barrier. Staff 12 Testimony at p. 25. However, I disagree with that opinion.
13 Leaking of radioactive fluids, in my opinion constitutes failure 14 of the system in a pipe, that, like all safety related pipes 15 carrying radioactive fluid, was not supposed to fail.
16 Accordingly, if a failure has already occurred, independent of 17 the root cause of that failure, absent a comprehensive 18 inspection, or protection of the system, there can be no 19 guarantee that future unpredictable failures will not occur in 20 other safety related piping.
21 Q. NRC Staff Testimony relies heavily on a document 22 called the Interim Staff Guidance, LR-ISG-2011-03, Changes to Rebuttal Testimony of David J. Duquette Contention NYS-5 6
1 The Generic Aging Lessons Learned (GALL) Report Aging Management 2 Program XI.M41 Buried and Underground Piping and Tanks 3 (Exhibit NRC000019), or the Draft ISG. You did not mention 4 this document in your testimony; was it available to you as you 5 were preparing your testimony?
6 A. No. This document was released in 2012 as I 7 understand it. I had not seen it before I read the Staffs 8 experts testimony.
9 Q. Have you read the Draft ISG?
10 A. Yes.
11 Q. Does it change your testimony in any way?
12 A. Rather than changing my testimony, the Draft ISG 13 further provides strong support for the portion of my testimony 14 addressing the need for cathodic protection. The Draft ISG 15 makes clear that, contrary to NRC and Entergys expert 16 testimony, failure to provide cathodic protection must be 17 justified, which has not been done by Entergy for Indian Point.
18 The Draft ISG states that an exception must be stated and 19 justified if the basis for not providing cathodic protection is 20 other than demonstrating that external corrosion control (i.e.
21 cathodic protection and coatings) is not required, or 22 demonstrating that installation, operation, or surveillance of a 23 cathodic protection system is not practical. Entergy has not Rebuttal Testimony of David J. Duquette Contention NYS-5 7
1 demonstrated that cathodic protection of IPECs buried piping is 2 not required, nor have they provided evidence that installation, 3 operation, or surveillance are not practical. In fact, it is my 4 opinion that proper operation and surveillance, much of which 5 can be done remotely, is far more practical that the requirement 6 to periodically excavate, inspect and repair meaningful sections 7 of buried piping.
8 The Draft ISG completely supports my prior testimony 9 concerning the importance of cathodic protection at this plant.
10 The Draft ISG requires a plant owner to take into consideration 11 factors including corrosivity of soil and backfill conditions in 12 assessing whether or not the absence of cathodic protection is 13 justified. As I noted in my initial testimony, at Indian Point, 14 we have corrosive soil and problematic backfill conditions.
15 Generally, I believe the Draft ISG supports nearly 16 everything I said NRC should require Entergy to do: (1) follow 17 the dictates of NUREG-1801,Section XI.M41, and (2) follow the 18 recommendations of NACE SP0169-2007.
19 Q. Do you have any other observations about the Draft 20 ISG?
21 A. Yes. I disagree with NRC Staffs experts statements 22 in footnote 3 in which they said that the Staff evaluated the 23 Applicants AMP against key elements of AMP XI.M41 and the Draft Rebuttal Testimony of David J. Duquette Contention NYS-5 8
1 ISG for AMP XI.M41 and concluded that Entergys AMP is adequate 2 to manage the applicable aging effects to ensure that buried 3 piping and tanks will perform their current licensing basis 4 functions. To reiterate, the Draft ISG requires the following:
5
- The failure to provide cathodic protection in 6 accordance with Table 2a must be justified in the LRA.
7 8
- An exception must be stated and justified if the basis 9 for not providing cathodic protection is other than 10 demonstrating that external corrosion control (i.e.,
11 cathodic protection and coatings) is not required or 12 demonstrating that installation, operation, or 13 surveillance of a cathodic protection system is not 14 practical.
15 16
- The applicant must demonstrate, through the submission 17 of a study, the impracticality of installing or 18 operating a cathodic protection system. This study 19 should be conducted by a competent person as defined 20 in NACE SP 0169-2007, Section 1.3, Introduction, who 21 is knowledgeable in the design, installation, and 22 operation of cathodic protection systems. The study 23 should be submitted with the LRA.
