ML111010612

Watch Memorandum-Entergy's Incorrect and Misleading Information Regarding Proven Tests to Detect Cable Insulation Degradation

ML111010612
Person / Time
Site:	Pilgrim
Issue date:	04/11/2011
From:	Lampert M Pilgrim Watch
To:	Atomic Safety and Licensing Board Panel
SECY RAS
References
RAS 19900, 50-293-LR, ASLBP 06-848-02-LR
Download: ML111010612 (9)

Text

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of Docket # 50-293-LR Entergy Corporation Pilgrim Nuclear Power Station License Renewal Application April 11 2011 PILGRIM WATCH MEMORANDUM -ENTERGYS INCORRECT AND MISLEADING INFORMATION REGARDING PROVEN TESTS TO DETECT CABLE INSULATION DEGRADATION In this proceeding, Pilgrim Watch repeatedly said that there were no proven commercially available tests to detect cable insulation degradation.

At an April 6, 2011 Massachusetts General Court public hearing, Entergy said that there were no proven commercially available tests to detect cable insulation degradation, contradicting statements made in previous filings in this proceeding. The hearing was held by the Joint Committees of Environment, Natural Resources and Agriculture; Telecommunications, Utilities and Energy; Public Health; Public Safety and Homeland Security.

Specifically, the Joint Committees asked Entergys panel if there were proven tests to assess submerged electric cable degradation at Pilgrim Station. Mr. S.J. Bethay,

Director Nuclear Safety Assurance Pilgrim Station, responded for Entergys panel. He testified that there were no proven commercially available tests to detect cable insulation degradation; but when they became available, Pilgrim would use them. (Emphasis added)

Mr. Bethay was accompanied at the table for presenting to the Joint Committees by Entergys top leadership personnel including Michael Balduzzi, Rick Smith and Michael Slobodian. They did not contradict or qualify Mr. Bethays statement Entergys Previous Claims To The Contrary

1. In the Declaration Of Vincent Fallacara And Roger B. Rucker In Support Of Entergys Answer Opposing Pilgrim Watchs Request For Hearing On A New Contention (Feb 14, 2011) Vincent Fallacara, Director of Engineering at Pilgrim, said in regard to the adequacy of cable insulation test methods

12. Mr. Blanch challenges the adequacy of the cable insulation test methods called for by the AMP. He contends that there is no proven test that will provide assurance that cables and splices that have been submerged will function when called upon. He claims to rely on findings from the NRC, the Electric Power Research Institute (EPRI), Sandia National Laboratory (Sandia), and Brookhaven National Laboratory (Brookhaven). Blanch Affidavit ¶¶ 29, 32-35, 45-46. See also PW Request at 27.

13. These claims by Pilgrim Watch and Mr. Blanch are incorrectthere are many proven tests to determine the degradation of cable insulation from different aging mechanisms. Emphasis added.

2. In Entergys Answer Opposing Pilgrim Watch Request For Hearing On A New Contention Feb 14, 2011, section (a) Proven Tests for Cable Insulation Degradation, Entergy again disputed the lack of proven tests.

3. At the March 9, 2011 Plymouth hearing, Mr. Lewis, representing Entergy, said in his description of what the NRCs December 2010 Information Notice said:

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( licensees should do these type of tests that are capable of detecting degradation. (Transcript, pg., 881, lines 21-22, emphasis added). The clear implication was that there were tests capable of detecting degradation.

Conclusion Both Entergy and Pilgrim Watch now agree that there are no proven tests to detect cable insulation degradation.

Respectfully signed, Mary lampert (Signed Electronically)

Pilgrim Watch, pro se 148 Washington Street Duxbury, MA 02332 Tel. 781-934-0389 Email mary.lampert@comcast.net 3

ATTACHMENT Declaration Rebecca J. Chin (Please note that additional declarations may be provided, upon request)

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before The Atomic Safety And Licensing Board In the Matter of Docket # 50-293-LR Entergy Corporation Pilgrim Nuclear Power Station License Renewal Application April 11, 2011 Declaration Rebecca J. Chin I, Rebecca J. Chin, hereby declare under penalty of perjury that the following is true and correct.

I have been appointed by the Town of Duxbury Emergency Management Director to represent the town at the ASLB hearings regarding proceedings in Pilgrims license renewal application. I was present at the April 6, 2011 Massachusetts General Court public hearing held by the Joint Committees of Environment, Natural Resources and Agriculture; Telecommunications, Utilities and Energy; Public Health; Public Safety and Homeland Security in response to the ongoing nuclear reactor tragedy in Fukushima.

