ML110200267

Pilgrim Watch Request for Hearing on a New Contention: Inadequacy of Entergy'S Aging Management of Non-Environmentally Qualified (EQ) Inaccessible Cables (Splices) at Pilgrim Station

ML110200267
Person / Time
Site:	Pilgrim
Issue date:	01/20/2011
From:	Lampert M Pilgrim Watch
To:	Atomic Safety and Licensing Board Panel
SECY RAS
Shared Package
ML110200264	List: ML110200265 ML110200266 ML110200267 ML110200268
References
50-293-LR, ASLBP 06-848-02-LR, RAS 19453
Download: ML110200267 (72)

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 January 20, 2011 PILGRIM WATCH REQUEST FOR HEARING ON A NEW CONTENTION:

INADEQUACY OF ENTERGYS AGING MANAGEMENT OF NON-ENVIRONMENTALLY QUALIFIED (EQ) INACCESSIBLE CABLES (SPLICES)

AT PILGRIM STATION In accordance with 10 C.F.R § 2.309 (c)(1) Pilgrim Watch files a new technical/safety related contention supported by fact and expert testimony.1 The contention reads:

Entergys Aging Management Plan (as amended by Entergy on January 7, 2011) for non-environmentally qualified (EQ) inaccessible cables and cable splices at Pilgrim Station is insufficient to provide reasonable assurance that these cables will be in compliance with NRC Regulations and public health and safety shall be protected during license renewal.

1 Pilgrim Watch filed a Request for Hearing on a New Contention: Inadequacy of Entergys Aging Management of Non-EQ Inaccessible Cables (Splices) at Pilgrim Station December 13, 2010. It was based on new information that became available on December 3, 2010 when NRC Issued Information Notice 2010-26: Submerged Electrical Cables. January 7, 2011 Entergy and the Staff filed Answers opposing PWs December 13 Request. From Entergys and NRCs filings, PW learned additional new information that supports this filing.

I. INTRODUCTION The license renewal application for Pilgrim Station was amended by Entergy January 7, 2011. Like its original Aging Management Program (AMP), in its 2006 License Renewal Application, it fails to comply with the requirements of 10 C.F.R. §§ 54.21(a) and 54.29 because the applicant has not proposed an adequate or sufficiently specific plan for aging management of non-environmentally qualified inaccessible electrical cables, and splices (cables) for which such aging management is required.

Without an adequate plan for aging management of non-environmentally qualified inaccessible electrical cables protection of public health and safety cannot be assured.

II. THE CONTENTION IS WITHIN THE SCOPE OF THESE PROCEEDINGS 10 C.F.R. 54.4 sets forth the scope of review2 concerning safety issues in a license renewal proceeding. The safety review "is confined to matters relevant to the extended period of operations requested by the applicant," and focuses on the plant systems, structures, and components "that will require an aging management review for the period of extended operation," or "are subject to an evaluation of time-limited aging analyses." Duke Energy 2

This rule reads in relevant part:

§ 54.4 Scope.

(a) Plant systems, structures, and components within the scope of this part are --

(1) Safety-related systems, structures, and components which are those relied upon to remain functional during and following design-basis events (as defined in 10 CFR 50.49 (b)(1)) to ensure the following functions --

The integrity of the reactor coolant pressure boundary; The capability to shut down the reactor and maintain it in a safe shutdown condition; or The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures comparable to those referred to in § 50.34(a)(1), § 50.67(b)(2), or § 100.11 of this chapter, as applicable.

(2) All non-safety-related systems, structures, and components whose failure could prevent satisfactory accomplishrnent of any of the functions identified in paragraphs (a)(1)(i), (ii), or (iii) of this section.

(3) All systems, structures, and components relied on in safety analyses or plant evaluations to perform a function that demonstrates compliance with the Commission's regulations for fire protection (10 CFR 50.48),

environmental qualification (10 CFR 50.49), pressurized thermal shock (10 CFR 50.61), anticipated transients without scram (10 CFR 50.62), and station blackout (10 CFR 50.63).

2

Corp. (McGuire Nuclear Station, Units 1 and 2; Catawba Nuclear Station, Units 1, 2 and 3), 56 N.R.C. 358, 363-64 (2002)

The NRC has emphasized that the level of inspection and testing related to age-management over the extended license term is one of the core issues addressed by the license renewal proceeding. Aging management of inaccessible cables is plainly within scope. Part 54 centers the license renewal reviews on the most significant overall safety concern posed by extended reactor operation the detrimental effects of aging. By its very nature, the aging of materials becomes important principally during the period of extended operation beyond the initial 40-year license term, . . . . Adverse aging effects can result from material fatigue, oxidation, erosion, corrosion, . . . and shrinkage. Such age-related degradation can affect a number of reactor and auxiliary systems, . . . Indeed, a host of individual components and structures are at issue. See 10 C.F.R. 54.21(a)(1)(i).

Left unmitigated, the effects of aging can overstress equipment, unacceptably reduce safety margins, and lead to the loss of required plant functions, including the capability . . .

to otherwise prevent or mitigate the consequences of accidents with a potential for offsite exposures.

Accordingly, Part 54 requires renewal applicants to demonstrate how their programs will be effective in managing the effects of aging during the proposed period of extended operation. Applicants must identify any additional actions, i.e. maintenance, replacement of parts, etc., that will need to be taken to manage adequately the detrimental effects of aging.

The Pilgrim Nuclear Power Plant Application for License Renewal (Application) includes a list of systems that require aging management. Among them are Non-EQ 3

Inaccessible cables (A.2.1.21 Non-EQ Inaccessible Medium-Voltage Cable Program; A.2.1.23 Non-EQ Insulated Cables and Connections Program; Section B.1.19 Non-EQ Inaccessible Medium-Voltage Cable). Deficiencies in the Aging Management Plan could endanger the safety and welfare of the public and are therefore within the scope of a relicensing hearing. The January 7, 2011 commitments 3are provided (Attachment 2).

lll. THE CONTENTION IS A MATERIAL ISSUE The issue raised in th[is new] contention is material to the findings the NRC must make to support the action that is involved in the proceeding. 10 CFR§2.309(f)(iv)

In considering the license renewal for Millstone Nuclear Power Station, the ASLB stated that [w]here a contention alleges a deficiency or error in the application, the deficiency or error must have some independent health and safety significance. In the Matter of Dominion Nuclear Connecticut, Inc. (Millstone Nuclear Power Station, Units 2 and 3)

Docket Nos. 50-336-LR, 50-423-LR ASLBP No. 04-824-01-LR July 28, 2004, p. 7. See Private Fuel Storage, L.L.C. (Independent Spent Fuel Storage Installation), LBP- 98-7, 47 NRC 142, 179-80 (1998), affd in part, CLI-98-13, 48 NRC 26 (1998). The deficiency highlighted in this contention has enormous independent health and safety significance.

NRCs IN 2010-26 (Attachment 2) says, for example ( at 6) that, Because these cables are not designed or qualified for submerged or moist environments, the possibility that more than one cable could fail has increased; this failure could disable safety-related accident mitigation systems.

3 The Commitments were provided by Entergy as Exhibit A to Entergys Answer Opposing Pilgrim Watchs Request for Hearing on a New Contention. Entergy Letter No. 2.06.003 4

The subsurface at Pilgrim Nuclear Power Station (PNPS) is moist. The reactor is located adjacent to Cape Cod Bay and in a meteorological weather climate subject to fog, rain and snow. In addition the Applicant has failed to extablish current subsrface groundwater flow throughout the entire site since the Dames & Moore 1967 hydrological geeological survey performed prior to construction. (Blanch Decl.,18)

IV. THE CONTENTION IS SUPPORTED BY FACTS OR EXPERT OPINION Section 2.309(f)(v) requires "a concise statement of the alleged facts or expert opinion which support the petitioner's position on the issue and on which the petitioner intends to rely at hearing, together with references to the specific sources and documents on which the petitioner intends to rely to support its position on the issue." An intervenor is not required to prove its case at the contention filing stage: "the factual support necessary to show that a genuine dispute exists need not be in affidavit or formal evidentiary form and need not be of the quality as that is necessary to withstand a summary disposition motion." Statement of Policy on Conduct of Adjudicatory Proceedings, 48 N.R.C. 18, 22 n.1 (1998), citing, Rules of Practice for Domestic Licensing Proceedings Procedural Changes in the Hearing Process, Final Rule, 54 F.R. 33168, 33171 (Aug. 11, 1989). Rather, petitioner must make "a minimal showing that the material facts are in dispute, thereby demonstrating that an inquiry in depth is appropriate." In Gulf States Utilities Co., 40 NRC 43, 51 (1994),

citing, Rules of Practice for Domestic Licensing Proceedings Procedural Changes in the Hearing Process, Final Rule, 54 F.R. 33168, 33171 (Aug. 11, 1989). Pilgrim Watch relies here on: the expert opinion of Paul Blanch, retired nuclear engineer specializing in electrical 5

(Attachment 1); Entergys revised LRA; many government documents (including the NRCs admissions and opinions stated in IN 2010-26, NUREG/CR-7000 and 10 C.F.R 50.49) and the National Electrical Manufacturers Association (NEMA) reports.

V. THE CONTENTION RAISES A GENUINE DISPUTE OF MATERIAL LAW OR FACT Section 2.309(f)(vi) requires that a petitioner provide sufficient information to show that a genuine dispute exists with the applicant/licensee on a material issue of law or fact. As required, the information set forth in this contention includes references to specific portions of the application that the petitioner disputes and the supporting reasons for each dispute; and to the fact that the application fails to contain information on a relevant matter as required by law, and identifies each such failure and the supporting reasons for the petitioners belief.

PW references, for example: NRC Information Notice 2010-26, Submerged Electrical Cables; sections of the amended LRA including Commitment 15; A.2.1.23 Non-EQ Insulated Cables and Connections Program, A.2.1.23 Non-EQ Insulated Cables and Connections Program, Section B.1.19 Non-EQ Inaccessible Medium-Voltage Cable, Section B.1.21; NUREG-1891; Entergys Letter No. 2,11,001; and pertinent government documents and regulations, including SAND 96-0344, NUREG/CR 7000, and 10 C.F.R. 50.49. Together, these are far more than the required "minimal showing that the material facts are in dispute, thereby demonstrating that an inquiry in depth is appropriate." In Gulf States Utilities Co., 40 NRC 43, 51 (1994), citing, Rules of Practice for Domestic Licensing Proceedings Procedural Changes in the Hearing Process, Final Rule, 54 F.R. 33168, 33171 (Aug. 11, 1989). In addition, PW provides an expert declaration.