24 25
- The applicant must conduct a 20-year search of 26 operating experience for evidence of adverse 27 conditions as described in Section 4.f., Adverse 28 Indications, of Appendix A of this Draft ISG.
29 30 I have seen no evidence that Entergy has performed any of the 31 above. I have not seen any justification for the lack of 32 cathodic protection at Indian Point, and I have not seen any 33 study showing the impracticality of installing or operating a 34 cathodic protection system or that cathodic protection is not 35 necessary. Finally, I have seen no evidence of the 20 year Rebuttal Testimony of David J. Duquette Contention NYS-5 9
1 search of operating experience for evidence of adverse 2 conditions, or for evidence that no adverse conditions exist at 3 IPEC.
4 Page one of the Draft ISG states that the ISG is based on 5 industry operating experience, but the NRC experts admit that 6 Entergy isnt required to meet the requirements of the revised 7 GALL report, or the Draft ISG, in footnote 3. It is poor 8 engineering practice, in my expert opinion, to be aware of 9 industry operating experience and resultant recommendations and 10 not incorporate them into current operating procedures. The 11 very nature of engineering practice is to take advantage of 12 observations and experience to improve operating procedures, 13 especially from a safety perspective.
14 The Draft ISG also states: Given that the potential for 15 piping degradation increases with time, the inspection 16 quantities for some materials increase throughout the 30-year 17 period starting 10 years prior to entering the period of 18 extended operation. I have not seen any indication that 19 Entergys AMP proposes to do this.
20 Finally, in a section entitled Cathodic Protection Survey 21 Acceptance Criteria, on page 5, the Draft ISG states that 22 Based on staff findings during AMP audits, multiple 23 sites do not have an upper limit on cathodic 24 protection pipe-to-soil potential. If the cathodic Rebuttal Testimony of David J. Duquette Contention NYS-5 10
1 protection pipe-to-soil values are too high, coating 2 damage can occur. The staff deleted the general 3 reference to the NACE standards for the acceptance 4 criteria and incorporated the NACE SP0169-2007 5 specific cathodic protection survey acceptance 6 criteria into the AMP.
7 8 The NACE SP0169-2007 specific cathodic protection survey 9 acceptance criteria were established in 2007. However, as I 10 noted in my initial testimony, Entergy has not and apparently 11 will not commit to following NACE guidelines. The NRC Staff 12 certainly were aware of NACE SP0169-2007 and incorporated it 13 into the ISG document as the basis for changes to the generic 14 aging lessons learned (GALL) report revision 2, Aging Management 15 Program XI.M41 Buried and Underground Piping and Tanks. The 16 criteria should have been implemented at operating plants and 17 certainly incorporated into LRAs. Accordingly, there is no 18 excuse for the NRC to fail to require that Entergy meet those 19 guidelines now that the NRC Staff has incorporated them into its 20 Draft ISG.
21 Q. In light of your position that proper specifications 22 were not followed at Indian Point, what additional steps do you 23 believe Entergy should be taking that it has not committed to 24 take at Indian Point?
25 A. As I have stated, I believe that the NRC should 26 require Entergy to (1) follow the dictates of NUREG-1801, Rebuttal Testimony of David J. Duquette Contention NYS-5 11
1 Section XI.M41, and (2) follow the recommendations of NACE 2 SP0169-2007.
3 Q. Do you agree with Entergys experts assertion that 4 cathodic protection is only warranted when coating has degraded 5 and when the metallic surface of the piping is exposed? (Entergy 6 Testimony Q61/A61).
7 A. No. Since any inspection program will only uncover a 8 small fraction of potential sites where coating damage has 9 occurred, there is no way to know where coating damage has 10 occurred that will expose sections of bare steel pipe. Without 11 knowing the extent of coating degradation or coating damage 12 there is no way to assess the efficacy of cathodic protection 13 after damage has been discovered. However, the judicious 14 installation, operation, and maintenance of a cathodic 15 protection system to the buried piping system will have the 16 effect of completely arresting any future corrosion damage.
