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{{#Wiki_filter:United States Nuclear Regulatory Commission Official Hearing Exhibit Entergy Nuclear Operations, Inc.
{{#Wiki_filter:Rebuttal Testimony of David J. Duquette Contention NYS-5 1
In the Matter of:
UNITED STATES 1
NUCLEAR REGULATORY COMMISSION 2
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 3
-----------------------------------x 4
In re:
Docket Nos. 50-247-LR; 50-286-LR 5
License Renewal Application Submitted by ASLBP No. 07-858-03-LR-BD01 6
Entergy Nuclear Indian Point 2, LLC, DPR-26, DPR-64 7
Entergy Nuclear Indian Point 3, LLC, and 8
Entergy Nuclear Operations, Inc.
October 5, 2012 9
-----------------------------------x 10 PRE-FILED WRITTEN REBUTTAL TESTIMONY OF 11 DR. DAVID J. DUQUETTE 12 REGARDING CONTENTION NYS-5 13 On behalf of the State of New York (NYS or the State),
14 the Office of the Attorney General hereby submits the following 15 rebuttal testimony by Dr. David J. Duquette, Ph.D., regarding 16 Contention NYS-5.
17 Q.
What documents did you review in preparation for this 18 rebuttal testimony?
19 A.
I read Entergys Statement of Position Regarding 20 Contention NYS-5 (Buried Piping and Tanks); the Testimony of 21 Entergy Witnesses Alan Cox, Ted Ivy, Nelson Acevedo, Robert Lee, 22 Stephen Biagiotti, and Jon Cavallo Concerning Contention NYS-5 23 United States Nuclear Regulatory Commission Official Hearing Exhibit In the Matter of:
Entergy Nuclear Operations, Inc.
(Indian Point Nuclear Generating Units 2 and 3)
(Indian Point Nuclear Generating Units 2 and 3)
ASLBP #: 07-858-03-LR-BD01                                                                       NYSR20399 Docket #: 05000247 l 05000286                                                       Revised: October 16, 2012 Exhibit #: NYSR20399-00-BD01                  Identified: 10/17/2012 Admitted: 10/17/2012                        Withdrawn:
ASLBP #: 07-858-03-LR-BD01 Docket #: 05000247 l 05000286 Exhibit #:
Rejected:                                       Stricken:
Identified:
Admitted:
Withdrawn:
Rejected:
Stricken:
Other:
Other:
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.                                    October 5, 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),
NYSR20399-00-BD01 10/17/2012 10/17/2012 NYSR20399 Revised: October 16, 2012
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.
Rebuttal Testimony of David J. Duquette Contention NYS-5 2
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?
(Buried Piping and Tanks) and the exhibits thereto (Entergy 1
13      A. No.
Testimony). I also read NRC Staffs Statement of Position on 2
14      Q. Please describe your experience with respect to the 15 aging management of buried piping at a nuclear power plant.
Contention NYS-5 (Buried Pipes and Tanks) and the Testimony of 3
16      A. My experience with corrosion issues at nuclear plants 17 includes consultation at Three Mile Island (TMI-1 and TMI-2),
Kimberly J. Green and William C. Holston Concerning Contention 4
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
NYS-5 (Buried Pipes And Tanks) and the exhibits thereto (NRC 5
Staff Testimony). None of those documents have changed my 6
opinions related to the management of the buried pipelines at 7
IPEC.
8 Q.
As an initial matter, Entergy states on page 6 of its 9
Statement of Position that you appear to have no prior 10 experience with respect to the aging management of buried piping 11 at a nuclear power plant. Is this correct?
12 A.
No.
13 Q.
Please describe your experience with respect to the 14 aging management of buried piping at a nuclear power plant.
15 A.
My experience with corrosion issues at nuclear plants 16 includes consultation at Three Mile Island (TMI-1 and TMI-2),
17 Diablo Canyon, all of the pressurized water reactors and boiling 18 water reactors formerly operated by Commonwealth Edison (these 19 include Byron, LaSalle, Braidwood, Dresden, Quad Cities, 20 Clinton), and Seabrook. I have served on EPRI panels for 21 corrosion control in nuclear power systems, and I was funded by 22 EPRI for 5 years and by the Department of Energy for 11 years 23


1 for corrosion research in nuclear systems. I have supervised 2 Ph.D. students performing research on nuclear systems for U.S.
Rebuttal Testimony of David J. Duquette Contention NYS-5 3
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.
for corrosion research in nuclear systems. I have supervised 1
13      A. Why was this information not included on the CV you 14 provided in your earlier testimony?
Ph.D. students performing research on nuclear systems for U.S.
15      A. I provided my academic CV with my prior testimony, 16 which does not include these or other consulting engagements.
2 Navy applications at the Knolls Atomic Power Laboratory. I have 3
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
also had personal tours of numerous reactors because of my 4
service on the Nuclear Waste Technical Review Board including 5
Dresden, Savannah River, Hanford, several French plants and 6
plants in England, Germany, Spain, and Argentina. In each of 7
those tours I discussed high level aspects of technical 8
management of the facilities, including aging and maintenance of 9
the infrastructures, in detail. As indicated below, I have also 10 had considerable experience in the management of corrosion of 11 underground piping systems.
12 A.
Why was this information not included on the CV you 13 provided in your earlier testimony?
14 A.
I provided my academic CV with my prior testimony, 15 which does not include these or other consulting engagements.
16 It is my opinion that my academic CV, without these engagements, 17 qualifies me as an expert in the matter of NYS-5 (Buried Pipes 18 and Tanks). However, I have also had considerable experience in 19 assessing corrosion of numerous structures including other 20 buried structures such as oil and natural gas lines, buried 21 tanks and other underground infrastructure. Any of these 22 experiences would have qualified me as an expert in the area of 23


1 buried metallic components. There is nothing specifically 2 nuclear about the buried pipes at Indian Point.
Rebuttal Testimony of David J. Duquette Contention NYS-5 4
3      Q. In response to your position that Entergy should 4 assume that pipes were defectively coated and that pipes were 5 improperly backfilled, Entergy emphasizes that the 6 specifications in place at the time of plant construction (that 7 is, in the 1960s, before Entergy owned the facility) contained 8 procedures for installing and inspecting coatings installed by 9 the piping manufacturer (Entergy Testimony, Q65-71). Have you 10 seen any evidence from Entergys disclosures that indicate 11 whether those specifications were in fact met?
buried metallic components. There is nothing specifically 1
12      A. No. Entergy has provided the specifications, but in 13 the material I reviewed, I have not seen any indication that 14 they were met.
nuclear about the buried pipes at Indian Point.
15      Q. Do you have reason to believe the specifications were 16 not met at the time of construction?
2 Q.
17      A. Yes. The corrosion problem Entergy identified in 2009 18 at the Indian Point Unit 2 condensate storage tank return line 19 was caused by improper backfill, which in turn resulted in a 20 coating failure. This is irrefutable evidence that the 21 specifications were not met 100% of the time at this site at the 22 time of construction.
In response to your position that Entergy should 3
23      Q. NRCs experts state that follow-up inspections in 2009 Rebuttal Testimony of David J. Duquette Contention NYS-5 4
assume that pipes were defectively coated and that pipes were 4
improperly backfilled, Entergy emphasizes that the 5
specifications in place at the time of plant construction (that 6
is, in the 1960s, before Entergy owned the facility) contained 7
procedures for installing and inspecting coatings installed by 8
the piping manufacturer (Entergy Testimony, Q65-71). Have you 9
seen any evidence from Entergys disclosures that indicate 10 whether those specifications were in fact met?
11 A.
No. Entergy has provided the specifications, but in 12 the material I reviewed, I have not seen any indication that 13 they were met.
14 Q.
Do you have reason to believe the specifications were 15 not met at the time of construction?
16 A.
Yes. The corrosion problem Entergy identified in 2009 17 at the Indian Point Unit 2 condensate storage tank return line 18 was caused by improper backfill, which in turn resulted in a 19 coating failure. This is irrefutable evidence that the 20 specifications were not met 100% of the time at this site at the 21 time of construction.
22 Q.
NRCs experts state that follow-up inspections in 2009 23