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A Licensing Board should not address the merits of a contention when addressing admissibility. Public Service Co. of New Hampshire (Seabrook Station, Units 1 and 2),

LBP-82-106, 16 NRC 1649, 1654 (1982).

VI. THERE IS A SUBSTANTIAL BASIS FOR THE CONTENTION Introduction

1. Pilgrim Nuclear Power Station (PNPS), like all other nuclear plants, has miles4 of inaccessible electrical cables5 throughout the plant. The cables play vital roles in the operation of a nuclear power plant. This is recognized in 10 CFR 54.4 and 54.21. In addition, in the underground circuits, Pilgrims inaccessible cables may include splices6 that are part of, and are exposed to the same environmental and operational stresses as the cables on which they are installed. For the purposes of this contention, the inaccessible cables and splices are effectively one and the same, and are collectively referred to as cables.

2. The motion includes any cables not qualified for exposure to moisture (referred herein as Non-EQ). Non-EQ cables are significantly more likely to fail or experience undetected failures due to submergence and moisture accumulation, as discussed in 4

Estimated to be many miles of internal wiring and cables; discovery will determine precise amount and location 5

In this context, wires and cables are considered to be the same components 6

NUREG/CR 7000 at 2-4; Cable splices are exposed to the same environmental and operational stressors as the cables on which they are installed. Since cable splices are constructed of many of the same or similar materials as the electric cables on which they are installed, these stressors can also cause aging degradation of the polymer insulating materials used in the cable splice. In addition, the other subcomponents that make up an electric cable splice (insulating tape, fillers, sleeves, insulating compounds, and compression connectors) are also susceptible to aging degradation due to the various stressors to which they are exposed.

NUREG/CR-6788, at 4-16: If the underground cable circuit includes a cable splice, long-term submergence of the splice can also result in unexpectedly early failure of the cable system if the splice is not specifically qualified for continuous submerged operation. If a splice is not installed correctly, failure could occur even more quickly in the presence of moisture or standing water.

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Information Notice 2010-26, NUREG/CR 7000, SAND96-0344, and the National Electrical Manufacturers Association (NEMA), the US national organization that oversees all electric building codes in the USA and other countries.

3. Based on 10 C.F.R. 54.21(a)(1) and 10 C.F.R. 54.4 electrical cables are clearly within the scope of 10 C.F.R 54, irrespective of the design or the applied voltage, either AC or DC.

4. Pilgrim has a history of submerged and/or wetted cables7, and there has been no verification of the long-term operability that provides reasonable assurance of continued operability of these cables.

5. As shown in Pilgrim Watchs Request for Hearing on Cables (December 13, 2010) and Pilgrim Watchs Reply to Entergys and NRC Staffs Answers Opposing Pilgrim Watchs Request for Hearing on New Contention (January 14, 2011), the amended AMP (like the original AMP) is insufficient to provide that these [inaccessible cables and cable splices at Pilgrim Station] provide reasonable assurance that these cables will be in compliance with NRC regulations and public health and safety will be protected during license renewal.

Significance of Non-EQ Inaccessible Electric Cables

6. Almost every active safety and non safety system at Pilgrim Nuclear Power Station (PNPS) is dependent upon electrical power to perform its function to prevent major accidents. If an accident occurs, electrical power is required to prevent a reactor meltdown with major radioactive releases to the environment.

7 Inspection Report 05000293/2010003,1RO6 Flood Protection Measures, July 29, 2010 (Attachment 3) 8

7. Nuclear plants are designed to cope for a short period, typically four hours, without alternating current8 (AC) electrical power. During this short period, electrical power from batteries9 can be used to control steam-driven valves and pumps that cool the reactor core; once the batteries are depleted, if workers have not restored AC electrical power from the onsite emergency diesel generators or the offsite electrical grid, the plant then proceeds towards a reactor meltdown.

8. Failure to properly manage aging of non-environmentally-qualified (Non-EQ)

Inaccessible Cables may challenge: (a) the integrity of the reactor coolant pressure boundary; (b) the capability to shut down the reactor and maintain it in a safe shutdown condition; and/or (c) the capability to prevent or mitigate the consequences of accidents that could result in potential offsite exposures comparable to those referred to in § 50.34(a)(1), § 50.67(b)(2), or § 100.11. (Blanch Decl., 50)

9. The failure to properly manage aging of the Non-EQ inaccessible electric cables (and any splices) could result in the loss of safety related cables and buses that supply emergency power to safety equipment including Station Blackout (SBO) loads, service water motors/pumps, safety injection pumps, and other electrical loads required to meet the requirements of 10 C.F.R. § 54.4.

10. Consequence of failures of Non-EQ inaccessible electric cables (and any splices) may result in accidents beyond the Design Basis Accidents resulting in exposures to the public exceeding 10 C.F.R. § 100 limits.

11. Any cable that is "important to safety" has to be designed for the environmental conditions to which it will be exposed. Therefore, any cable that is submerged or exposed 8

Similar to the power in homes and other facilities 9

Direct Current (Similar to car batteries) 9

to moisture must be designed for that environment Pilgrims submerged Non-EQ cables are not so designed and are not qualified.

12. Non-EQ cables are in violation of NRC regulation. NRC's regulatory requirements are clearly delineated in General Design Criterion 4 within Appendix A to 10 CFR Part 50.10 It says:

Criterion 4--Environmental and dynamic effects design bases. Structures, systems, and components important to safety shall be designed to accommodate the effects of and to be compatible with the environmental conditions associated with normal operation, maintenance, testing, and postulated accidents, including loss-of-coolant accidents. These structures, systems, and components shall be appropriately protected against dynamic effects, including the effects of missiles, pipe whipping, and discharging fluids, that may result from equipment failures and from events and conditions outside the nuclear power unit. (Emphasis added)

13. Pilgrims submerged cables are not designed to accommodate the effects of and to be compatible with the environmental conditions. Criterion 4 has no provision or footnote that allows exceptions to the rule when owners promise to test the cables every now and then. Periodically testing a submerged cable when that cable is not designed for that environment is a violation of federal regulations, period. Non-complying cables are still non-complying.

14. 10 CFR § 50.49 titled Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants is a regulation provided to assure electrical equipment, including cables, will function in a harsh environment. When 50.49 was initially implemented and backfitted on existing plants such as Pilgrim, inaccessible and 10 Available online at http://www.nrc.gov/reading-rm/doc-collections/cfr/part050/part050-appa.html 10

buried cables were never considered. This may have been an oversight, but it never anticipated that these inaccessible cables would be exposed to a harsh environment such as submergence discussed in 10 CFR 50.49. (Blanch Decl., 38)

15. Mr. Blanch says It is my professional opinion, now that we realize that these vital cables are subjected to a harsh environment (submergence and moisture) as defined in 10 CFR 50.49(d)(5) and (6) that all safety related inaccessible cables be within the scope of 10 CFR 50.49. (Blanch Decl., 39)

16. Cables within the containment and other plant areas experiencing a harsh environment including submergence are within the scope of 10 CFR 50.49. (Blanch Decl., 40) Pilgrims environment meets the definition of harsh due to its location on the shores of Cape Cod Bay exposing components to salt and presumably other contaminants suchas oil and radiation. (Blanch Decl., 23)

17. Cables are a significant safety issue; as the NRCs own papers make abundantly clear. IN-2010-26 warns that it is not simply a single failure that is of concern. They say, Cables not designed or qualified for, but exposed to, wet or submerged environments have the potential to degrade. Cable degradation increases the probability that more than one cable will fail on demand because of a cable fault, lightning surge, or a switching transient. Although a single failure is within the plant design basis, multiple failures of this kind would be challenging for plant operators. Also, an increased potential exists for a common-mode failure of accident mitigating system cables if they are subjected to the same environment and degradation mechanism for which they are not designed or qualified for. (IN 2010-26, at 7; and Blanch Decl., 45) 11

NRC Admissions

18. On December 2, 2010 the NRC issued Information Notice 2010-26: Submerged Electrical Cables (Attachment 3 and Adams Accession No. ML1028004) to inform addresses of observations of protracted cable submergence in water. This document clearly shows that numerous non-qualified cables have been exposed to submergence and moisture.

19. The new information included in the December 2, 2010 notice said that (a) Pilgrim Nuclear Power Station (PNPS) is specifically mentioned; (b) the NRC has concluded that cable submergence in water is serious; (c) despite its conclusion that the issue is serious, the NRC has not required PNPS to take any action (The NRC expects recipients (of the IN) to consider taking action[but] the suggestions that appear in this IN are not NRC requirements; therefore no specific actionis required (IN 2010-26, at 1, emphasis added); and (d) in view of the NRCs failure to require corrective action only relicensing provides a mechanism for ensuring that this significant aging management issue will be addressed at PNPS.

20. The NRCs December 2 announcement (IN 2010-26) that it will require no corrective action to address what it now admits is a significant safety issue, supports PWs new contention that Entergys Aging Management Plan for non-environmentally qualified (EQ) inaccessible cables at Pilgrim Station is insufficient to provide reasonable assurance that public health and safety shall be protected during license renewal.

21. In IN 2010-26, the NRC and Brookhaven National Lab (BNL) admit that (a) cable failures have a variety of causes, (b) submerged cables present significant concerns, 12

(c) the concerns are largely related to aging, and (d) that significant steps should be taken.

The NRC admits:

a. Cable failures have a variety of causes, including manufacturing defects, damage caused by shipping and installation, and exposure to electrical transients or abnormal environmental conditions during operation.