17 Q. Do you have any other comments regarding cathodic 18 protection?
19 A. Entergy has experience with cathodic protection. At 20 one time the steel sections of the dock were cathodically 21 protected although it is not clear if that system is still in 22 operation. Entergy has also installed a limited cathodic 23 protection system in the vicinity of the city water lines Rebuttal Testimony of David J. Duquette Contention NYS-5 12
1 (Entergy Testimony, A119(a)). It should not be a major exercise 2 to expand the existing cathodic protection system to the piping 3 under consideration in Contention NYS-5.
4 Q. NRC experts note that Entergys aging management 5 program does not commit to meeting NACE standards, which call 6 for cathodic protection, but that Entergy has compensated for 7 this by requiring more frequent inspections. NRC Staff Testimony 8 A29. In your professional judgment, do an increased number of 9 inspections sufficiently make up for the absence of cathodic 10 protection in buried pipes and tanks?
11 A. No. An increased number of inspections will allow the 12 examination of more sites, but the total amount of piping that 13 will be excavated and inspected will still be much less than the 14 extent of the entire buried piping system. While the increased 15 number of inspections may statistically improve the possibility 16 of discovering coating and/or metal damage, the undetected areas 17 will still dominate the population. It is especially important 18 to note that the corrosiveness of the soil at IPEC is quite 19 variable near the surface, while little is known about the 20 quality of the soil at the depth of the piping. The incident at 21 Indian Point where backfill had damaged the coating on the 22 piping, resulting in corrosion of the pipe, is an example of the 23 difficulty in performing a three dimensional analysis of soil Rebuttal Testimony of David J. Duquette Contention NYS-5 13
1 conditions at any buried piping site. Poor backfill, or other 2 aggressive conditions at the piping horizon can only be poorly 3 correlated with the chemical composition and corrosivity of soil 4 at the surface.
5 And regarding the increased number of inspections, it is 6 still not clear what the criteria will be for site selection, 7 where the inspections will be done, specifically how often they 8 will be done, and how quickly future inspections will take place 9 if a problem is found.
10 Q. NRC Staffs experts explain that the number of 11 inspections Entergy proposes is consistent with the Draft ISG.
12 NRC Staff Testimony A42. Do you agree with that statement?
13 A. No. One merely has to read the Draft ISG to come to 14 the conclusion that Entergys inspections do not follow the 15 guidelines of the ISG or of NACE SP0169-2007, or AMP XI.M41.
16 Each of those documents cites the necessity of justification if 17 cathodic protection is not utilized. Increased frequency of 18 inspections does not replace the requirement for cathodic 19 protection, and certainly does not qualify as justification to 20 ignore the considerable benefits of cathodic protection.
21 Q. Entergys experts explain that Entergy has gathered 22 significant insights into the condition of IPEC buried pipes 23 and their coatings through direct visual examinations of Rebuttal Testimony of David J. Duquette Contention NYS-5 14
1 excavated piping and indirect (e.g., APEC, guided-wave testing) 2 examinations performed to date. Entergy Testimony, A34. In 3 your opinion, is guidedwave testing a reliable inspection 4 method?
5 A. No, and neither NACE nor the NRC Staff think it is 6 either. Even the document on which the NRC Staff relies so 7 heavily, the Draft ISG, states that guided wave inspections do 8 not meet the intent of the paragraph requiring inspections.
9 Moreover, on this particular site, guided-wave technology was 10 not effective. Guided-wave technology was used on the 11 condensate storage return line a year before a through wall 12 failure, generated from external corrosion, occurred, with no 13 indication of any significant pipe wall reduction found using 14 the guided-wave technology.
15 Q. Entergys experts indicate that available data do 16 not indicate that soil surrounding in-scope buried piping at 17 IPEC is corrosive. (Entergy Testimony, Q83/A83). Do you agree 18 with that statement?