1 on 28 feet of city water line and 8 feet of fire protection line 2 revealed no coating defects or potentially damaging backfill 3 (NRC Staff Testimony, A28). Does this alleviate your concern?
4      A. No. The admitted use of improper backfill leading to 5 corrosion of such severity that the pipe was compromised 6 suggests that there are other sites that may have been 7 inadequately or improperly assessed. Since at least one site 8 was either overlooked or improperly characterized, barring 9 complete inspection of all of the underground piping, there can 10 be no assurance that other areas have not been improperly 11 characterized. A sampling of 28 feet of city water line or of 12 only 8 feet of fire protection line hardly constitutes a 13 significant fraction of the entire underground piping system at 14 IPEC. There is no known method for assessing the depth of 15 localized corrosion at any other piping location at the site 16 based on these limited inspections. For example, given the 17 level of inspection and analysis that has been performed, there 18 is no way to know if there are sites where corrosion may have 19 penetrated though 90% of the pipe wall. To reiterate some of my 20 previous testimony, the use of a remote inspection technique, 21 guided wave technology, failed to detect the extent of corrosion 22 damage at the leak location at IPEC.
Rebuttal Testimony of David J. Duquette Contention NYS-5 5
Rebuttal Testimony of David J. Duquette Contention NYS-5 5
on 28 feet of city water line and 8 feet of fire protection line 1
revealed no coating defects or potentially damaging backfill 2
(NRC Staff Testimony, A28). Does this alleviate your concern?
3 A.
No. The admitted use of improper backfill leading to 4
corrosion of such severity that the pipe was compromised 5
suggests that there are other sites that may have been 6
inadequately or improperly assessed. Since at least one site 7
was either overlooked or improperly characterized, barring 8
complete inspection of all of the underground piping, there can 9
be no assurance that other areas have not been improperly 10 characterized. A sampling of 28 feet of city water line or of 11 only 8 feet of fire protection line hardly constitutes a 12 significant fraction of the entire underground piping system at 13 IPEC. There is no known method for assessing the depth of 14 localized corrosion at any other piping location at the site 15 based on these limited inspections. For example, given the 16 level of inspection and analysis that has been performed, there 17 is no way to know if there are sites where corrosion may have 18 penetrated though 90% of the pipe wall. To reiterate some of my 19 previous testimony, the use of a remote inspection technique, 20 guided wave technology, failed to detect the extent of corrosion 21 damage at the leak location at IPEC.
22


1      Q. The NRC Staff takes the position that although the 2 Applicants in-scope buried pipe plant-specific operating 3 experience has revealed locations where coatings have been 4 damaged, the current licensing basis functions of the affected 5 systems were maintained (NRC Staff Testimony, A30). Does this 6 alleviate your concern?
Rebuttal Testimony of David J. Duquette Contention NYS-5 6
7      A. No. The fact that a failure has not yet occurred is 8 no indication that a failure will not occur in the renewed 9 licensing period. It has been stated that the function of the 10 buried piping system is to maintain a pressure barrier. Staff 11 Testimony at p. 25. However, I disagree with that opinion.
Q.
12 Leaking of radioactive fluids, in my opinion constitutes failure 13 of the system in a pipe, that, like all safety related pipes 14 carrying radioactive fluid, was not supposed to fail.
The NRC Staff takes the position that although the 1
15 Accordingly, if a failure has already occurred, independent of 16 the root cause of that failure, absent a comprehensive 17 inspection, or protection of the system, there can be no 18 guarantee that future unpredictable failures will not occur in 19 other safety related piping.
Applicants in-scope buried pipe plant-specific operating 2
20      Q. NRC Staff Testimony relies heavily on a document 21 called the Interim Staff Guidance, LR-ISG-2011-03, Changes to 22 The Generic Aging Lessons Learned (GALL) Report Aging Management 23 Program XI.M41 Buried and Underground Piping and Tanks Rebuttal Testimony of David J. Duquette Contention NYS-5 6
experience has revealed locations where coatings have been 3
damaged, the current licensing basis functions of the affected 4
systems were maintained (NRC Staff Testimony, A30). Does this 5
alleviate your concern?
6 A.
No. The fact that a failure has not yet occurred is 7
no indication that a failure will not occur in the renewed 8
licensing period. It has been stated that the function of the 9
buried piping system is to maintain a pressure barrier. Staff 10 Testimony at p. 25. However, I disagree with that opinion.
11 Leaking of radioactive fluids, in my opinion constitutes failure 12 of the system in a pipe, that, like all safety related pipes 13 carrying radioactive fluid, was not supposed to fail.
14 Accordingly, if a failure has already occurred, independent of 15 the root cause of that failure, absent a comprehensive 16 inspection, or protection of the system, there can be no 17 guarantee that future unpredictable failures will not occur in 18 other safety related piping.
19 Q.
NRC Staff Testimony relies heavily on a document 20 called the Interim Staff Guidance, LR-ISG-2011-03, Changes to 21 The Generic Aging Lessons Learned (GALL) Report Aging Management 22 Program XI.M41 Buried and Underground Piping and Tanks 23


1 (Exhibit NRC000019), or the Draft ISG. You did not mention 2 this document in your testimony; was it available to you as you 3 were preparing your testimony?
Rebuttal Testimony of David J. Duquette Contention NYS-5 7
4      A. No. This document was released in 2012 as I 5 understand it. I had not seen it before I read the Staffs 6 experts testimony.
(Exhibit NRC000019), or the Draft ISG. You did not mention 1
7      Q. Have you read the Draft ISG?
this document in your testimony; was it available to you as you 2
8      A. Yes.
were preparing your testimony?
9      Q. Does it change your testimony in any way?
3 A.
10      A. Rather than changing my testimony, the Draft ISG 11 further provides strong support for the portion of my testimony 12 addressing the need for cathodic protection. The Draft ISG 13 makes clear that, contrary to NRC and Entergys expert 14 testimony, failure to provide cathodic protection must be 15 justified, which has not been done by Entergy for Indian Point.
No. This document was released in 2012 as I 4
16 The Draft ISG states that an exception must be stated and 17 justified if the basis for not providing cathodic protection is 18 other than demonstrating that external corrosion control (i.e.
understand it. I had not seen it before I read the Staffs 5
19 cathodic protection and coatings) is not required, or 20 demonstrating that installation, operation, or surveillance of a 21 cathodic protection system is not practical. Entergy has not 22 demonstrated that cathodic protection of IPECs buried piping is 23 not required, nor have they provided evidence that installation, Rebuttal Testimony of David J. Duquette Contention NYS-5 7
experts testimony.
6 Q.
Have you read the Draft ISG?
7 A.
Yes.
8 Q.
Does it change your testimony in any way?
9 A.
Rather than changing my testimony, the Draft ISG 10 further provides strong support for the portion of my testimony 11 addressing the need for cathodic protection. The Draft ISG 12 makes clear that, contrary to NRC and Entergys expert 13 testimony, failure to provide cathodic protection must be 14 justified, which has not been done by Entergy for Indian Point.
15 The Draft ISG states that an exception must be stated and 16 justified if the basis for not providing cathodic protection is 17 other than demonstrating that external corrosion control (i.e.
18 cathodic protection and coatings) is not required, or 19 demonstrating that installation, operation, or surveillance of a 20 cathodic protection system is not practical. Entergy has not 21 demonstrated that cathodic protection of IPECs buried piping is 22 not required, nor have they provided evidence that installation, 23


1 operation, or surveillance are not practical. In fact, it is my 2 opinion that proper operation and surveillance, much of which 3 can be done remotely, is far more practical that the requirement 4 to periodically excavate, inspect and repair meaningful sections 5 of buried piping.
Rebuttal Testimony of David J. Duquette Contention NYS-5 8
6      The Draft ISG completely supports my prior testimony 7 concerning the importance of cathodic protection at this plant.
operation, or surveillance are not practical. In fact, it is my 1
8 The Draft ISG requires a plant owner to take into consideration 9 factors including corrosivity of soil and backfill conditions in 10 assessing whether or not the absence of cathodic protection is 11 justified. As I noted in my initial testimony, at Indian Point, 12 we have corrosive soil and problematic backfill conditions.
opinion that proper operation and surveillance, much of which 2
13      Generally, I believe the Draft ISG supports nearly 14 everything I said NRC should require Entergy to do: (1) follow 15 the dictates of NUREG-1801, Section XI.M41, and (2) follow the 16 recommendations of NACE SP0169-2007.
can be done remotely, is far more practical that the requirement 3
17      Q. Do you have any other observations about the Draft 18 ISG?
to periodically excavate, inspect and repair meaningful sections 4
19      A. Yes. I disagree with NRC Staffs experts statements 20 in footnote 3 in which they said that the Staff evaluated the 21 Applicants AMP against key elements of AMP XI.M41 and the Draft 22 ISG for AMP XI.M41 and concluded that Entergys AMP is adequate 23 to manage the applicable aging effects to ensure that buried Rebuttal Testimony of David J. Duquette Contention NYS-5 8
of buried piping.
5 The Draft ISG completely supports my prior testimony 6
concerning the importance of cathodic protection at this plant.
7 The Draft ISG requires a plant owner to take into consideration 8
factors including corrosivity of soil and backfill conditions in 9
assessing whether or not the absence of cathodic protection is 10 justified. As I noted in my initial testimony, at Indian Point, 11 we have corrosive soil and problematic backfill conditions.
12 Generally, I believe the Draft ISG supports nearly 13 everything I said NRC should require Entergy to do: (1) follow 14 the dictates of NUREG-1801, Section XI.M41, and (2) follow the 15 recommendations of NACE SP0169-2007.
16 Q.
Do you have any other observations about the Draft 17 ISG?
18 A.
Yes. I disagree with NRC Staffs experts statements 19 in footnote 3 in which they said that the Staff evaluated the 20 Applicants AMP against key elements of AMP XI.M41 and the Draft 21 ISG for AMP XI.M41 and concluded that Entergys AMP is adequate 22 to manage the applicable aging effects to ensure that buried 23