Latent shield or insulation damage could result from errors during cable installation, which could be caused by cable jamming, cable pull-bys, cable sidewall bearing pressure, pulling cables through conduits and flexible conduit, or computerized cable routing system software routing cables through the wrong raceway. (IN 2010-26, 5)

b. Cables not designed or qualified for, but exposed to, wet or submerged environments have the potential to degrade. Cable degradation increases the probability that more than one cable will fail on demand because of a cable fault, lightning surge, or a switching transient. Although a single failure is within the plant design basis, multiple failures of this kind would be challenging for plant operators. Also, an increased potential exists for a common-mode failure of accident mitigating system cables if they are subjected to the same environment and degradation mechanism for which they are not designed or qualified for. (IN 2010-26, at 7)

c. The likelihood of failure from any of these factors increases over time as the cable insulation degrades and/or is exposed to water. (IN 2010-26, at 5)

These failure data indicated an increasing trend in underground cable failures, and the predominant contributing factor was submergence or moisture intrusion that degraded the insulation. The staff noted that the cables are failing within the plants 40-year licensing periods. (IN 2010-26 at 7) 13

d. The NRC expects [but does not require] licensees to identify conditions that are adverse to quality for cables, such as long-term submergence in water. Upon discovery of a submerged condition, the licensee should [but is not required to]

take prompt corrective actions to restore the environment to within the cables design specifications, immediately determine the operability of the cable(s) to perform its intended design function, and determine the impact of the adverse environment on the design life of the cable. These corrective actions typically involve the removal of water, the installation of a sump pump or the repair of the drainage conditions, and evaluation of the operability of the cable(s) including testing where appropriate. The long-term [no time frame is even discussed] corrective actions could involve establishment of a condition monitoring program for all cables which are inaccessible and underground and under the maintenance rule, including testing of cables to verify the cables are not degraded and visual inspection of manholes for water accumulation to ensure continued operability. (IN 2010-26 at 6, Petitioners comments added in italics)

22. The NRCs failure to require licensees to take action means that requiring a greatly improved AMP is the only way to insure that Entergy does what should be done. And those requirements must be spelled out and enforced; the NRC also admits that past steps taken by licensees to address the problem of aging submerged cables have been insufficient:

Some licensees have attempted to periodically drain the accumulated water from the cable surroundings to avoid cable failures. In some cases, the water quickly refilled the cavity in areas in which the water table was above the base level of a cable trench or underground vault. In other cases, water accumulated seasonally (e.g., because of snowfall or rain), filling the conduit 14

or raceways. In both cases, periodic draining could slow the rate of insulation degradation, but it may not prevent cable degradation. Licensees should ensure that cables that could become submerged are adequately monitored. (IN 2010-26, at 7) (Emphasis added)

23. Despite these admissions, the NRC has not ordered any corrective action.

Particularly in view of the staffs recognition that cables are failing within the plants 40 year licensing period, it could hardly be clearer that sufficiently managing aging of inaccessible cables should be a critical part of relicensing.

24. And even if the NRC had required Licensees to ensure that cables that could be submerged are adequately monitored (Id.), it utterly failed to take the critical next step in any aging/failed component management program: failed or failing cables must be replaced or otherwise updated to bring the cables into compliance with NRC Regulations.

Industry

25. National Electrical Manufacturers Association (NEMA) is the US national organization that oversees all electric building codes in the USA and other countries. Its document, Evaluating Water-Damaged Electrical Equipment, 2006, says that Non-EQ cable water damaged should be replaced. (Blanch Decl., 21,24)

26. Contaminants in Water: The National Electrical Manufacturers Association (NEMA) and its experts are clear the effect of contaminated water on cables. For example, one manufacturer said that the problem was particularly acute if, as at PNPS, it involved salt water.

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When wire and cable products are exposed to water or excessive moisture, the components may be damaged due to mildew or corrosion. This damage can result in insulation or termination failures. This problem can be more severe if the components have been subjected to salt wateror high concentrations of chemicals, oils, fertilizers etc. [Blanch 21, Emphasis added]

Another expert not only described the significance of the problem, but went on to say, point blank, that faulty components had to be replaced (Blanch Decl., 18-23)

In the normal electrical distribution system, the performance ability of electrical equipment and components is primarily dependent on clean, corrosion free conductive surfaces and by the equipments dielectric insulation capabilities. Water damaged equipment whether through floodwaters or other means, negates that ability and raises the risk of future equipment failure and possibly fire and shock hazards to unknown levels.

It is absolutely critical that these components be replaced. Connecting power to an electrical system containing them poses a serious fire hazard and other risks.

Contaminated water that oxidizes metal contact points will increase resistance. This resistance will generate heat directly in proportion to [the square of the resistance of the] amount of current that flows through the oxidized metal. The more heat that is generated, the more resistance is increased. This snowballing effect can lay dormant until the appliance is used or until loads are increased across a contact point. Thereby becoming a fire hazard sometime after the electricity is turned on. (Blanch Decl., 24; PW insert, edit) 16

Pilgrims Site Specific Cable System Degradation Mechanisms

27. Moisture: At 7, IN 2010-26 the NRC admitted that These failure data indicated an increasing trend in underground cable failures, and the predominant contributing factor was submergence or moisture intrusion that degraded the insulation.

28. Many of the wires and cables used at PNPS to supply power to vital and non-vital electrical equipment are contained within conduits. The conduits themselves that function to isolate the wires from the environment are made of materials that are subject to degradation, especially as they age and are exposed to Pilgrims moist salt water environment. Corroded conduits and manholes allow moisture inside. The wires and cables, together with any connections and splices inside the conduits, are only designed to operate properly in a dry environment and were not designed or specified to operate in a moist or wet environment. While a cable may work for awhile if wet and/or submerged, there is no assurance it will not fail if wet or submerged, if it had previously experienced exposure to moisture.

29. There is no basis upon which anyone can assume that most inaccessible electrical cables at Pilgrim Nuclear Power Station have not been exposed to significant moisture over the past 40 years since initial construction in the 1960s. This is because:

(a) Pilgrim is located on low land directly beside Cape Cod Bay.

(b) The FEIS describes the soil as sandy, silt and clay - soil types that retain moisture.

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(c) Plymouths climate11 is characterized by frequent showers, thunderstorms, high humidity in the spring and summer. Summer winds typically are from the southwest or southeast and bring warm, moist air that can contribute to fog formation. Spring and summer southwesterly winds may drive hurricanes northward with the potential to flood shores where cables are buried; and the storms of autumn or winter, noreasters, also have particularly strong winds and may drive winter storms into northeastern-facing shores with storm/tidal surges.

Snow storms generally occur in winter. Melting snow, rains, tidal surges etc result in moisture percolating downwards wetting and degrading conduits and wiring below.

(d) Water travels downward from leaks inside the reactor following along wires to collect below.

(e) Manhole covers may not be watertight; and the water table is high in seasonal cycles and the tidal surges accompanying storms.

(f) Storms and higher tides are increasingly common and therefore the conduits may get refilled soon after purging.

(g) Condensation is an additional factor caused by changes in temperature in the climate.

The foregoing all increase the potential for conduit and insulation degradation.

30 Age: IN 2010-26 at 7, it said that, The staff noted that the cables are failing within the plants 40-year licensing periods. Pilgrim is one of the oldest operating commercial reactors in the county. Pilgrim Watch understands that the majority of the conduits and wires at PNPS were installed during initial construction in the 1960s and 11 http://www.mass.gov/czm//oceanmanagement/waves_of_change/pdf/troceancc.pdf 18

possible some at subsequent plant updates. Entergy has not said exactly when each of its unaccessible non-qualified cables and wires were installed. It should make this information available to both the NRC and public.

31. Corrosion increases with age. The aging degradation of wires is commonly the result of deterioration of the wiring insulation. Aging causes insulation to become less and less pliable, making it easier for cracks and tears to form and grow larger. Residual defects in the insulation, leftover from blemishes during manufacturing and nicks and scrapes during installation, are pre-existing weaknesses exploited by aging. According to the recently issued EPRI reports, 12 wires degrade with age and the most susceptible to degradation are the oldest wires.

32. It is very clear that the number of cable failures is rapidly increasing with age as shown from the following graph copied from the NRCs own study titled Inaccessible Or Underground Power Cable Failures That Disable Accident Mitigation Systems Or Cause Plant Transients (Blanch Decl., 47) 12 Plant Support Engineering: Aging Management Program Development Guidance for AC and DC Low-Voltage Power Cable Systems for Nuclear Power Plants, Regulatory and management concern regarding the reliability of low-voltage power cable systems at nuclear plants has been increasing for the past 5-10 years. The staff of the United States Nuclear Regulatory Commission are concerned that wetted (up to and including submergence) low-voltage power cable circuits may be degrading to the point at which multiple cable circuits may fail when called on to perform functions affecting safety. Utility managers are concerned that cables may fail, causing adverse safety consequences and/or plant shutdowns. This document provides guidance for developing and implementing a cable aging management program for low-voltage power cable circuits in nuclear power plants.

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33. It may appear that the number of failure decreases after 30 years, but this is misleading. Very few plants have been operating for more than 30 years; and the number of failures per plants of various age is not stated.. There is no reason to suspect that the likelihood of failure will magically decrease after age 30 unless NRC assures the requirements of 10 CFR 50.49 are put in place. It is recognized that many inaccessible cables are being subjected to design basis events that include conditions of normal operation defined by 10 CFR 50.49.

34. Although 10 CFR 50 Appendix A and B require testing and corrective actions, the fact that these failures are increasing with age indicates that proper corrective actions are not being implemented by the licensees. There is no recognized testing that can provide reasonable assurance that these cables can perform their intended functions. (Blanch Decl., 49)

35. Contaminants in Water: As said above at 22, the National Electrical Manufacturers Association (NEMA) and its experts are clear that water, particularly 20

contaminated water, has a negative effect on cables. For example, one manufacturer said that the problem was particularly acute if, as at PNPS, it involved salt water.

When wire and cable products are exposed to water or excessive moisture, the components may be damaged due to mildew or corrosion. This damage can result in insulation or termination failures. This problem can be more severe if the components have been subjected to salt wateror high concentrations of chemicals, oils, fertilizers etc. [Blanch 21, Emphasis added]

36. There are no existing methods to assure operability short of visual inspection and/or replacement with cables designed for operation in a wet or submerged environment. NRC agrees13 and said, in NRC Inforamtion Notice 2010-26, at 7, the staff noted that the cables are failing within the plants 40-year licensing periods. Some of the cable failures have resulted in plant transients and shutdowns, loss of safety redundancy, entries into limiting conditions for operation, and challenges to plant operators. The NRC staff published the summary report that captured the review of responses from all licensees on November 12, 2008 (ADAMS Accession No. ML082760385).