19 A. No. Entergys own consultants report indicated that 20 soil on the IPEC site was mildly to moderately corrosive. I 21 discussed this report in my initial testimony. Corrosive is 22 corrosive; soil conditions either are or are not corrosive. To 23 say that moderately corrosive soil is not corrosive is Rebuttal Testimony of David J. Duquette Contention NYS-5 15
1 inaccurate and misleading.
2 Q. Do you agree with the definition of failure offered 3 by Entergy and NRC Staff?
4 A. Absolutely not. Entergy offers an overly narrow 5 definition of a piping failure, and NRC Staff does not offer its 6 own definition but simply adopts Entergys. Entergy defines the 7 function of a pipe as maintaining a pressure boundary. Entergy 8 Testimony at Answer 94. The function of piping and of tanks is 9 not only to maintain pressure, but to contain the fluids that 10 either flow or are stored in them. Piping systems that contain, 11 or can contain, potentially toxic materials, by definition, fail 12 if the toxic material is released to the environment. For 13 example, there are holding tanks at Hanford, Washington, that 14 contain highly radioactive liquids, that are currently leaking, 15 and the effluent will eventually reach the Columbia River 16 watershed. The State of Washington and the surrounding 17 population certainly consider the leaking of highly radioactive 18 liquids to be failure of the tanks.
19 In some cases small perforations on pipes such as corrosion 20 induced pits can even be considered a more serious failure of a 21 piping system than complete failure of the pressure boundary. A 22 simple consideration of Bernoullis equations indicates that 23 liquids under pressure will have an increased velocity if the Rebuttal Testimony of David J. Duquette Contention NYS-5 16
1 exit orifice in a pipe has a smaller diameter than the pipe 2 itself. This increase in velocity from the exit orifice (a pit 3 or local perforation) may actually result in fluids reaching the 4 surface more rapidly than if the pressure barrier is completely 5 compromised.
6 Q. Entergy indicates that the piping at issue in this 7 contention is a relatively small subset of the piping managed 8 by Entergys aging management program. Entergy Statement of 9 Position at 22. Do you believe it is impractical, as Entergy 10 asserts, to excavate all in-scope buried piping?
11 A. Yes, I agree. However, there is no need to excavate 12 all of the buried piping. The application of a well designed, 13 properly operated, and adequately maintained cathodic protection 14 system will effectively arrest any corrosion that may now exist.
15 It will also prevent further corrosion from initiating, thus 16 effectively obviating the need for complete excavation of the 17 buried piping systems.
18 Q. Do you agree with the NRC Staff expert Mr. Holstons 19 assertion that a leak (whether radioactive or non-radioactive) 20 from a piping system does not degrade the ability of a piping 21 system to perform its CLB pressure boundary function unless the 22 leak is very substantial.? (NRC Staff Testimony, A19)
Rebuttal Testimony of David J. Duquette Contention NYS-5 17
1 A. Mr. Holston is correct in that a leak does not 2 necessarily degrade the ability of a piping system to perform as 3 a pressure barrier. However, as I have stated, maintaining a 4 pressure barrier is only one function of a piping system. The 5 second, and perhaps more important function for piping systems 6 such as those at IPEC that are not under high pressure, is to 7 contain the fluid in the system. If the piping cannot perform 8 that function it has, de facto, failed.
9 Q. NRC Staffs expert Mr. Holston points out that Staff 10 guidance does not recommend a baseline inspection, baseline 11 piping wall conditions, or determination of corrosion rates, and 12 that such baseline and corrosion rate analyses are not necessary 13 to adequately manage leaks. NRC Staff Testimony A33. Do you 14 agree with those statements?
15 A. No. I dont understand Mr. Holstons opinion except 16 that he appears to believe that leaks are acceptable. It is my 17 opinion that a leak of a radioactive fluid presents a danger to 18 the population in the vicinity of the radioactive leak. I also 19 dont understand how Mr. Holston has arrived at the conclusion 20 that leaks can be managed without some consideration of the 21 conditions of the pipe wall conditions.
22 Q. Entergys experts state that you did not take into 23 account the specific program documents and procedures that are Rebuttal Testimony of David J. Duquette Contention NYS-5 18
1 being used to implement the aging management program when you 2 stated that the program was conceptual and aspirational in 3 nature. Entergy Testimony Q88/A88. What is your response to 4 that?