At the hearing, I heard Mr. S.J. Bethay, Entergy spokesperson, respond to a question from the committee panel. He said that there were no proven commercially available tests to detect cable insulation degradation; but when they became available, Pilgrim would use them. Mr. Bethay was accompanied at Entergys presentation table by other Entergy Pilgrim personnel including Michael Balduzzi, Rick Smith and Michael Slobodian. They did not contradict or qualify Mr. Bethays statement.

Rebecca J. Chin (Electonically signed) 31 DeerPath Trl North Duxbury, MA 02332 Tel. 781-837-0009 Email: rebeccajchin@hotmail.com

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before The Atomic Safety And Licensing Board In the Matter of Docket # 50-293-LR Entergy Corporation Pilgrim Nuclear Power Station License Renewal Application April 11, 2011 CERTIFICATE OF SERVICE I hereby certify that Pilgrim Watch Memorandum Regarding Entergys Incorrect &

Misleading Information Regarding Proven Tests To Detect Cable Insulation Degradation and Certiciate of Service were served April 11, 2011 in the above captioned proceeding to the following persons by the Electronic Information Exchange and complimentary copies sent via email to the service list Secretary of the Commission Administrative Judge Attn: Rulemakings and Adjudications Richard F. Cole Staff Atomic Safety and Licensing Board Mail Stop 0-16 C1 Mail Stop -T-3-F23 United States Nuclear Regulatory US NRC Commission Washington, DC 20555-0001 Office of Commission Appellate Administrative Judge Adjudication Ann Marshall Young, Chair Mail Stop 0-16 C1 Atomic Safety and Licensing Board United States Nuclear Regulatory Mail Stop - T-3 F23 Commission US NRC Washington, DC 20555-0001 Washington, DC 20555-0001 Atomic Safety and Licensing Board Administrative Judge Mail Stop T-3 F23 Paul B. Abramson United States Nuclear Regulatory Atomic Safety and Licensing Board Commission Mail Stop T-3 F23 Washington, DC 20555-0001 US NRC Washington, DC 20555-0001

U.S. Nuclear Regulatory Commission Mark Stankiewicz Office of Commission Appellate Town Manager, Town of Plymouth Adjudication 11 Lincoln Street Mail Stop: 0-16C1 Plymouth MA 02360 Washington, DC 20555-0001 U.S. Nuclear Regulatory Commission Sheila Slocum Hollis, Esq.

Office of General Counsel Town of Plymouth MA Mail Stop: 0-15 D21 Duane Morris, LLP Washington DC 20555-0001 505 9th Street, N.W. 1000 Susan L. Uttal, Esq. Washington D.C. 20004-2166 Andrea Jones, Esq.

Brian Harris, Esq. Richard R. MacDonald Michael Dreher, Esq. Town Manager, Town of Duxbury Brian Newell, Paralegal 878 Tremont Street Duxbury, MA 02332 U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Fire Chief & Director DEMA, Mail Stop: 011-F1 Town of Duxbury Washington, DC 20555-0001 688 Tremont Street P.O. Box 2824 Lisa Regner, Project Mgr. Plant Lic. Duxbury, MA 02331 Branch 1-1, Operator Reactor Licensing Washington, DC 20555-0001 Terence A. Burke, Esq.

Entergy Nuclear Paul A. Gaukler, Esq. Mail Stop M-ECH-62 David R. Lewis, Esq. Jackson, MS 39213 Jason B. Parker, Esq.

Pillsbury, Winthrop, Shaw, Pittman, Katherine Tucker, Esq.

LLP - 2300 N Street, N.W. Law Clerk, Atomic Safety and Licensing Washington, DC 20037-1128 Board Panel U.S. Nuclear Regulatory Commission Martha Coakley, Attorney General 11545 Rockville Pike, Mail Stop T3-E2a Matthew Brock, Assistant Attorney Rockville, MD 20852 General Commonwealth of Massachusetts Office of Attorney General One Ashburton Place Signed (electronically) by Boston, MA 02108 Mary Lampert Pilgrim Watch, pro se 148 Washington St.

Duxbury, MA 023332 Tel: 781-934-0389 Email: mary.lampert@comcast.net April 11,2011

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