37. Installation & Manufacturing Defects14: IN 2010-26 says (at 5) that Cable failures have a variety of causes, including manufacturing defects, damage caused by 13 NRC Regulatory Issue Resolution Protocol-Inaccessible or Underground Cable Performance Issues at Nuclear Power Plants (August 19, 2009) available NRC Electronic Library, Adams Accession No.

ML092460425 14 Response to NRC Generic Letter 2007-0, Attachment 1 to Entergy Letter No. 2.07.034 Generic Letter 2007-01 Response (ML071300361): Request 1-Provide a history of inaccessible or underground power cable failures for all cables that are within the scope of 10 CFR 50.65 (the Maintenance Rule) and for all voltage levels.Response 1:Pilgrim has experienced one cable failure within the scope of the GL. The requested information is provided below. Cable failed during service due installation damage.

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shipping and installation. (and) The likelihood of failureincreaces over time as the cable insulation degrades and/or is exposed to water.

38. There is no basis for assuming that none of these cables were likely damaged during their installation at Pilgrim,15 meaning scrapes and other damage likely occurred in the surface of the insulation and possibly deeper, unless Entergy can prove otherwise.

Manufacturing defects cannot be ignored either. These coating defects permit moisture to infiltrate the wiring. Moisture/submergence increases the probability of failure should an accident occur. Failure of the wires assures failure of connected components (emergency diesel generators, emergency reactor cooling motors and pumps, valves, etc.) If these wires have any surface defects/degradation due to installation, other unknown defects or normal aging, there is no assurance that they are capable of performing their designated safety functions when required if they have experienced submergence and/or moisture exposure.

Pilgrim, Site Specific Experience, Examples

39. The IN 2010-26 Attachment 4 included examples of NRC Inspection Reports on Cable Submergence issues.

40. For example, NRC Integrated Inspection Report 05000293/2010003, 1RO6 Flood Protection Measures, July 29, 2010, Pilgrim shows that NRC inspectors looked in to three cable vaults, and observed partially and fully submerged medium voltage cables in all three; indeed Entergy admitted that two of the three were always found submerged..

(Report, pp.7-8) The report made clear that flooding is a recurring, if not rampant, 15 Some plants during construction, actually connected wires to cables and trucks to pull wires through the buried pipes 22

problem; and demonstrates that both NRC oversight and Entergys compliance are and have been inadequate to provide reasonable assurance that these electric wires will function as required either now or over the license renewal period, leaving protection of public safety to chance. The Reports main finding describes a sample taken on April 28, 2010, where the inspectors observed water in the three (3) manholes and vaults inspected:

On April 28, 2010, the inspectors observed water in each of the manholes and vaults listed above. The inspectors noted that no dewatering or drainage systems existed in the manholes. Entergy procedure EN-DC-346, Revision 0, "Cable Reliability Program," was issued and effective on December 31, 2009.

This procedure discusses manhole inspections and dewatering, and requires, in part, "If manual inspections and pumping are used to maintain a cable system dry, the intervals must be sufficient to keep the cables dry. Adjust intervals as necessary, based on inspection results." Discussions with Entergy personnel involved with these inspections indicated that cables in Manhole 2A were periodically found submerged or partially submerged, and that cables in Manholes 4 and 5 were always found submerged. The cables that were submerged included cables that were installed from the 4160V, non-safety related startup transformer and connected to the A2 and A4 non-safety related busses. The inspectors identified that Entergy had previously identified submerged cables in August and September of 2009, however, corrective actions were not sufficient to preclude these cables from being submerged. The inspectors also determined that The inspectors identified that Entergy had previously identified submerged cables in August and September of 2009, however, corrective actions were not sufficient to preclude these cables from being submerged (Pg., 8, emphasis added) 23

41. The IN 2010-26 reports that the inspectors determined that the submergence of the cables was an event of very low safety significance- a Green finding.16 What this really reflects is grade inflation in the NRCs lenient grading system.Even if this one report reasonably could have generated a Green, as does essentially every other NRC grade, it does not show that PNPS, inaccessible non-qualified cables are all of low safety significance now, or that they will be so during the 20 years to which Entergys AMP applies.

42. Prior to that, for example, wiring failures were reported at Pilgrim in NRC Information Notice 2002-12.

Pilgrims LRA, Aging Management Program

43. A review of Pilgrims LRA, and Commitment 15, shows that its Aging Management Progam (AMP) is inadequate and does not properly respond to the issues outlined in IN 2010-26, requirements of 10 C.F.R.50.49 and other referenced documents; thereby it does not provide reasonable assurance that public health and safety will be protected.

44. Pilgrim Watch learned from Entergys and the Staffs Answers Opposing Pilgrim Watchs Request for Hearing On a New Contention, filed January 7, 2011 additional new information that:

16 Green Findings: The NRC's data for the most recent full year (2009) appears on slide 19 from the annual assessment meeting NRC conducted for the Kewaunee nuclear plant in Wisconsin. (Attachment 5).

In 2009, there were 879 green inspection findings and a grand total of 7 greater-than-green findings (all white). So, there's less than a 1 percent chance that an inspection finding will be greater-than-green. But even that is a higher percentage than the likelihood that the NRC will find that a performance indicator will be greater-than-green. There were 7039 green performance indicators and only 18 greater-than-green.

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x On December 23, 2010, 10 days after PWs Request for a New Hearing was filed, the NRC made publicly available a new GALL revision (Rev. 2), its first since 2005, dealing with, among other things, issues presented by inaccessible electric cables.

x On January 7, 2011, Entergy amended its AMP to provide new commitments related to inaccessible electric cables.

All of this new information supports Pilgrim Watchs decision to file this Request for Hearing. It is plainly relevant to Entergys application for license renewal of Pilgrim Station. It is in scope; it is material; and there is a basis for our contention that the AMP as it stands today despite the Commitment and revision to the GALL is insufficient.

45. Pertinent portions of Entergys Pilgrim Nuclear Power Station License Renewal Application (LRA) Supplemental Information (Exhibit A to Entergys Answer Opposing Pilgrim Watchs Request for Hearing on a New Contention (1/2/2011) are provided in .

46. Entergys Letter No. 2.11.001, Attachment 2, pages 8-9 lists the revised text for LRA Section A.2.1.2.1 and Section B.1.19..

a. A.2.1.21 Non-EQ Inaccessible Medium-Voltage Cable Program says:

In the Non-EQ Inaccessible Medium-Voltage Cable Program, in-scope cables (400 V to 35 kV) exposed to significant moisture will be tested at least once every six years to provide an indication of the condition of the conductor insulation. The specific test performed is a proven commercially available test for detecting deterioration of the insulation system due to wetting.

Significant moisture is defined as periodic exposures that last more than a few days. Significant voltage exposure is defined as periodic exposures that last more than a few days.

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Inspections for water collection in cable manholes and conduit containing inaccessible medium-voltage cables in scope of this program will occur at least annually, with some manholes inspected more freqeuntly based on evaluation of inspection results. [Emphasis added to flag some areas of concern]

Section B.1.19 Non-EQ Inaccessible Medium-Voltage Cable Program Description (Entergy Letter, Attachment 1, page 9)

The Non-EQ Inaccessible Medium-Voltage Cable Program at PNPS will be based on and consistent with the program described in NUREG-1801,Section XI.E3, Inaccessible Medium-Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements.

Inspections for water accumulation in manholes containing inaccessible low and medium-voltage cables with a license renewal intended function will be conducted at least annually and trended to determine the need to revise manhole inspection frequency. Additional operational inspections will be performed to verify drainage systems are functional prior to predicted heavy rains or flooding events such as hurricanes. The acceptance criteria include direct observations that the cables are not wetted or submerged, that cables/splices and cable support structures are intact, and that dewatering/drainage systems are functional.

In this program, periodic actions will be taken to prevent cables from being exposed to significant moisture, such as inspecting for water collection in cable manholes and conduit, and draining water, as needed. In scope low-voltage and medium-voltage cables exposed to significant moisture will be tested at least once every six years to provide an indication of the condition of the conductor insulation. All in-scope medium voltage cables will be tested prior to entering the PEO and low-voltage cables will be tested within 26

six years of entering the PEO. The test is to be a proven method for detecting deterioration of the insulation system due to wetting, such as dielelectric loss (dissipation factor/power factor), AC voltage withstand, partial discharge, step voltage, time domain reflectometry, insulation resistance andpolorization index, line resonance analysis, or other testing that is state-of-the-art at the time the test isperformed. [Emphasis added to flag some areas of concern]

This program will be initiated prior to the period of extended operations.

Exceptions to NUREG-18-01: None These sections illustrate the inadequacy of Entergys AMP:

i. Significant moisture is defined to eliminate most of what could be truly significant.

ii. Simply looking to see whether a system is functional before a predicted heavy rain or flooding event hardly provides any proection against the unpredicted.

iii. Whether something is functional before something happens does not answer whether it remains functional during a wetting or submergence, and tells nothing about wetting or submergence either before or after.

iv. Undefined testing once over the next 20+ years using an unproved test system shows nothing.

v. Inspections for water accumulation, i.e., what can I see, is insufficient on its face; at least absent testing for water accumlation, present or in the past, in places that cannot be seen simply by removing a manhole cover.

vi. Even if significant moisture were adequately defined, looking to see if a cable is exposed to significant moisture fails even to ask if it has been significantly exposed in the past.

vii. There is no requirement that all high and low voltage cables will be tested; the word all is used only in reference to medium voltage cables prior to entering the PEO.

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viii. And, consistently with the entire AMP, there is no mention of what will be done if a test shows deterioration.

47. Some of this is repeated in Commitment 15 (Letter Number 2.11.001, Attachment 1, page 10, but what it says is equally insufficient to satisfy the public health and safety:

The deficiencies in this Commitment are legion.

Entergys AMP for Non-EQ inaccessible cables at Pilgrim, as amended, remains woefully insufficient

48. Entergys Aging Management Plan for non-environmentally qualified (EQ) submerged cables at Pilgrim Station, as amended, remains insufficient to provide reasonable assurance that public health and safety shall be protected during license renewal, examples follow.