1 piping and tanks will perform their current licensing basis 2 functions. To reiterate, the Draft ISG requires the following:
Rebuttal Testimony of David J. Duquette Contention NYS-5 9
3    x The failure to provide cathodic protection in 4      accordance with Table 2a must be justified in the LRA.
piping and tanks will perform their current licensing basis 1
5 6    x An exception must be stated and justified if the basis 7      for not providing cathodic protection is other than 8      demonstrating that external corrosion control (i.e.,
functions. To reiterate, the Draft ISG requires the following:
9      cathodic protection and coatings) is not required or 10      demonstrating that installation, operation, or 11      surveillance of a cathodic protection system is not 12      practical.
2
13 14    x The applicant must demonstrate, through the submission 15      of a study, the impracticality of installing or 16      operating a cathodic protection system. This study 17      should be conducted by a competent person as defined 18      in NACE SP 0169-2007, Section 1.3, Introduction, who 19      is knowledgeable in the design, installation, and 20      operation of cathodic protection systems. The study 21      should be submitted with the LRA.

22 23    x The applicant must conduct a 20-year search of 24      operating experience for evidence of adverse 25      conditions as described in Section 4.f., Adverse 26      Indications, of Appendix A of this Draft ISG.
The failure to provide cathodic protection in 3
27 28 I have seen no evidence that Entergy has performed any of the 29 above. I have not seen any justification for the lack of 30 cathodic protection at Indian Point, and I have not seen any 31 study showing the impracticality of installing or operating a 32 cathodic protection system or that cathodic protection is not 33 necessary. Finally, I have seen no evidence of the 20 year 34 search of operating experience for evidence of adverse Rebuttal Testimony of David J. Duquette Contention NYS-5 9
accordance with Table 2a must be justified in the LRA.
4 5

An exception must be stated and justified if the basis 6
for not providing cathodic protection is other than 7
demonstrating that external corrosion control (i.e.,
8 cathodic protection and coatings) is not required or 9
demonstrating that installation, operation, or 10 surveillance of a cathodic protection system is not 11 practical.
12 13

The applicant must demonstrate, through the submission 14 of a study, the impracticality of installing or 15 operating a cathodic protection system. This study 16 should be conducted by a competent person as defined 17 in NACE SP 0169-2007, Section 1.3, Introduction, who 18 is knowledgeable in the design, installation, and 19 operation of cathodic protection systems. The study 20 should be submitted with the LRA.
21 22

The applicant must conduct a 20-year search of 23 operating experience for evidence of adverse 24 conditions as described in Section 4.f., Adverse 25 Indications, of Appendix A of this Draft ISG.
26 27 I have seen no evidence that Entergy has performed any of the 28 above. I have not seen any justification for the lack of 29 cathodic protection at Indian Point, and I have not seen any 30 study showing the impracticality of installing or operating a 31 cathodic protection system or that cathodic protection is not 32 necessary. Finally, I have seen no evidence of the 20 year 33 search of operating experience for evidence of adverse 34


1 conditions, or for evidence that no adverse conditions exist at 2 IPEC.
Rebuttal Testimony of David J. Duquette Contention NYS-5 10 conditions, or for evidence that no adverse conditions exist at 1
3      Page one of the Draft ISG states that the ISG is based on 4 industry operating experience, but the NRC experts admit that 5 Entergy isnt required to meet the requirements of the revised 6 GALL report, or the Draft ISG, in footnote 3. It is poor 7 engineering practice, in my expert opinion, to be aware of 8 industry operating experience and resultant recommendations and 9 not incorporate them into current operating procedures. The 10 very nature of engineering practice is to take advantage of 11 observations and experience to improve operating procedures, 12 especially from a safety perspective.
IPEC.
13      The Draft ISG also states: Given that the potential for 14 piping degradation increases with time, the inspection 15 quantities for some materials increase throughout the 30-year 16 period starting 10 years prior to entering the period of 17 extended operation. I have not seen any indication that 18 Entergys AMP proposes to do this.
2 Page one of the Draft ISG states that the ISG is based on 3
19      Finally, in a section entitled Cathodic Protection Survey 20 Acceptance Criteria, on page 5, the Draft ISG states that 21      Based on staff findings during AMP audits, multiple 22      sites do not have an upper limit on cathodic 23      protection pipe-to-soil potential. If the cathodic 24      protection pipe-to-soil values are too high, coating 25      damage can occur. The staff deleted the general Rebuttal Testimony of David J. Duquette Contention NYS-5 10
industry operating experience, but the NRC experts admit that 4
Entergy isnt required to meet the requirements of the revised 5
GALL report, or the Draft ISG, in footnote 3. It is poor 6
engineering practice, in my expert opinion, to be aware of 7
industry operating experience and resultant recommendations and 8
not incorporate them into current operating procedures. The 9
very nature of engineering practice is to take advantage of 10 observations and experience to improve operating procedures, 11 especially from a safety perspective.
12 The Draft ISG also states: Given that the potential for 13 piping degradation increases with time, the inspection 14 quantities for some materials increase throughout the 30-year 15 period starting 10 years prior to entering the period of 16 extended operation. I have not seen any indication that 17 Entergys AMP proposes to do this.
18 Finally, in a section entitled Cathodic Protection Survey 19 Acceptance Criteria, on page 5, the Draft ISG states that 20 Based on staff findings during AMP audits, multiple 21 sites do not have an upper limit on cathodic 22 protection pipe-to-soil potential. If the cathodic 23 protection pipe-to-soil values are too high, coating 24 damage can occur. The staff deleted the general 25


1      reference to the NACE standards for the acceptance 2      criteria and incorporated the NACE SP0169-2007 3      specific cathodic protection survey acceptance 4      criteria into the AMP.
Rebuttal Testimony of David J. Duquette Contention NYS-5 11 reference to the NACE standards for the acceptance 1
5 6      The NACE SP0169-2007 specific cathodic protection survey 7 acceptance criteria were established in 2007. However, as I 8 noted in my initial testimony, Entergy has not and apparently 9 will not commit to following NACE guidelines. The NRC Staff 10 certainly were aware of NACE SP0169-2007 and incorporated it 11 into the ISG document as the basis for changes to the generic 12 aging lessons learned (GALL) report revision 2, Aging Management 13 Program XI.M41 Buried and Underground Piping and Tanks. The 14 criteria should have been implemented at operating plants and 15 certainly incorporated into LRAs. Accordingly, there is no 16 excuse for the NRC to fail to require that Entergy meet those 17 guidelines now that the NRC Staff has incorporated them into its 18 Draft ISG.
criteria and incorporated the NACE SP0169-2007 2
19      Q. In light of your position that proper specifications 20 were not followed at Indian Point, what additional steps do you 21 believe Entergy should be taking that it has not committed to 22 take at Indian Point?
specific cathodic protection survey acceptance 3
23      A. As I have stated, I believe that the NRC should 24 require Entergy to (1) follow the dictates of NUREG-1801, Rebuttal Testimony of David J. Duquette Contention NYS-5 11
criteria into the AMP.
4 5
The NACE SP0169-2007 specific cathodic protection survey 6
acceptance criteria were established in 2007. However, as I 7
noted in my initial testimony, Entergy has not and apparently 8
will not commit to following NACE guidelines. The NRC Staff 9
certainly were aware of NACE SP0169-2007 and incorporated it 10 into the ISG document as the basis for changes to the generic 11 aging lessons learned (GALL) report revision 2, Aging Management 12 Program XI.M41 Buried and Underground Piping and Tanks. The 13 criteria should have been implemented at operating plants and 14 certainly incorporated into LRAs. Accordingly, there is no 15 excuse for the NRC to fail to require that Entergy meet those 16 guidelines now that the NRC Staff has incorporated them into its 17 Draft ISG.
18 Q.
In light of your position that proper specifications 19 were not followed at Indian Point, what additional steps do you 20 believe Entergy should be taking that it has not committed to 21 take at Indian Point?
22 A.
As I have stated, I believe that the NRC should 23 require Entergy to (1) follow the dictates of NUREG-1801, 24