5 A. Entergys experts are not correct. I did take these 6 program documents and procedures into account, and I generally 7 support the details within them - my problem stems from the fact 8 that Entergys proposed aging management program contains 9 virtually none of the details found within these documents.
10 Accordingly, any requirements contained within the proposed 11 program that are not incorporated into the plants license or 12 UFSAR are unenforceable by the NRC and can be changed at any 13 time without NRC notice, as the NRCs expert Mr. Holston has 14 admitted in A.47 of his testimony. The details found in these 15 programs need to be incorporated into the aging management 16 program to which Entergy is committed, and then into the 17 operating license itself. Of even greater concern is that even 18 these expanded, albeit unenforceable, plans by Entergy ignore 19 implementation of AMP XI.41, the issuance of the ISG and the 20 NACE basis for the ISG. The ISG is based on industry 21 experience, perhaps the most important consideration in good 22 engineering practice and yet Entergy is disregarding it.
23 Q. Entergys experts have also asserted that you Rebuttal Testimony of David J. Duquette Contention NYS-5 19
1 misunderstand the applicable program documentation as to the 2 timing of inspections, and indicate that Entergy will perform 20 3 visual inspections for IP2 and 14 direct visual inspections for 4 IP3 before the period of extended operation, and 14 direct 5 visual inspections for IP2 and 16 direct visual inspections for 6 IP3 during each 10-year interval of the period of extended 7 operation. Does this explanation satisfy you?
8 A. No. Entergys experts have not addressed the where 9 and when. They have not explained the specific criteria for 10 site selection, where the inspections will take place, or when 11 they will take place (for example, will they do all 14 12 inspections of IP2 in year five? year nine? start with year 1?).
13 This remains an open issue for me because in the past, Entergy 14 claims that they had performed a presumably careful inspection 15 of part of the CST line (according to their criteria), and the 16 line failed in a place other than that which was inspected. The 17 where and when is critical here to understanding the efficacy 18 of the proposed aging management plan. Entergys experts do not 19 indicate in their testimony why these numbers were chosen. I 20 agree that, if NRC does not require compliance with AMP XI.M41 21 and the ISG, more frequent inspections will be needed, but how 22 many more and at what intervals? Entergys experts have not 23 answered these questions such that my position on this issue has Rebuttal Testimony of David J. Duquette Contention NYS-5 20
1 been resolved. The very nature of a spot inspection program 2 that can only be limited to specific sites is, by its very 3 nature, flawed, as witnessed by the lack of ability to predict 4 the corrosion failure of the CST line.
5 Q. Have you now completed your rebuttal testimony 6 regarding Contention NYS-5?
7 A. Yes. However, I retain the ability to offer further 8 testimony if new information is provided.
9 I have reviewed all the exhibits referenced herein. True 10 and accurate copies of documents not attached to my initial 11 testimony are attached here.
12 Rebuttal Testimony of David J. Duquette Contention NYS-5 21
1 UNITED STATES 2 NUCLEAR REGULATORY COMMISSION 3 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4 x 5 In re: Docket Nos. 50-247-LR; 50-286--LR 6 License Renewal Application Submitted by ASLBP No. 07-858-03-LR-BDO1 7 Entergy Nuclear Indian Point 2, LLC, DPR-26, DPR-64 8 Entergy Nuclear Indian Point 3, LLC, and 9 Entergy Nuclear Operations, Inc. June 6, 2012 10 x 11 DECLARATION OF DAVID J. DUQUETTE 12 I, David J. Duquette, do hereby declare under penalty of 13 perjury that my statements in the foregoing testimony and my 14 statement of professional qualifications are true and correct to 15 the best of my knowledge and belief.
Executed in Accord wit1 10 C F R / 2 304(d) r(
/ Ph D David J iuete Materials Engineering Cofis/.iltin services 4 North Lane Loudonville, New York 12211 Tel: 518 276 6490 Fax: 518 462 1206 Email: duqued@rpi edu June 6, 2012 Rebuttal Testimony of David J. Duquette Contention NYS-5 22