49. Replacement: Entergy never commits to, or even mentions, replacing Non-EQ cables exposed to any submergence. NEMA is the US national organization that oversees all electric building codes in the USA and other countries. Its document, Evaluating Water-Damaged Electrical Equipment, 2006, says specifically that Non-EQ 28

cable water damaged should be replaced. (Blanch Decl., 21, 24, 37) Mr. Blanch concludes at 37 that, Cables that have been exposed to any submergence must be replaced with cables designed and qualified for underwater operation. This is my professional opinion supported by positions proffered by the electrical industry (NEMA) for commercial and industrial facilities. One would hope to believe that a commercial nuclear power plant would, as an absolute minimum comply with and far exceed these commercial standards and guidelines.

50. Voltage: Commitment 15 says that the Non-EQ Inaccessible Medium Voltage Cable Program as described in LRA section B.1.19 (will) include inaccessible 400 V to 2kV cables with a license renewal intended function in this program. The problem is that on its face the commitment ignores cables carrying less than 400 Volts (See Blanch Decl., 27-29)

Commitment 15 thus excludes numerous cables that perform a license renewal intended function and are potentially exposed to significant moisture. Mr. Blanch says specifically that Entergy has arbitrarily redefined the scope of its cables monitoring programs thereby eliminating the majority of vital cables within the scope of 10 CFR 54.4 and 10 CFR 54.21. There are miles of cables17 operating at voltages of less than 400 volts that meet the requirements defined in 10 CFR 54, yet Entergy and the NRC has failed to address any requirements for aging management for these cables and wires. (Blanch Decl., 28)

51. Frequency of Inspections: The commitment says that Cables will be tested for cable insulation degradation at least one every six years after entering the period of 17 The exact amount, function and location of these cables needs to be determined during the proceedings.

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extended operation (and) [i]nspections for water accumulation in manholes containing in-scope inaccessible low voltage and medium voltage cables will be performed at least annually.

52. Inspections in Entergys Commitment remain too infrequent. For example, NUREG/CR-7000 BNL-NUREG-90318-2009 at 4-18 said that, The failure data showed a trend toward early failure, the majority occurring in the range of 11-20 years of service and 21-30 years of service; this is shorter than the plants original 40-year licensing period. The NRC staff noted in its conclusions that the predominant factor contributing to cable failures at nuclear power plants appears to be the presence of water/moisture or exposure to submerged conditions.

Looking at some unqualified cables every six years, and lifting some manhole covers once a year, is wholly insufficient.

53. Assumptions Degradation: The frequency of inspection is based on a false assumption regarding degradation. The probability of corrosion is not constant with time and therefore cannot be characterized with a number and entered as such into a "Rule" - such as if we inspected yesterday we don't need to inspect again for 10 years.

First, corrosion/degradation is a rate process and the rate is NOT constant with time.18 Therefore, the probability would have to be adjusted with age, or the risk becomes a function of age. As a consequence, the entire risk management in the AMP is totally misguided.

18 Entergys unsupported assertion that corrosion/degradation is not a time dependent process ignores all of the evidence to that effect that was put before the Board in connection with Contention 1.

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54. Baseline Inspection, components: The frequency of inspection cannot be properly determined absent a lack of a commitment to perform a baseline inspection of all components, not just some. Commitment 15 says in the Program description of B.1.19 (Entergy Letter No. 2.11.001, Attachment 1, page 9) All in-scope medium voltage cables will be tested prior to entering the PEO and low-voltage cables will be tested within six years of entering the PEO. (Emphasis added) They fail to say if the purpose is to establish a baseline; and there is no reason to exclude low-voltage cables from an inspection prior to permission for extended operations. The program is not adequate without a commitment to perform a baseline review of all cables within scope to determine the condition of the submerged Non-EQ cables, prior to license extension and compare their present condition to what it was when installed. Absent a baseline, there is no way to access the adequacy of the AMP and to trend degradation over time. (Blanch Decl., 42)

Baseline Inspection, environment: Absent from the AMP is a requirement to perform a thorough subsurface hydological-geological survey over the entire site to determine groundwater flow today as it relates to inaccessible Non-EQ cables within scope; to compare those results to the original Dames and Moore 1967 hydro study to see if locally adverse conditions are more severe than were anticipated when the plant was originally designed. Further, a requirement to follow up with regular subsequent scheduled subsurface surveys to track changes in groundwater flow and tides expected from, for example, onsite construction or impacts from global warming changes, 2012-2032.

NUREG/CR 7000 says that, 31

It should be emphasized that the occurrence of cable system operating environments or locally adverse conditions that are unanticipated or more severe that the original plant design may constitute a design deficiency of the cable system, specifically, a potential violation of GDC 1, 4, 17, and 18. NRC regulations, such as 10 CFR 50, Appendix B, (quality assurance), the maintenance rule (10 CFR 50.65), and environmental qualification regulations (10 CFR 50.49), require that programs and administrative controls be established to monitor and detect degraded conditions on a regular basis and to promptly implement effective corrective actions and design modifications, consistent with its safety significance, so that any further cable degradation is minimized. A cable system must be designed to meet all applicable regulations and to perform its intended function in the plant environment under all anticipated operational occurrences and design basis events (4-20)

Entergys AMP does not satisfy this. In particular, it does not require Entergy to promply implment corrective actions and design modifications: or to meet all applicable regulations: by replacing all non-qualified cables with ones that are qualified.

55. The frequency of inspections is not sufficient especially in consideration of Pilgrims location on the shores of Cape Cod Bay; soil types (sand, silt and clay) that retain moisture (FEIS); a climate characterized by rain, snow, tidal surges, and the presence of contaminants that hasten degradation. For example, IN 2010-26 at 7 pointed out that:

Some licensees have attempted to periodically drain the accumulated water from the cable surroundings to avoid cable failures. In some cases, the water quickly refilled the cavity in areas in which the water table was above the base level of a cable trench or underground vault. In 32

other cases, water accumulated seasonally (e.g., because of snowfall or rain), filling conduit or raceways. In both cases, periodic draining could slow the rate of insulation degradation, but it may not prevent cable degradation

56. Contaminants, such as salt, increase degradation (Blanch Decl., 23) and the need for more frequent inspections. For example, a NEMA manufacturer said that degradation was particularly acute if salt water was involved.

When wire and cable products are exposed to water or excessive moisture, the components may be damaged due to mildew or corrosion.

This damage can result in insulation or termination failures. This problem can be more severe if the components have been subjected to salt wateror high concentrations of chemicals, oils, fertilizers etc. [Blanch 20, Emphasis added]

57. Timely Subsurface Hydro-Geo Studies: An important step in determining the appropriate frequency of inspection for Pilgrims site apparently has been overlooked.

Pilgrim has not shown that they have performed either an updated subsurface hydrological geological survey over the entire site to know precisely the current groundwater flow over the property today and superimposed on that informational map the locations of all the cables.

58. Age: Frequency of inspection apparently has not been linked, as it should have been, to the age of the component. The likelihood of failure increases over time as the cable insulation degrades and/or is exposed to water. (IN 2010-26, at 5)

59. Mr. Blanch (Decl.,47 ) said that, It is very clear that the number of cable failures is rapidly increasing with age as shown from the following graph copied from the NRCs 33

own study titled Inaccessible Or Underground Power Cable Failures That Disable Accident Mitigation Systems Or Cause Plant Transients

60. As said earlier, It may appear that the number of failure decreases after 30 years, but this is misleading. Very few plants have been operating for more than 30 years; and the number of failures per plants of various age is not stated. There is no reason to suspect that the likelihood of failure will magically decrease after age 30 unless NRC assures the requirements of 10 CFR 50.49 are put in place. It is recognized that many inaccessible cables are being subjected to design basis events that include conditions of normal operation defined by 10 CFR 50.49. (Blanch Decl., 48 )

61. Mr. Blanch conlcudes that, [R]isk will increase with continued age as clearly shown by the NRCs own published data unless the NRC is willing to implement the recommendations of industry studies and independent organizations including NEMA and NEC and its own regulations (10 CFR 50.49). (Blanch Decl.,52 )

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62. Inspections for water accumulation in manholes containing inaccessible low and medium-voltage cables with a license renewal intended function will be conducted at least annually does not provide for the fact that not all inaccessible cables are capable of inspection by manholes.

63: Sampling: The program is silent on sampling; there is no indication that the entire component, or indeed what components, will be examined. We need to know the size of the sample; whether different samples will be taken at different times, whether any testing is in fact a requirment and if so what it is; the locations of samples; and the rational for the sampling protocol. Because the Applicant has failed to show that they have identified both the location and extent of Non-EQ Inaccessible Cables (and any splices) in use at Pilgrim and the current groundwater flow, they have not, and cannot, have any basis for determining where and what must be sampled if that sample is to be meaningful..

64. Proven Commercially Available Tests to Detect Insulation Deterioration:

Entergys Commitment 15 and the revised Gall say that testing must be a proven method for detecting deterioration of the insulation system due to wetting, such as power factor, partial discharge, or polarization index, or other testing that is state-of-the-art at the time the test is performed. Entergys Application committed to implement these GALL programs, making no exceptions. However, this incorrectly infers they have a proven method for detecting cable deterioration. EPRI, Sandia and Brookhaven have concluded there is not any proven technology to detect degradation. (Blanch Decl., 29-33) 35

65. For example, the Sandia Study (SAND 96-0344) at 6.4 says:

No currently available technique was identified as being effective at monitoring the electrical aging of medium-voltage cables. Some methods may be effective at detecting severe electrical degradation or monitoring certain types of degradation (such as thermal aging); however, correlation of these measurements with the expended or remaining life of these cables has not been demonstrated.

And, Mr. Blanch (Blanch Decl., Jan 14, 2011; at 44) correctly points out that, While this Sandia document may be 14 years old, however its conclusions have not been superseded by additional research including extensive EPRI and NRC studies

66. Further, NUREG/CR 7000 (5.1 Conclusions) admits and confirms that in-service testing is not sufficient:

In-service testing of safety-related systems and components can demonstrate the integrity and function of associated electric cables under test conditions.