1 Section XI.M41, and (2) follow the recommendations of NACE 2 SP0169-2007.
Rebuttal Testimony of David J. Duquette Contention NYS-5 12 Section XI.M41, and (2) follow the recommendations of NACE 1
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).
SP0169-2007.
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.
2 Q.
17      Q. Do you have any other comments regarding cathodic 18 protection?
Do you agree with Entergys experts assertion that 3
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
cathodic protection is only warranted when coating has degraded 4
and when the metallic surface of the piping is exposed? (Entergy 5
Testimony Q61/A61).
6 A.
No. Since any inspection program will only uncover a 7
small fraction of potential sites where coating damage has 8
occurred, there is no way to know where coating damage has 9
occurred that will expose sections of bare steel pipe. Without 10 knowing the extent of coating degradation or coating damage 11 there is no way to assess the efficacy of cathodic protection 12 after damage has been discovered. However, the judicious 13 installation, operation, and maintenance of a cathodic 14 protection system to the buried piping system will have the 15 effect of completely arresting any future corrosion damage.
16 Q.
Do you have any other comments regarding cathodic 17 protection?
18 A.
Entergy has experience with cathodic protection. At 19 one time the steel sections of the dock were cathodically 20 protected although it is not clear if that system is still in 21 operation. Entergy has also installed a limited cathodic 22 protection system in the vicinity of the city water lines 23


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.
Rebuttal Testimony of David J. Duquette Contention NYS-5 13 (Entergy Testimony, A119(a)). It should not be a major exercise 1
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?
to expand the existing cathodic protection system to the piping 2
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
under consideration in Contention NYS-5.
3 Q.
NRC experts note that Entergys aging management 4
program does not commit to meeting NACE standards, which call 5
for cathodic protection, but that Entergy has compensated for 6
this by requiring more frequent inspections. NRC Staff Testimony 7
A29. In your professional judgment, do an increased number of 8
inspections sufficiently make up for the absence of cathodic 9
protection in buried pipes and tanks?
10 A.
No. An increased number of inspections will allow the 11 examination of more sites, but the total amount of piping that 12 will be excavated and inspected will still be much less than the 13 extent of the entire buried piping system. While the increased 14 number of inspections may statistically improve the possibility 15 of discovering coating and/or metal damage, the undetected areas 16 will still dominate the population. It is especially important 17 to note that the corrosiveness of the soil at IPEC is quite 18 variable near the surface, while little is known about the 19 quality of the soil at the depth of the piping. The incident at 20 Indian Point where backfill had damaged the coating on the 21 piping, resulting in corrosion of the pipe, is an example of the 22 difficulty in performing a three dimensional analysis of soil 23


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.
Rebuttal Testimony of David J. Duquette Contention NYS-5 14 conditions at any buried piping site. Poor backfill, or other 1
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.
aggressive conditions at the piping horizon can only be poorly 2
10      Q. NRC Staffs experts explain that the number of 11 inspections Entergy proposes is consistent with the Draft ISG.
correlated with the chemical composition and corrosivity of soil 3
12 NRC Staff Testimony A42. Do you agree with that statement?
at the surface.
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.
4 And regarding the increased number of inspections, it is 5
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.
still not clear what the criteria will be for site selection, 6
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
where the inspections will be done, specifically how often they 7
will be done, and how quickly future inspections will take place 8
if a problem is found.
9 Q.
NRC Staffs experts explain that the number of 10 inspections Entergy proposes is consistent with the Draft ISG.
11 NRC Staff Testimony A42. Do you agree with that statement?
12 A.
No. One merely has to read the Draft ISG to come to 13 the conclusion that Entergys inspections do not follow the 14 guidelines of the ISG or of NACE SP0169-2007, or AMP XI.M41.
15 Each of those documents cites the necessity of justification if 16 cathodic protection is not utilized. Increased frequency of 17 inspections does not replace the requirement for cathodic 18 protection, and certainly does not qualify as justification to 19 ignore the considerable benefits of cathodic protection.
20 Q.
Entergys experts explain that Entergy has gathered 21 significant insights into the condition of IPEC buried pipes 22 and their coatings through direct visual examinations of 23


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?
Rebuttal Testimony of David J. Duquette Contention NYS-5 15 excavated piping and indirect (e.g., APEC, guided-wave testing) 1 examinations performed to date. Entergy Testimony, A34. In 2
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.
your opinion, is guidedwave testing a reliable inspection 3
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 immediately after a through-wall 12 failure, that was generated from external corrosion. The 13 technique indicated an 85% loss of wall thickness but did not 14 identify through-wall failure.
method?
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?
4 A.
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 Rebuttal Testimony of David J. Duquette Contention NYS-5 15
No, and neither NACE nor the NRC Staff think it is 5
either. Even the document on which the NRC Staff relies so 6
heavily, the Draft ISG, states that guided wave inspections do 7
not meet the intent of the paragraph requiring inspections.
8 Moreover, on this particular site, guided-wave technology was 9
not effective. Guided-wave technology was used on the 10 condensate storage return line immediately after a through-wall 11 failure, that was generated from external corrosion. The 12 technique indicated an 85% loss of wall thickness but did not 13 identify through-wall failure.
14 Q.
Entergys experts indicate that available data do 15 not indicate that soil surrounding in-scope buried piping at 16 IPEC is corrosive. (Entergy Testimony, Q83/A83). Do you agree 17 with that statement?
18 A.
No. Entergys own consultants report indicated that 19 soil on the IPEC site was mildly to moderately corrosive. I 20 discussed this report in my initial testimony. Corrosive is 21 corrosive; soil conditions either are or are not corrosive. To 22


1 say that moderately corrosive soil is not corrosive is 2 inaccurate and misleading.
Rebuttal Testimony of David J. Duquette Contention NYS-5 16 say that moderately corrosive soil is not corrosive is 1
3      Q. Do you agree with the definition of failure offered 4 by Entergy and NRC Staff?
inaccurate and misleading.
5      A. Absolutely not. Entergy offers an overly narrow 6 definition of a piping failure, and NRC Staff does not offer its 7 own definition but simply adopts Entergys. Entergy defines the 8 function of a pipe as maintaining a pressure boundary. Entergy 9 Testimony at Answer 94. The function of piping and of tanks is 10 not only to maintain pressure, but to contain the fluids that 11 either flow or are stored in them. Piping systems that contain, 12 or can contain, potentially toxic materials, by definition, fail 13 if the toxic material is released to the environment. For 14 example, there are holding tanks at Hanford, Washington, that 15 contain highly radioactive liquids, that are currently leaking, 16 and the effluent will eventually reach the Columbia River 17 watershed. The State of Washington and the surrounding 18 population certainly consider the leaking of highly radioactive 19 liquids to be failure of the tanks.
2 Q.
20      In some cases small perforations on pipes such as corrosion 21 induced pits can even be considered a more serious failure of a 22 piping system than complete failure of the pressure boundary. A 23 simple consideration of Bernoullis equations indicates that Rebuttal Testimony of David J. Duquette Contention NYS-5 16
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


1 liquids under pressure will have an increased velocity if the 2 exit orifice in a pipe has a smaller diameter than the pipe 3 itself. This increase in velocity from the exit orifice (a pit 4 or local perforation) may actually result in fluids reaching the 5 surface more rapidly than if the pressure barrier is completely 6 compromised.
Rebuttal Testimony of David J. Duquette Contention NYS-5 17 liquids under pressure will have an increased velocity if the 1
7      Q. Entergy indicates that the piping at issue in this 8 contention is a relatively small subset of the piping managed 9 by Entergys aging management program. Entergy Statement of 10 Position at 22. Do you believe it is impractical, as Entergy 11 asserts, to excavate all in-scope buried piping?
exit orifice in a pipe has a smaller diameter than the pipe 2
12      A. Yes, I agree. However, there is no need to excavate 13 all of the buried piping. The application of a well designed, 14 properly operated, and adequately maintained cathodic protection 15 system will effectively arrest any corrosion that may now exist.
itself. This increase in velocity from the exit orifice (a pit 3
16 It will also prevent further corrosion from initiating, thus 17 effectively obviating the need for complete excavation of the 18 buried piping systems.
or local perforation) may actually result in fluids reaching the 4
19      Q. Do you agree with the NRC Staff expert Mr. Holstons 20 assertion that a leak (whether radioactive or non-radioactive) 21 from a piping system does not degrade the ability of a piping 22 system to perform its CLB pressure boundary function unless the 23 leak is very substantial.? (NRC Staff Testimony, A19)
surface more rapidly than if the pressure barrier is completely 5
Rebuttal Testimony of David J. Duquette Contention NYS-5 17
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) 23