However, in-service tests do not provide assurance that cables will continue to perform successfully when they are called upon to operate fully loaded for extended periods as they would under normal service operating conditions or under design basis conditions. In-service testing of systems and components does not provide specific information on the status of cable aging degradation processes and the physical integrity and dialectric strength of its insulation and jacket materials. (Emphasis added)

67. Entergys Commitment No. 15 that says, Cables will be tested for cable insulation degradation using a proven, commercially available test for detecting cable insulation deterioration is meaningless statement. What is a proven ... test. Entergy 36

offers no facts to show that any of the tests it lists are proven; much less that the proposed scope and frequency of the tests are statistically significant or reliable. As for the proven ... test itself, no information is provided indicating: who approved any test, whether they had a vested interest in the results; when any tests were performed; whether the test applied to the specific circumstances at Pilgrim, whether any components tested were the same age as Pilgrims and located in a wetted salt environment. Neither is there any information regarding methodology such as the sample size and statistical significance of proof provided and so on.

68. At 33, Mr. Blanch summarizes, Entergy infers they have a proven method for detecting cable deterioration yet NRC, EPRI, NEMA, NEC, Sandia and Brookhaven have concluded there is not any proven technology to detect cable and splice degradation due to periodic submergence in a saltwater and otherwise chemically contaminated environment.

69. In addition Mr. Blanch agrees that, 10 CFR 50 Appendix A and B require testing and corrective actions however the fact that these failures are increasing with age indicates that proper corrective actions are not being implemented by the licensees. There is no recognized testing that can provide reasonable assurance that these cables can perform their intended functions. (Blanch Decl., 49)

70. Entergys Aging Management Plan (as amended by Entergy on January 7, 2011) lacks specificity. It fails to provide the public with reasonable assurance. Examples:

71. Definition Significant Moisture: In A.2.1.21, significant moisture is defined as periodic exposures that last more than a few days. There is no rationale provided to explain why exposure to moisture for a straight few days would cause any more 37

damage than would repeated exposure for shorter time periods. If the period of exposure, in the aggregant, adds up to or exceeds a few days, the moisture is significant. The issue is that Non-EQ cables are not designed for exposure to moisture, period.

72. Acceptance Criteria lacks specificity: B. 1.19 says for example that, The acceptance criteria include direct observations that the cables are not wetted or submerged, that cables/splices and cable support structures are intact, and that dewatering/drainage systems are functional. It ignores any testing to see if cables that cannot be directly observed are wetted or submerted. The acceptance criteria instead should include both teting and direct observations to insure that the cables have not been wetted or submerged, and that they remain, and should be expected to remain, fully functional.. But this cannot be done, simply because these cables are not qulaified for moist environments. Other examples of the insufficiency of Entergys commitments include::

x What does cable splices and cable support structures are intact mean? More important, what actions are requried if they are not intact? Entergy never says.

x What does dewatering/drainage systems are functional mean? For example, does it mean the drainage system allows 95% of the water to drain or less than 50 or 10%?

73. Entergy will evaluate unacceptable test results to determine the need for increasing the testing frequency. Absent here, and of particular concern to PW, is what if a test result is unacceptable? Does Entergy simply test the same failed cable more frequently in the future in the hope of getting a better test result,or does it do what it it should do - replace the unacceptable cable? Entergy also fails to 38

provide any indication of what constitutes an Unacceptable test result - the grading or pass/fail criteria - and the situation is exacerbated by the fact that neither NRC nor other third party is not mentioned as being involved in the oversight or grading process. In regard to the latter, there is no assurance that Entergys bottom line, and not public safety, is the driving force. Further the choice of other testing that is state-of-the-art at the time the tests are performed is too loose terminology and needs qualification. For example, who determines whether a program is state-of-the-art and best for Pilgrims site and issues at hand?

74. The Applicant has failed to address specific recommendations from the referenced Sandia report (SAND96-0344).

75. The Applicant has failed to address specific recommendations from the recently issued Brookhaven report funded by the NRC and titled Essential Elements of an Electric Cable Condition Monitoring Program NUREG/CR-7000.

76. There is no technical basis provided to justify differences between programs for aging management of accessible cables and inaccessible cables. 10 C.F.R. § 54.21(a)(3)

77. Entergys Letter No. 2.11.001, Attachment 1 (page 9) says that the program attributes of the Non-EQ Inaccessible medium-voltage cable program at PNPS will be consistent with the program attributes described in NUREG-1801, Revision 2, section XI.E3; and that there are no exceptions to NUREG-1801. However being consistent does not magically solve all problems described in this motion. Entergy heretofore argued that the Commission has held such a commitment provides reasonable assurance that the targeted aging effects will be adequately managed. (Entergys January 7, 2011 Op, pg., 26) Entergys statement does not provide any facts to support on what basis the 39

Commission has held, such a commitment provides reasonable assurance and neither does it judge its adequacy as applied specifically to Pilgrims site specific circumstances.

78. Mr. Blanchs Declaration at 26 says very clearly that Implementation of a program consistent with the vague guidance of the GALL revision provides no assurance that the proposed program is in compliance with NRC regulations and industry standards.

GALL must clearly recognize that these cables must be addressed under the requirement of 10 CFR 50.49.

79. The Applicant has not demonstrate(d) that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, 10 C.F.R. § 54.21(a)(3) for those SSCs identified.

Pilgrims Safety Evaluation Report (SER) NUREG-189119

80. PNPS SER Final Report (November 2007) does not provide reasonable assurance either, for at least the following reasons:

a. General Design Criterion 4 in Appendix A to 10 CFR Part 50 requires safety equipment to be designed for the environmental conditions it is subjected to during normal operation and postulated accidents. 10 CFR 50.49 requires electrical equipment to be qualified for the environmental conditions it experiences during normal operation and postulated accidents.

19 SER, NUREG 1891 http://adamswebsearch2.nrc.gov/idmws/doccontent.dll?library=PU_ADAMS^PBNTAD01&ID=07180005 4

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Rather than ensuing that cabling exposed to "significant moisture" is designed and qualified to operate under that condition (as required by NRC Regulations),

PNPS SER accepts under-designed and unqualified cabling as long as one periodically checks from time to time to see that the cables still work (at that moment), or are not then wet, submerged or degraded. The most troubling aspect of the SER is on page 3-18:

In this program, periodic inspections and drainage, as needed, for water collection in cable manholes and conduit prevent cable exposure to significant moisture. The condition of the conductor insulation for in-scope medium-voltage cables exposed to significant moisture will be tested at least every ten years; the specific test type to be determined before the initial test. The program will start prior to the period of extended operation.

"The specific test type to be determined before the initial test" means that no test type is now specified. It's an important test. When water accumulation is found, the test looks for damage to the in-scope medium-voltage cables exposed to that water. Because the test is not specified now, it's hard to conclude whether it is adequate or inadequate. The test might involve a mere visual examination of a dime-sized section of the cable insulation, assuming all other parts of the insulation are equally sound. Or it might be a more meaningful test. Absent a solid test, this whole exercise ends up little more than a water safari. We fail to see much assurance that a useful determination that exposure to "significant moisture" has not damaged the medium-voltage cables. That is, or should be, the whole point of it all.

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A recent report by the NRC Office of Inspector General (OIG), Office of Inspector Generals Audit of NRCs License Renewal Program20 made clear that neither the NRC nor the public can rely on the SERs conclusion that aging will be adequately managed so that the intended functions will be maintained consistent with the CLB over the extended period of operations. The OIGs audit revealed that, among other failures, the NRC Staffs license renewal review process is weak. In Section C of the report, the OIG concluded that:

most audit team members do not conduct independent verification of operating experience, instead relying on license-supplied information. This is because program managers have not established requirements and controls to standardize the conduct and depth of such reviews. In the absence of conducting independent verification of plant-specific operating experience, license renewal auditors may not have adequate assurances that relevant operating experience was captured in the licensees renewal application of NRCs consideration. [OIG-07-A-15, at 18] (Emphasis added)

There was no evidence that Pilgrims SER does not fit this description - no manhole cover was lifted for inspection for water or other independent verification occurred. Instead the SER at Pilgrim as described at 3-18 says that, the staff reviewed the operating experience presented in the LRA and interviewed the applicants technical personnel to confirm that the AMP complied with the 20 Office of Inspector Generals Audit of NRCs License Renewal Program, OIG-07-A-15, September 6, 2007. NRC ADAMS ML072490486 42

GALL. In other words, the staff simply reviewed what was in the LRA, asked the licensee a couple of clarifying questions and went away satisfied.

b. 3.0.3.1.5 Non-Environmental Qualification Inaccessible Medium-Voltage Cable Program The staff asked the applicant to explain how it had considered operating experience for manhole inspection frequency. Entergy responded that, the applicant revised the program evaluation report to include the following: The inspection will be based on actual plant experience with water accumulation in the manholes and the frequency of inspection will be adjusted based on the results of the evaluation, but the frequency will be at least once every 2 years. (3-19) NRC Staff was satisfied with this response; however, Entergy did not explain how often the inspections will occur or what procedure will be used. Will inspections be based on happenstance, convenience, or some random time period between 1-24 months?

The Staff also asked the applicant whether it inspects water in manholes under specific procedures for such inspections and, if so, for a copy of the procedures.

The applicant responded that it has no formal procedure. The Staff was satisfied that Entergy in Commitment No. 15-committed to develop a formal procedure to prevent cable exposure to significant moisture. However commitments do not provide details - when will it be established and what will it do? The time frame and/or procedure could be unsatisfactory. At this point in time neither the NRC Staff nor the public knows.

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The Staff asked the applicant to revise the AMP B.1.19 program evaluation report and define significant moisture for consistency with the GALL Reports scope or to explain how inaccessible medium-voltage cable exposed to significant moisture more than a few days and less than a few years is not susceptible to water treeing.

In its response, the Applicant revised the program evaluation report and said that, Significant moisture is defined as periodic exposure to moisture that last more than a few days (e.g., cable in standing water). Periodic exposure to moisture that lasts less than a few days (i.e., normal rain and drain) is not significant. Based on its review, the staff finds the applicants response acceptable because the scope of the program is consistent with that of the GALL Report. However, that definition does not provide reasonable assurance and NRC knows this to be true.