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.
Rebuttal Testimony of David J. Duquette Contention NYS-5 18 A.
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?
Mr. Holston is correct in that a leak does not 1
15      A. No. I dont understand Mr. Holstons opinion except 16 that he appears to believe that leaks are acceptable. I also 17 dont understand how Mr. Holston has arrived at the conclusion 18 that leaks can be managed without some consideration of the 19 conditions of the pipe wall conditions.
necessarily degrade the ability of a piping system to perform as 2
20      Q. Entergys experts state that you did not take into 21 account the specific program documents and procedures that are 22 being used to implement the aging management program when you 23 stated that the program was conceptual and aspirational in Rebuttal Testimony of David J. Duquette Contention NYS-5 18
a pressure barrier. However, as I have stated, maintaining a 3
pressure barrier is only one function of a piping system. The 4
second, and perhaps more important function for piping systems 5
such as those at IPEC that are not under high pressure, is to 6
contain the fluid in the system. If the piping cannot perform 7
that function it has, de facto, failed.
8 Q.
NRC Staffs expert Mr. Holston points out that Staff 9
guidance does not recommend a baseline inspection, baseline 10 piping wall conditions, or determination of corrosion rates, and 11 that such baseline and corrosion rate analyses are not necessary 12 to adequately manage leaks. NRC Staff Testimony A33. Do you 13 agree with those statements?
14 A.
No. I dont understand Mr. Holstons opinion except 15 that he appears to believe that leaks are acceptable. I also 16 dont understand how Mr. Holston has arrived at the conclusion 17 that leaks can be managed without some consideration of the 18 conditions of the pipe wall conditions.
19 Q.
Entergys experts state that you did not take into 20 account the specific program documents and procedures that are 21 being used to implement the aging management program when you 22 stated that the program was conceptual and aspirational in 23


1 nature. Entergy Testimony Q88/A88. What is your response to 2 that?
Rebuttal Testimony of David J. Duquette Contention NYS-5 19 nature. Entergy Testimony Q88/A88. What is your response to 1
3      A. Entergys experts are not correct. I did take these 4 program documents and procedures into account, and I generally 5 support the details within them - my problem stems from the fact 6 that Entergys proposed aging management program contains 7 virtually none of the details found within these documents.
that?
8 Accordingly, any requirements contained within the proposed 9 program that are not incorporated into the plants license or 10 UFSAR are unenforceable by the NRC and can be changed at any 11 time without NRC notice, as the NRCs expert Mr. Holston has 12 admitted in A.47 of his testimony. The details found in these 13 programs need to be incorporated into the aging management 14 program to which Entergy is committed, and then into the 15 operating license itself. Of even greater concern is that even 16 these expanded, albeit unenforceable, plans by Entergy ignore 17 implementation of AMP XI.41, the issuance of the ISG and the 18 NACE basis for the ISG. The ISG is based on industry 19 experience, perhaps the most important consideration in good 20 engineering practice and yet Entergy is disregarding it.
2 A.
21      Q. Entergys experts have also asserted that you 22 misunderstand the applicable program documentation as to the 23 timing of inspections, and indicate that Entergy will perform 20 Rebuttal Testimony of David J. Duquette Contention NYS-5 19
Entergys experts are not correct. I did take these 3
program documents and procedures into account, and I generally 4
support the details within them - my problem stems from the fact 5
that Entergys proposed aging management program contains 6
virtually none of the details found within these documents.
7 Accordingly, any requirements contained within the proposed 8
program that are not incorporated into the plants license or 9
UFSAR are unenforceable by the NRC and can be changed at any 10 time without NRC notice, as the NRCs expert Mr. Holston has 11 admitted in A.47 of his testimony. The details found in these 12 programs need to be incorporated into the aging management 13 program to which Entergy is committed, and then into the 14 operating license itself. Of even greater concern is that even 15 these expanded, albeit unenforceable, plans by Entergy ignore 16 implementation of AMP XI.41, the issuance of the ISG and the 17 NACE basis for the ISG. The ISG is based on industry 18 experience, perhaps the most important consideration in good 19 engineering practice and yet Entergy is disregarding it.
20 Q.
Entergys experts have also asserted that you 21 misunderstand the applicable program documentation as to the 22 timing of inspections, and indicate that Entergy will perform 20 23


1 visual inspections for IP2 and 14 direct visual inspections for 2 IP3 before the period of extended operation, and 14 direct 3 visual inspections for IP2 and 16 direct visual inspections for 4 IP3 during each 10-year interval of the period of extended 5 operation. Does this explanation satisfy you?
Rebuttal Testimony of David J. Duquette Contention NYS-5 20 visual inspections for IP2 and 14 direct visual inspections for 1
6      A. No. Entergys experts have not addressed the where 7 and when. They have not explained the specific criteria for 8 site selection, where the inspections will take place, or when 9 they will take place (for example, will they do all 14 10 inspections of IP2 in year five? year nine? start with year 1?).
IP3 before the period of extended operation, and 14 direct 2
11 This remains an open issue for me because in the past, Entergy 12 claims that they had performed a presumably careful inspection 13 of part of the CST line (according to their criteria), and the 14 line failed in a place other than that which was inspected. The 15 where and when is critical here to understanding the efficacy 16 of the proposed aging management plan. Entergys experts do not 17 indicate in their testimony why these numbers were chosen. I 18 agree that, if NRC does not require compliance with AMP XI.M41 19 and the ISG, more frequent inspections will be needed, but how 20 many more and at what intervals?   Entergys experts have not 21 answered these questions such that my position on this issue has 22 been resolved. The very nature of a spot inspection program 23 that can only be limited to specific sites is, by its very Rebuttal Testimony of David J. Duquette Contention NYS-5 20
visual inspections for IP2 and 16 direct visual inspections for 3
IP3 during each 10-year interval of the period of extended 4
operation. Does this explanation satisfy you?
5 A.
No. Entergys experts have not addressed the where 6
and when. They have not explained the specific criteria for 7
site selection, where the inspections will take place, or when 8
they will take place (for example, will they do all 14 9
inspections of IP2 in year five? year nine? start with year 1?).
10 This remains an open issue for me because in the past, Entergy 11 claims that they had performed a presumably careful inspection 12 of part of the CST line (according to their criteria), and the 13 line failed in a place other than that which was inspected. The 14 where and when is critical here to understanding the efficacy 15 of the proposed aging management plan. Entergys experts do not 16 indicate in their testimony why these numbers were chosen. I 17 agree that, if NRC does not require compliance with AMP XI.M41 18 and the ISG, more frequent inspections will be needed, but how 19 many more and at what intervals? Entergys experts have not 20 answered these questions such that my position on this issue has 21 been resolved. The very nature of a spot inspection program 22 that can only be limited to specific sites is, by its very 23


1 nature, flawed, as witnessed by the lack of ability to predict 2 the corrosion failure of the CST line.
Rebuttal Testimony of David J. Duquette Contention NYS-5 21 nature, flawed, as witnessed by the lack of ability to predict 1
3      Q. Have you now completed your rebuttal testimony 4 regarding Contention NYS-5?
the corrosion failure of the CST line.
5      A. Yes. However, I retain the ability to offer further 6 testimony if new information is provided.
2 Q.
7      I have reviewed all the exhibits referenced herein. True 8 and accurate copies of documents not attached to my initial 9 testimony are attached here.
Have you now completed your rebuttal testimony 3
Rebuttal Testimony of David J. Duquette Contention NYS-5 21
regarding Contention NYS-5?
4 A.
Yes. However, I retain the ability to offer further 5
testimony if new information is provided.
6 I have reviewed all the exhibits referenced herein. True 7
and accurate copies of documents not attached to my initial 8
testimony are attached here.
9


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.           October 5, 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.
Rebuttal Testimony of David J. Duquette Contention NYS-5 22 UNITED STATES 1
Executed in Accord with 10 C.F.R. § 2.304(d)
NUCLEAR REGULATORY COMMISSION 2
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 3
-----------------------------------x 4
In re:
Docket Nos. 50-247-LR; 50-286-LR 5
License Renewal Application Submitted by ASLBP No. 07-858-03-LR-BD01 6
Entergy Nuclear Indian Point 2, LLC, DPR-26, DPR-64 7
Entergy Nuclear Indian Point 3, LLC, and 8
Entergy Nuclear Operations, Inc.
October 5, 2012 9
-----------------------------------x 10 DECLARATION OF DAVID J. DUQUETTE 11 I, David J. Duquette, do hereby declare under penalty of 12 perjury that my statements in the foregoing testimony and my 13 statement of professional qualifications are true and correct to 14 the best of my knowledge and belief.
15 Executed in Accord with 10 C.F.R. § 2.304(d)
David J. Duquette, Ph.D.
David J. Duquette, Ph.D.
Materials Engineering Consulting Services 4 North Lane Loudonville, New York 12211 Tel: 518 276 6490 Fax: 518 462 1206 Email: duqued@rpi.edu October 5, 2012 Rebuttal Testimony of David J. Duquette Contention NYS-5 22}}
Materials Engineering Consulting Services 4 North Lane Loudonville, New York 12211 Tel: 518 276 6490 Fax: 518 462 1206 Email: duqued@rpi.edu October 5, 2012}}

Latest revision as of 20:20, 11 January 2025

Official Exhibit - NYSR20399-00-BD01 - Prefiled Rebuttal Testimony of Dr. David J. Duquette in Support of Contention NYS-5 (Jun. 6, 2012)
ML12340A802
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 10/05/2012
From: Duquette D
Materials Engineering Consulting Services
To:
Atomic Safety and Licensing Board Panel
SECY RAS
References
RAS 23635, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01
Download: ML12340A802 (22)
v • d • e


Text

Rebuttal Testimony of David J. Duquette Contention NYS-5 1

UNITED STATES 1

NUCLEAR REGULATORY COMMISSION 2

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 3

x 4

In re:

Docket Nos. 50-247-LR; 50-286-LR 5

License Renewal Application Submitted by ASLBP No. 07-858-03-LR-BD01 6

Entergy Nuclear Indian Point 2, LLC, DPR-26, DPR-64 7

Entergy Nuclear Indian Point 3, LLC, and 8

Entergy Nuclear Operations, Inc.

October 5, 2012 9

x 10 PRE-FILED WRITTEN REBUTTAL TESTIMONY OF 11 DR. DAVID J. DUQUETTE 12 REGARDING CONTENTION NYS-5 13 On behalf of the State of New York (NYS or the State),

14 the Office of the Attorney General hereby submits the following 15 rebuttal testimony by Dr. David J. Duquette, Ph.D., regarding 16 Contention NYS-5.

17 Q.

What documents did you review in preparation for this 18 rebuttal testimony?

19 A.

I read Entergys Statement of Position Regarding 20 Contention NYS-5 (Buried Piping and Tanks); the Testimony of 21 Entergy Witnesses Alan Cox, Ted Ivy, Nelson Acevedo, Robert Lee, 22 Stephen Biagiotti, and Jon Cavallo Concerning Contention NYS-5 23 United States Nuclear Regulatory Commission Official Hearing Exhibit In the Matter of:

Entergy Nuclear Operations, Inc.

(Indian Point Nuclear Generating Units 2 and 3)

ASLBP #: 07-858-03-LR-BD01 Docket #: 05000247 l 05000286 Exhibit #:

Identified:

Admitted:

Withdrawn:

Rejected:

Stricken:

Other:

NYSR20399-00-BD01 10/17/2012 10/17/2012 NYSR20399 Revised: October 16, 2012

Rebuttal Testimony of David J. Duquette Contention NYS-5 2

(Buried Piping and Tanks) and the exhibits thereto (Entergy 1

Testimony). I also read NRC Staffs Statement of Position on 2

Contention NYS-5 (Buried Pipes and Tanks) and the Testimony of 3

Kimberly J. Green and William C. Holston Concerning Contention 4

NYS-5 (Buried Pipes And Tanks) and the exhibits thereto (NRC 5

Staff Testimony). None of those documents have changed my 6

opinions related to the management of the buried pipelines at 7

IPEC.

8 Q.

As an initial matter, Entergy states on page 6 of its 9

Statement of Position that you appear to have no prior 10 experience with respect to the aging management of buried piping 11 at a nuclear power plant. Is this correct?

12 A.

No.

13 Q.

Please describe your experience with respect to the 14 aging management of buried piping at a nuclear power plant.

15 A.

My experience with corrosion issues at nuclear plants 16 includes consultation at Three Mile Island (TMI-1 and TMI-2),

17 Diablo Canyon, all of the pressurized water reactors and boiling 18 water reactors formerly operated by Commonwealth Edison (these 19 include Byron, LaSalle, Braidwood, Dresden, Quad Cities, 20 Clinton), and Seabrook. I have served on EPRI panels for 21 corrosion control in nuclear power systems, and I was funded by 22 EPRI for 5 years and by the Department of Energy for 11 years 23

Rebuttal Testimony of David J. Duquette Contention NYS-5 3

for corrosion research in nuclear systems. I have supervised 1

Ph.D. students performing research on nuclear systems for U.S.

2 Navy applications at the Knolls Atomic Power Laboratory. I have 3

also had personal tours of numerous reactors because of my 4

service on the Nuclear Waste Technical Review Board including 5

Dresden, Savannah River, Hanford, several French plants and 6

plants in England, Germany, Spain, and Argentina. In each of 7

those tours I discussed high level aspects of technical 8

management of the facilities, including aging and maintenance of 9

the infrastructures, in detail. As indicated below, I have also 10 had considerable experience in the management of corrosion of 11 underground piping systems.

12 A.

Why was this information not included on the CV you 13 provided in your earlier testimony?

14 A.

I provided my academic CV with my prior testimony, 15 which does not include these or other consulting engagements.

16 It is my opinion that my academic CV, without these engagements, 17 qualifies me as an expert in the matter of NYS-5 (Buried Pipes 18 and Tanks). However, I have also had considerable experience in 19 assessing corrosion of numerous structures including other 20 buried structures such as oil and natural gas lines, buried 21 tanks and other underground infrastructure. Any of these 22 experiences would have qualified me as an expert in the area of 23

Rebuttal Testimony of David J. Duquette Contention NYS-5 4

buried metallic components. There is nothing specifically 1

nuclear about the buried pipes at Indian Point.

2 Q.

In response to your position that Entergy should 3

assume that pipes were defectively coated and that pipes were 4

improperly backfilled, Entergy emphasizes that the 5

specifications in place at the time of plant construction (that 6

is, in the 1960s, before Entergy owned the facility) contained 7

procedures for installing and inspecting coatings installed by 8

the piping manufacturer (Entergy Testimony, Q65-71). Have you 9

seen any evidence from Entergys disclosures that indicate 10 whether those specifications were in fact met?

11 A.

No. Entergy has provided the specifications, but in 12 the material I reviewed, I have not seen any indication that 13 they were met.

14 Q.

Do you have reason to believe the specifications were 15 not met at the time of construction?

16 A.

Yes. The corrosion problem Entergy identified in 2009 17 at the Indian Point Unit 2 condensate storage tank return line 18 was caused by improper backfill, which in turn resulted in a 19 coating failure. This is irrefutable evidence that the 20 specifications were not met 100% of the time at this site at the 21 time of construction.

22 Q.

NRCs experts state that follow-up inspections in 2009 23

Rebuttal Testimony of David J. Duquette Contention NYS-5 5

on 28 feet of city water line and 8 feet of fire protection line 1

revealed no coating defects or potentially damaging backfill 2

(NRC Staff Testimony, A28). Does this alleviate your concern?

3 A.

No. The admitted use of improper backfill leading to 4

corrosion of such severity that the pipe was compromised 5

suggests that there are other sites that may have been 6

inadequately or improperly assessed. Since at least one site 7

was either overlooked or improperly characterized, barring 8

complete inspection of all of the underground piping, there can 9

be no assurance that other areas have not been improperly 10 characterized. A sampling of 28 feet of city water line or of 11 only 8 feet of fire protection line hardly constitutes a 12 significant fraction of the entire underground piping system at 13 IPEC. There is no known method for assessing the depth of 14 localized corrosion at any other piping location at the site 15 based on these limited inspections. For example, given the 16 level of inspection and analysis that has been performed, there 17 is no way to know if there are sites where corrosion may have 18 penetrated though 90% of the pipe wall. To reiterate some of my 19 previous testimony, the use of a remote inspection technique, 20 guided wave technology, failed to detect the extent of corrosion 21 damage at the leak location at IPEC.

22

Rebuttal Testimony of David J. Duquette Contention NYS-5 6

Q.

The NRC Staff takes the position that although the 1

Applicants in-scope buried pipe plant-specific operating 2

experience has revealed locations where coatings have been 3

damaged, the current licensing basis functions of the affected 4

systems were maintained (NRC Staff Testimony, A30). Does this 5

alleviate your concern?

6 A.

No. The fact that a failure has not yet occurred is 7

no indication that a failure will not occur in the renewed 8

licensing period. It has been stated that the function of the 9

buried piping system is to maintain a pressure barrier. Staff 10 Testimony at p. 25. However, I disagree with that opinion.

11 Leaking of radioactive fluids, in my opinion constitutes failure 12 of the system in a pipe, that, like all safety related pipes 13 carrying radioactive fluid, was not supposed to fail.