NRC Regulatory Issue Resolution Protocol Inaccessible or Underground Cable System Performance Issues at Nuclear Power Plants, January 21, 2010, Slide 4 (NRC Electronic Library, Adams Accession No ML100150850) Staff comments say in contrast that, Cable Aging Management Program Guides should address All cables subjected to any level of wetting or submergence. [Emphasis added]

c. 3.0.3.1.7 Non-Environmental Qualification Insulated Cables and Connections Program Somehow satisfying the Staff, the applicant revised LRA Section B.1.19 program description to read, 44

This program addresses cables and connections at plants whose configuration is such that most cables and connections installed in adverse localized environments are accessible. This program can be thought of as a sampling program. Selected cables and connections from accessible areas will be inspected and represent, with reasonable assurance, all cables and connections in the adverse localized environments. If an unacceptable condition or situation is identified for a cable or connection in the inspecting sample, a determination will be made as to whether the same condition or situation is applicable to other accessible cables or connections. The sample size will be increased based on an evaluation per the corrective program.

PW fails to understand how this provides reasonable assurance or satisfied Staff that was doing its job. First, and most important, there is no reason to believe that accessible cables are representative of inaccessible cables. In fact it is likely that inaccessible cables have a greater probability of being degraded. Further, for the described accessible cable program, no information is provided on what basis the determination will be made.

Routine Maintenance (Business as Usual) Does not Provide Reasonable Assurance

81. NUREG/CR 7000 (5.1 Conclusions) summarized by saying that 10 CFR Part 50 including Appendix A and B regulations require licensees to assess the condition of their components, to monitor the performance or condition of structures, systems, and 45

components in a manner sufficient to provide reasonable assurance that they are capable of performing their intended functions, and to establish a test program to ensure that all testing required to demonstrate that components will perform satisfactorially in service is identified and performed.

Recent incidents around the country, and at Pilgrim, involving early failures (IN 2010, IN 2002-12, Generic Letter 2007-01, Inaccessible or Underground Power cable failures That Disable Accident Mitigation Systems or Cause Plant Transients, suggest that licensees approaches to cable testing, such as in-service testing, surveillance testing, preventative maintenance, maintenance rule, etc., do not charaterize sufficiently the condition of cable insulation nor provide information on the extent of aging and degradation mechanisms that can lead to failure. The proof is in the pudding.

NUREG/CR 7000 (5.1 Conclusions) goes on to say that, In-service testing of safety-related systems and components can demonstrate the integrity and function of associated electric cables under test conditions.

However, in-service tests do not provide assurance that cables will continue to perform successfully when they are called upon to operate fully loaded for extended periods as they would under normal service operating conditions or under design basis conditions. In-service testing of systems and components does not provide specific information on the status of cable aging degradation processes and the physical integrity and dielectric strength of its insulation and jacket materials. (Emphasis added) 46

Some Recommendations, Examples

82. NUREG/CR 7000 put forward some rcommendations that Entergy has not met; and during the proceeding our expert(s) will both comment on these and address what further must.be done to provide any reasonable assurrance. For example, at 4-18 and 4-19, NUREG/CR 7000 discusses what could and should be done:,

Clearly, underground cable environments needed to be monitored for the presence of moisture or standing water. However, due to the inaccessibility of these cable circuits, indirect methods for inspection and measurement must be considered. Visual inspection for moisture or standing water, or the signs of flooding, such as accumulations of sand, mud, and silt or flooding high water marks, could be performed at accessible manhole vaults or cable pull boxes along the length of an underground duct bank. Site survey data on the elevations of the manhole vaults along the underground cable duct bank can then be used to determine whether manhole flooding has affected connected cable ducts. If available, site hydrological data on water table depth and how the water table is affected by site precipitation or the water surface level in nearby bodies of water can also be used to determine where underground cable flooding may be occurring. Illuminated borescopes, such as those used for internal inspection of pipelines, can be routed down into underground duct banks or conduits to visually inspect for standing water or the signs of flooding, such as accumulations of sand, mud, and silt. Cable conduits that are above flood level elevation, but are susceptible to moisture intrusion, such as described in Information Notice 89-63 [Ref. 3621], can be checked for water accumulation using ultrasonic inspection at low points.

21 US NRC Information Notice 89-63, Possible Submergence of Electrical Circuits Located Above the Flood Level Because of Water Intrusion and Lack of Drainage, U.S. Nuclear Regulatory Commission, September 5, 1989.

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Some of the condition monitoring tests for cables performed for implementation of element 7 of the cable CM program, described in subsection 4.7, can be used to detect and locate the presence of water along the length of an electric cable. Time domain reflectometry (TDR), the ECAD inspection system, and the newer line resonance analysis (LIRA) technique, which are described in Section 3 of this report, may be able to accomplish this.

The results of electrical property measurement CM tests from program element 7 that can detect water treeing or the degradation of insulation dielectric strength resulting from water treeing could be reviewed as another indirect method for determining whether it is or has been operating in a submerged condition. CM measurement techniques such as insulation resistance/polarization index testing, dc high potential testing, and VLF withstand testing, can be used to check the condition of cables that may be exposed to water. Test results indicating weakened dielectric strength, or trends of unusually rapid deterioration of dielectric strength between successive testing periods, could be an indication of power cables operating in a submerged condition over extended periods of time.

The output results of the CM program element 3 monitoring of cable operating environment activities will be periodic environmental measurements, data, and inspection results for global and local cable operating environments for those cables selected for monitoring in the CM program. The periodic environmental monitoring information for each cable circuit is documented in the CM program database. These data, together with the baseline environmental characterization information, and will be available for review by the cable engineer under CM program element 9, in order to make decisions on managing cable operating environments.

And at 5.2 Recommendations, NUREG /CR 7000 concludes, 48

Special consideration should be given the problem of monitoring the operating environment for cable circuits routed through inaccessible underground cable ducts and conduits, covered cable distribution trenches, and manhole vaults because they can frequently become flooded resulting in power and control cables operating in wetted and completely submerged conditions for extended periods of time. Unless the installed cables have been procured specifically for continuous submerged or submarine operation, the licensees should ensure that cables installed in duct banks, manholes, bunkers and direct burial applications, are provided with proper drains, sumps, alarms and other protective measures and inspection activities to ensure that they are monitored and maintained in a dry environment.

These recomendations go far beyond what Entergy provided in their Aging Management Program. There is no excuse for providing less protection of the public especially in consideration of the following. Pilgrim has submerged Non-EQ inaccessible cables.

Pilgrim is not located on a dessert; instead it is located adjacent to Cape Cod Bay and in a climate subject to snow, rain and fog. Pilgrim has failed to perform a thorough up-dated hydro-geological anlaysis over the entire site since 1967 (pre-construction) so they do not have a clue concerning subsurface groundwater flow. License renewal adds an additional 20 years of operation, and GL 2007-01 showed a trend toward early failure, the majority occuring in the range of 11-20 years of service.

83. Mr. Blanch, at 43, quotes extensively from NUREG/CR-7000 study, including statements that electrical equipment important to safety, including electric cables must be environmentally qualified in accordance with the requriements of 10 CFR 50.49:

Electric equipment important to safety, including electric cables, that are required to continue to successfully perform their safety function in the harsh 49

environment throughout the duration of and following design basis events occurring at the end of their qualified life, must be environmentally qualified in accordance with the requirements of 10 CFR 50.49.

And NUREG/CR-7000 goes on to say:

NRC regulations, such as 10 CFR 50, Appendix B, (quality assurance), the maintenance rule (10 CFR 50.65), and environmental qualification regulations (10 CFR 50.49), require that programs and administrative controls be established to monitor and detect degraded conditions on a regular basis and to promptly implement effective corrective actions The licensees listing of environmentally qualified (EQ) Class 1E electric cables, as defined in 10 CFR 50.49 and IEEE Std. 323-1974 [Ref. 32], will be a subset of the entire listing of safety-related cables in the plant. However, since there may be some non-safety-related cables that are specified with environmental qualification requirements as a result of potential exposure to other-than-mild, or locally adverse, service environments, the listing of EQ cables should be reviewed to determine whether there are any cables in this category that should be added to the list of cables for the CM program environmental qualification regulations (10 CFR 50.49), require that programs and administrative controls be established to monitor and detect degraded conditions on a regular basis and to promptly implement effective corrective actions and design modifications, consistent with its safety significance, so that any further cable degradation is minimized. A cable system must be designed to meet all applicable regulations and to perform its intended function in the plant environment under all anticipated operational occurrences and design basis events.

NRC regulations, such as 10 CFR 50, Appendix B, (quality assurance), the 50

maintenance rule (10 CFR 50.65), and environmental qualification regulations (10 CFR 50.49), require that programs and administrative controls be established to monitor and detect degraded conditions on a regular basis and to promptly implement effective corrective actions and design modifications, consistent with its safety significance, so that any further cable degradation is minimized.

4.3.1 Characterizing Cable Operating Environments Characterization of the cable systems operating environments is necessary to establish and document the actual baseline environmental conditions that the cable system will be exposed to during normal operations. It is accomplished by:

x review of the design, specification, and installation documentation for the cable circuit, in order to locate the routing of the cable circuit throughout the plant; x It should be emphasized that the occurrence of cable system operating environments or locally adverse conditions that are unanticipated or more severe than the original plant design may constitute a design deficiency of the cable system, specifically, a potential violation of GDC 1, 4, 17, and 18. NRC regulations, such as 10 CFR 50, Appendix B, (quality assurance), the maintenance rule (10 CFR 50.65), and environmental qualification regulations (10 CFR 50.49), require that programs and administrative controls be established to monitor and detect degraded conditions on a regular basis and to promptly implement effective corrective actions design modifications, consistent with its safety significance, so that any further cable degradation is minimized. A cable system must be designed to meet all applicable regulations and to perform its 51

intended function in the plant environment under all anticipated operational occurrences and design basis events. (2-16)

Conclusion Even as amended, Entergys Aging Management Plan for non-environmentally qualified (EQ) inaccessible cables (splices) at Pilgrim Station is insufficient. The Aging Management Plan should include a program that assures all inaccessible cables are in

[1]

compliance with existing NRC Regulations discussed in Regulatory Issue Resolution Protocol Inaccessible or Underground Cable Performance Issues at Nuclear Power Plants, August 19, 2009. (NRC Electonic Library, Adams Accession No. ML092460425).