14 Accordingly, if a failure has already occurred, independent of 15 the root cause of that failure, absent a comprehensive 16 inspection, or protection of the system, there can be no 17 guarantee that future unpredictable failures will not occur in 18 other safety related piping.

19 Q.

NRC Staff Testimony relies heavily on a document 20 called the Interim Staff Guidance, LR-ISG-2011-03, Changes to 21 The Generic Aging Lessons Learned (GALL) Report Aging Management 22 Program XI.M41 Buried and Underground Piping and Tanks 23

Rebuttal Testimony of David J. Duquette Contention NYS-5 7

(Exhibit NRC000019), or the Draft ISG. You did not mention 1

this document in your testimony; was it available to you as you 2

were preparing your testimony?

3 A.

No. This document was released in 2012 as I 4

understand it. I had not seen it before I read the Staffs 5

experts testimony.

6 Q.

Have you read the Draft ISG?

7 A.

Yes.

8 Q.

Does it change your testimony in any way?

9 A.

Rather than changing my testimony, the Draft ISG 10 further provides strong support for the portion of my testimony 11 addressing the need for cathodic protection. The Draft ISG 12 makes clear that, contrary to NRC and Entergys expert 13 testimony, failure to provide cathodic protection must be 14 justified, which has not been done by Entergy for Indian Point.

15 The Draft ISG states that an exception must be stated and 16 justified if the basis for not providing cathodic protection is 17 other than demonstrating that external corrosion control (i.e.

18 cathodic protection and coatings) is not required, or 19 demonstrating that installation, operation, or surveillance of a 20 cathodic protection system is not practical. Entergy has not 21 demonstrated that cathodic protection of IPECs buried piping is 22 not required, nor have they provided evidence that installation, 23

Rebuttal Testimony of David J. Duquette Contention NYS-5 8

operation, or surveillance are not practical. In fact, it is my 1

opinion that proper operation and surveillance, much of which 2

can be done remotely, is far more practical that the requirement 3

to periodically excavate, inspect and repair meaningful sections 4

of buried piping.

5 The Draft ISG completely supports my prior testimony 6

concerning the importance of cathodic protection at this plant.

7 The Draft ISG requires a plant owner to take into consideration 8

factors including corrosivity of soil and backfill conditions in 9

assessing whether or not the absence of cathodic protection is 10 justified. As I noted in my initial testimony, at Indian Point, 11 we have corrosive soil and problematic backfill conditions.

12 Generally, I believe the Draft ISG supports nearly 13 everything I said NRC should require Entergy to do: (1) follow 14 the dictates of NUREG-1801,Section XI.M41, and (2) follow the 15 recommendations of NACE SP0169-2007.

16 Q.

Do you have any other observations about the Draft 17 ISG?

18 A.

Yes. I disagree with NRC Staffs experts statements 19 in footnote 3 in which they said that the Staff evaluated the 20 Applicants AMP against key elements of AMP XI.M41 and the Draft 21 ISG for AMP XI.M41 and concluded that Entergys AMP is adequate 22 to manage the applicable aging effects to ensure that buried 23

Rebuttal Testimony of David J. Duquette Contention NYS-5 9

piping and tanks will perform their current licensing basis 1

functions. To reiterate, the Draft ISG requires the following:

2



The failure to provide cathodic protection in 3

accordance with Table 2a must be justified in the LRA.

4 5



An exception must be stated and justified if the basis 6

for not providing cathodic protection is other than 7

demonstrating that external corrosion control (i.e.,

8 cathodic protection and coatings) is not required or 9

demonstrating that installation, operation, or 10 surveillance of a cathodic protection system is not 11 practical.

12 13



The applicant must demonstrate, through the submission 14 of a study, the impracticality of installing or 15 operating a cathodic protection system. This study 16 should be conducted by a competent person as defined 17 in NACE SP 0169-2007, Section 1.3, Introduction, who 18 is knowledgeable in the design, installation, and 19 operation of cathodic protection systems. The study 20 should be submitted with the LRA.

21 22



The applicant must conduct a 20-year search of 23 operating experience for evidence of adverse 24 conditions as described in Section 4.f., Adverse 25 Indications, of Appendix A of this Draft ISG.

26 27 I have seen no evidence that Entergy has performed any of the 28 above. I have not seen any justification for the lack of 29 cathodic protection at Indian Point, and I have not seen any 30 study showing the impracticality of installing or operating a 31 cathodic protection system or that cathodic protection is not 32 necessary. Finally, I have seen no evidence of the 20 year 33 search of operating experience for evidence of adverse 34

Rebuttal Testimony of David J. Duquette Contention NYS-5 10 conditions, or for evidence that no adverse conditions exist at 1

IPEC.

2 Page one of the Draft ISG states that the ISG is based on 3

industry operating experience, but the NRC experts admit that 4

Entergy isnt required to meet the requirements of the revised 5

GALL report, or the Draft ISG, in footnote 3. It is poor 6

engineering practice, in my expert opinion, to be aware of 7

industry operating experience and resultant recommendations and 8

not incorporate them into current operating procedures. The 9

very nature of engineering practice is to take advantage of 10 observations and experience to improve operating procedures, 11 especially from a safety perspective.

12 The Draft ISG also states: Given that the potential for 13 piping degradation increases with time, the inspection 14 quantities for some materials increase throughout the 30-year 15 period starting 10 years prior to entering the period of 16 extended operation. I have not seen any indication that 17 Entergys AMP proposes to do this.

18 Finally, in a section entitled Cathodic Protection Survey 19 Acceptance Criteria, on page 5, the Draft ISG states that 20 Based on staff findings during AMP audits, multiple 21 sites do not have an upper limit on cathodic 22 protection pipe-to-soil potential. If the cathodic 23 protection pipe-to-soil values are too high, coating 24 damage can occur. The staff deleted the general 25

Rebuttal Testimony of David J. Duquette Contention NYS-5 11 reference to the NACE standards for the acceptance 1

criteria and incorporated the NACE SP0169-2007 2

specific cathodic protection survey acceptance 3

criteria into the AMP.

4 5

The NACE SP0169-2007 specific cathodic protection survey 6

acceptance criteria were established in 2007. However, as I 7

noted in my initial testimony, Entergy has not and apparently 8

will not commit to following NACE guidelines. The NRC Staff 9

certainly were aware of NACE SP0169-2007 and incorporated it 10 into the ISG document as the basis for changes to the generic 11 aging lessons learned (GALL) report revision 2, Aging Management 12 Program XI.M41 Buried and Underground Piping and Tanks. The 13 criteria should have been implemented at operating plants and 14 certainly incorporated into LRAs. Accordingly, there is no 15 excuse for the NRC to fail to require that Entergy meet those 16 guidelines now that the NRC Staff has incorporated them into its 17 Draft ISG.

18 Q.

In light of your position that proper specifications 19 were not followed at Indian Point, what additional steps do you 20 believe Entergy should be taking that it has not committed to 21 take at Indian Point?

22 A.

As I have stated, I believe that the NRC should 23 require Entergy to (1) follow the dictates of NUREG-1801, 24

Rebuttal Testimony of David J. Duquette Contention NYS-5 12 Section XI.M41, and (2) follow the recommendations of NACE 1

SP0169-2007.

2 Q.

Do you agree with Entergys experts assertion that 3

cathodic protection is only warranted when coating has degraded 4

and when the metallic surface of the piping is exposed? (Entergy 5

Testimony Q61/A61).

6 A.

No. Since any inspection program will only uncover a 7

small fraction of potential sites where coating damage has 8

occurred, there is no way to know where coating damage has 9

occurred that will expose sections of bare steel pipe. Without 10 knowing the extent of coating degradation or coating damage 11 there is no way to assess the efficacy of cathodic protection 12 after damage has been discovered. However, the judicious 13 installation, operation, and maintenance of a cathodic 14 protection system to the buried piping system will have the 15 effect of completely arresting any future corrosion damage.

16 Q.

Do you have any other comments regarding cathodic 17 protection?

18 A.

Entergy has experience with cathodic protection. At 19 one time the steel sections of the dock were cathodically 20 protected although it is not clear if that system is still in 21 operation. Entergy has also installed a limited cathodic 22 protection system in the vicinity of the city water lines 23

Rebuttal Testimony of David J. Duquette Contention NYS-5 13 (Entergy Testimony, A119(a)). It should not be a major exercise 1

to expand the existing cathodic protection system to the piping 2

under consideration in Contention NYS-5.

3 Q.

NRC experts note that Entergys aging management 4

program does not commit to meeting NACE standards, which call 5

for cathodic protection, but that Entergy has compensated for 6

this by requiring more frequent inspections. NRC Staff Testimony 7

A29. In your professional judgment, do an increased number of 8

inspections sufficiently make up for the absence of cathodic 9

protection in buried pipes and tanks?

10 A.

No. An increased number of inspections will allow the 11 examination of more sites, but the total amount of piping that 12 will be excavated and inspected will still be much less than the 13 extent of the entire buried piping system. While the increased 14 number of inspections may statistically improve the possibility 15 of discovering coating and/or metal damage, the undetected areas 16 will still dominate the population. It is especially important 17 to note that the corrosiveness of the soil at IPEC is quite 18 variable near the surface, while little is known about the 19 quality of the soil at the depth of the piping. The incident at 20 Indian Point where backfill had damaged the coating on the 21 piping, resulting in corrosion of the pipe, is an example of the 22 difficulty in performing a three dimensional analysis of soil 23

Rebuttal Testimony of David J. Duquette Contention NYS-5 14 conditions at any buried piping site. Poor backfill, or other 1

aggressive conditions at the piping horizon can only be poorly 2

correlated with the chemical composition and corrosivity of soil 3

at the surface.

4 And regarding the increased number of inspections, it is 5

still not clear what the criteria will be for site selection, 6

where the inspections will be done, specifically how often they 7

will be done, and how quickly future inspections will take place 8

if a problem is found.

9 Q.

NRC Staffs experts explain that the number of 10 inspections Entergy proposes is consistent with the Draft ISG.

11 NRC Staff Testimony A42. Do you agree with that statement?

12 A.

No. One merely has to read the Draft ISG to come to 13 the conclusion that Entergys inspections do not follow the 14 guidelines of the ISG or of NACE SP0169-2007, or AMP XI.M41.

15 Each of those documents cites the necessity of justification if 16 cathodic protection is not utilized. Increased frequency of 17 inspections does not replace the requirement for cathodic 18 protection, and certainly does not qualify as justification to 19 ignore the considerable benefits of cathodic protection.

20 Q.

Entergys experts explain that Entergy has gathered 21 significant insights into the condition of IPEC buried pipes 22 and their coatings through direct visual examinations of 23

Rebuttal Testimony of David J. Duquette Contention NYS-5 15 excavated piping and indirect (e.g., APEC, guided-wave testing) 1 examinations performed to date. Entergy Testimony, A34. In 2

your opinion, is guidedwave testing a reliable inspection 3

method?

4 A.

No, and neither NACE nor the NRC Staff think it is 5

either. Even the document on which the NRC Staff relies so 6

heavily, the Draft ISG, states that guided wave inspections do 7

not meet the intent of the paragraph requiring inspections.

8 Moreover, on this particular site, guided-wave technology was 9

not effective. Guided-wave technology was used on the 10 condensate storage return line immediately after a through-wall 11 failure, that was generated from external corrosion. The 12 technique indicated an 85% loss of wall thickness but did not 13 identify through-wall failure.

14 Q.

Entergys experts indicate that available data do 15 not indicate that soil surrounding in-scope buried piping at 16 IPEC is corrosive. (Entergy Testimony, Q83/A83). Do you agree 17 with that statement?

18 A.

No. Entergys own consultants report indicated that 19 soil on the IPEC site was mildly to moderately corrosive. I 20 discussed this report in my initial testimony. Corrosive is 21 corrosive; soil conditions either are or are not corrosive. To 22

Rebuttal Testimony of David J. Duquette Contention NYS-5 16 say that moderately corrosive soil is not corrosive is 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

Rebuttal Testimony of David J. Duquette Contention NYS-5 17 liquids under pressure will have an increased velocity if the 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) 23

Rebuttal Testimony of David J. Duquette Contention NYS-5 18 A.

Mr. Holston is correct in that a leak does not 1

necessarily degrade the ability of a piping system to perform as 2

a pressure barrier. However, as I have stated, maintaining a 3

pressure barrier is only one function of a piping system. The 4

second, and perhaps more important function for piping systems 5

such as those at IPEC that are not under high pressure, is to 6

contain the fluid in the system. If the piping cannot perform 7

that function it has, de facto, failed.

8 Q.

NRC Staffs expert Mr. Holston points out that Staff 9

guidance does not recommend a baseline inspection, baseline 10 piping wall conditions, or determination of corrosion rates, and 11 that such baseline and corrosion rate analyses are not necessary 12 to adequately manage leaks. NRC Staff Testimony A33. Do you 13 agree with those statements?

14 A.

No. I dont understand Mr. Holstons opinion except 15 that he appears to believe that leaks are acceptable. I also 16 dont understand how Mr. Holston has arrived at the conclusion 17 that leaks can be managed without some consideration of the 18 conditions of the pipe wall conditions.

19 Q.

Entergys experts state that you did not take into 20 account the specific program documents and procedures that are 21 being used to implement the aging management program when you 22 stated that the program was conceptual and aspirational in 23

Rebuttal Testimony of David J. Duquette Contention NYS-5 19 nature. Entergy Testimony Q88/A88. What is your response to 1

that?

2 A.

Entergys experts are not correct. I did take these 3

program documents and procedures into account, and I generally 4

support the details within them - my problem stems from the fact 5

that Entergys proposed aging management program contains 6

virtually none of the details found within these documents.

7 Accordingly, any requirements contained within the proposed 8

program that are not incorporated into the plants license or 9

UFSAR are unenforceable by the NRC and can be changed at any 10 time without NRC notice, as the NRCs expert Mr. Holston has 11 admitted in A.47 of his testimony. The details found in these 12 programs need to be incorporated into the aging management 13 program to which Entergy is committed, and then into the 14 operating license itself. Of even greater concern is that even 15 these expanded, albeit unenforceable, plans by Entergy ignore 16 implementation of AMP XI.41, the issuance of the ISG and the 17 NACE basis for the ISG. The ISG is based on industry 18 experience, perhaps the most important consideration in good 19 engineering practice and yet Entergy is disregarding it.

20 Q.

Entergys experts have also asserted that you 21 misunderstand the applicable program documentation as to the 22 timing of inspections, and indicate that Entergy will perform 20 23

Rebuttal Testimony of David J. Duquette Contention NYS-5 20 visual inspections for IP2 and 14 direct visual inspections for 1

IP3 before the period of extended operation, and 14 direct 2

visual inspections for IP2 and 16 direct visual inspections for 3

IP3 during each 10-year interval of the period of extended 4

operation. Does this explanation satisfy you?

5 A.

No. Entergys experts have not addressed the where 6

and when. They have not explained the specific criteria for 7

site selection, where the inspections will take place, or when 8

they will take place (for example, will they do all 14 9

inspections of IP2 in year five? year nine? start with year 1?).

10 This remains an open issue for me because in the past, Entergy 11 claims that they had performed a presumably careful inspection 12 of part of the CST line (according to their criteria), and the 13 line failed in a place other than that which was inspected. The 14 where and when is critical here to understanding the efficacy 15 of the proposed aging management plan. Entergys experts do not 16 indicate in their testimony why these numbers were chosen. I 17 agree that, if NRC does not require compliance with AMP XI.M41 18 and the ISG, more frequent inspections will be needed, but how 19 many more and at what intervals? Entergys experts have not 20 answered these questions such that my position on this issue has 21 been resolved. The very nature of a spot inspection program 22 that can only be limited to specific sites is, by its very 23

Rebuttal Testimony of David J. Duquette Contention NYS-5 21 nature, flawed, as witnessed by the lack of ability to predict 1

the corrosion failure of the CST line.

2 Q.

Have you now completed your rebuttal testimony 3

regarding Contention NYS-5?

4 A.

Yes. However, I retain the ability to offer further 5

testimony if new information is provided.

6 I have reviewed all the exhibits referenced herein. True 7

and accurate copies of documents not attached to my initial 8

testimony are attached here.

9

Rebuttal Testimony of David J. Duquette Contention NYS-5 22 UNITED STATES 1

NUCLEAR REGULATORY COMMISSION 2

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 3

x 4

In re:

Docket Nos. 50-247-LR; 50-286-LR 5

License Renewal Application Submitted by ASLBP No. 07-858-03-LR-BD01 6

Entergy Nuclear Indian Point 2, LLC, DPR-26, DPR-64 7

Entergy Nuclear Indian Point 3, LLC, and 8

Entergy Nuclear Operations, Inc.

October 5, 2012 9

x 10 DECLARATION OF DAVID J. DUQUETTE 11 I, David J. Duquette, do hereby declare under penalty of 12 perjury that my statements in the foregoing testimony and my 13 statement of professional qualifications are true and correct to 14 the best of my knowledge and belief.

15 Executed in Accord with 10 C.F.R. § 2.304(d)

David J. Duquette, Ph.D.

Materials Engineering Consulting Services 4 North Lane Loudonville, New York 12211 Tel: 518 276 6490 Fax: 518 462 1206 Email: duqued@rpi.edu October 5, 2012

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