Also, as Pilgrim Watchs expert, Mr. Blanch, concluded (Decl., 53), It is very clear that if Pilgrim is granted its license renewal it must clearly demonstrate compliance with the all the requirements of 10 CFR 50.49 with concentration on 10 CFR 50.49(d)(5) and (6) and any in scope cables, and that aging and submergence be addressed within the requirements of this regulation. Further, Mr. Blanch added (Decl., 54), In lieu of any other program which is not proven, addressing the requirements for design, testing, construction and environmental qualification, 10 CFR 50.49 may provide reasonable

[1]

10 CFR Part 50, Appendix A, General Design Criterion (GDC) 2, Design Bases for Protection Against Natural Phenomena.

10 CFR Part 50, Appendix A, General Design Criterion (GDC) 4, Environmental and Dynamic Effects Design Bases.

10 CFR Part 50, Appendix A, GDC 17, Electric Power Systems.

10 CFR Part 50, Appendix A, GDC 18, Inspection and Testing of Electric Power Systems.

10 CFR 50.65(a)(1), Maintenance Rule.

10 CFR 50.49, Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants.

10 CFR 50.49, Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power

Plants, 10 CFR Part 50, Appendix B, Criterion III, Design Control.

10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings.

10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings.

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assurance that no other proposed program can provide. Risk will increase as Non-EQ cables age. (Blanch Decl., 52) Failure to address this issue before license renewal is granted could result in significant and unnecessary harm to the health and safety of the public.

VII. THE CONTENTION IS TIMELY Under 10 C.F.R 2.309(c), the determination whether the filing of a contention is non-timely is based on a balancing of eight factors, the most important of which is good cause, if any, for the failure to file on time. Crow Butte Resources, Inc.

(North Trend Expansion Project), LBP-08-6, 67 NRC 241 (2008)

The factors, and how each points to the conclusion that this contention should be accepted, are set forth below.

1. Good cause, if any, for failure to file on time.

The information upon which this contention is based did not become available to the public (including Pilgrim Watch) until January 7, 2011. From Entergy Answer Opposing Pilgrim Watch Request for hearing on a New Contention (January 7, 2011) and NRC Staffs Answer in Opposition to Pilgrim Watchs Request for Hearing on New Contention (January 7, 2011), PW learned new information:

x On December 23, 2010, 10 days after PWs Request for a New Hearing was filed, the NRC made publicly available a new GALL revision (Rev. 2), its first since 2005, dealing with, among other things, issues presented by inaccessible electric cables.

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x On January 7, 2011, Entergy amended its AMP to provide new commitments related to inaccessible electric cables.

Good cause has been consistently interpreted to mean that a proposed new contention be based on information that was not previously available, and was timely submitted in light of that new information. Dominion Nuclear Connecticut, Inc.

(Millstone Nuclear Power Station, Unit 3), CLI-09-5, 69 N.R.C. 115, 125-26 (2009) citing Pacific Gas & Electric Co. (Diablo Canyon Power Plant Independent Spent Fuel Storage Installation), CLI-08-1, 67 N.R.C. 1, 6 (2008). See also, NRC Digest, Prehearing Matters, 29: Newly arising information has long been recognized as providing "good cause" for acceptance of a late contention. Consumers Power Co. (Midland Plant, Units 1 and 2), LBP-82-63, 16 NRC 571, 577 (1982), citing Indiana and Michigan Electric Co.

(Donald C. Cook Nuclear Plant, Units 1 and 2), CLI-72-75, 5 AEC 13, 14 (1972);

Cincinnati Gas and Electric Co. (William H. Zimmer Nuclear Station), LBP-80-14, 11 NRC 570, 574 (1980), appeal dismissed,ALAB-595, 11 NRC 860 (1980).

Here is it clear that (1) the information is new and could not have been presented earlier, and (2) Pilgrim Watch acted promptly after learning of the new information.

Texas Utilities Electric Co. (Comanche Peak Steam Electric Station, Units 1 and 2), CLI-92-12, 36 N.R.C. 62, 69-73 (1992)2.

2. The nature of the requestors/petitioners right under the Act to be made a party to the proceeding.

Pilgrim Watch is already a party, and thus clearly has the right under the Act to be, a party to this proceeding.

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3. The nature and extent of the requestors/petitioners property, financial or other interest in the proceeding.

As said in Pilgrim Watchs originally filed petition (Request For Hearing And Petition To Intervene By Pilgrim Watch -May 25, 2006. Pg.1), and as remains the case, Pilgrim Watch is a non-profit citizens organization located at 148 Washington Street, Duxbury, Massachusetts, 02332. It is represented pro se by Mary Lampert who makes her residence and place of occupation and recreation within ten (10) miles of Pilgrim Nuclear Power Station. Under 10 CFR § 2.309 Petitioners have standing to intervene in the license renewal proceedings of Pilgrim because they live within 10 miles of the facility.

For reactor construction and licensing proceedings, the NRC has recognized a presumption that people who live within close proximity of the facility (50 miles) have standing to intervene in the proceedings.

4. The possible effect of any order that may be entered in the proceeding on the requestors/petitioners interest.

Petitioners believe that if Pilgrim is allowed to operate for an additional twenty years without taking the mitigation steps required by virtue of this contention that there will be an unacceptable risk to the environment jeopardizing the health, safety, property and finances of Petitioners' members who live, recreate, conduct business and own property within the vicinity of the Pilgrim Nuclear Power Station.

5. The availability of other means for protecting the petitioner's interests.

None of the factors suggesting other means referred to in Sec. 2,10.3.3.3E Factor #5 of the NRC Digest are present here. There is no state judicial forum or other NRC licensing procedure to which Pilgrim Watch can take its concerns regarding the fact 55

that Entergys Aging Management Plan for non-environmentally qualified (EQ) submerged cables, splices and connectors at Pilgrim Station is insufficient to provide the necessary reasonable assurance that public health and safety shall be protected during license renewal. (See, Private Fuel Storage, L.L.C. (Independent Spent Fuel Storage Installation), LBP-00-23, 52 NRC 114, 121-122 (2000)). The suggestion that an organization could adequately protect its interest by submitting a limited appearance statement gives insufficient regard to the value of participational rights enjoyed by parties

- including the entitlement to present evidence. Similarly, assertions that the organization might adequately protect its interest by making witnesses available to a successful petitioner or by transmitting information in its possession to appropriate State and local officials are without merit. Duke Power Co. (Amendment to Materials License SNM-1773 -- Transportation of Spent Fuel from Oconee Nuclear Station for Storage at McGuire Nuclear Station), ALAB-528, 9 NRC 146, 150 n.7 (1979). NRC Digest, Prehearing Matters, 38. And a petition under 10 C.F.R. § 2.206 for a show cause proceeding is not an adequate alternative means of protecting a late petitioner's interests.... Washington Public Power Supply System (WPPSS Nuclear Project No. 3)

ALAB-747, 18 NRC 1167, 1175-1176 (1983). See Florida Power and Light Co. (Turkey Point Nuclear Generating Plant, Units 3 and 4), LBP-90-5, 31 NRC 73, 81 (1990), aff'd, ALAB-950, 33 NRC 492, 495-96 (1991). After all, despite the long history of §2.206, the number of successful petitions brought under that section is extremely small. Dominion Nuclear Connecticut, Inc. (Millstone Nuclear Power Station, Units 2 and 3), LBP-05-16, 62 NRC 56, 67 (2005) (Id.)

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6. The extent to which the petitioner's interest will be represented by existing parties.

The other parties to this proceeding are Entergy and the NRC Staff. Throughout this proceeding both NRC Staff and Entergy (in concert with each other) have consistently opposed Pilgrim Watchs interests. There is no reasonable basis to expect that leopard will change its spots. The NRC has accurately recognized that, In weighing the [sixth] factor, a board will not assume that the interests of a late petitioner will be adequately represented by the NRC Staff. The general public interest, as interpreted by the Staff, may often conflict with a late petitioner's private interests or perceptions of the public interest. Washington Public Power Supply System (WPPSS Nuclear Project No. 3), ALAB-747, 18 NRC 1167, 1174-1175 n.22 (1983).

NRC Digest, Prehearing Matters, 35; see also NRC Practice Digest, Prehearing Matters 33: Participation of the NRC Staff in a licensing proceeding is not equivalent to participation by a private intervenor.

The Board accurately summarized the realities in Turkey Point (NRC Practice Digest, Prehearing Matters, 34-35):

"To what extent will Petitioners' interest be represented by existing parties?" must be answered, "None."

7. The extent to which petitioner's participation will broaden the issues or delay the proceeding.

The issue presented by this contention - Entergys Aging Management Plan for non-environmentally qualified (EQ) inaccessible cables and splices at Pilgrim Station is 57

insufficient to provide the necessary reasonable assurance that public health and safety shall be protected during license renewal is new. The ASLB has not looked at this before.

However, this factor includes only that delay which can be attributed directly to the tardiness of the petition. Jamesport, supra, ALAB-292, 2 NRC at 631; South Carolina Electric and Gas Co. (Virgil C. Summer Nuclear Station, Unit 1), LBP-81-11, 13 NRC 420, 425 (1981). Here, there is nothing tardy about Pilgrim Watchs petition to add this new petition. It is based on information that became public only a short time ago.

8. The extent to which petitioner's participation might reasonably assist in developing a sound record.

Absent Pilgrim Watchs participation, it is apparent that neither any other party nor the Board will develop any record whatever regarding the subject of this contention.

Pilgrim Watch intends to cover the inadequacies of Entergys Aging Management Program for Non-Environmentally Qualified Inaccessible Cables (Splices) at Pilgrim Station. Pilgrim Watch has provided in this new contention ample evidence to support its dispute. Pilgrim Watch intends principally to rely upon government documents and testimony from Paul Blanch, nuclear engineer specializing in electrical. The Petitioner satisifies 10 C.F.R 2.309(d), Standing: The Petitioner already is a party to this hearing and has satisfied the requirements.

PW does not seek to reopen the record.

As they did in opposing PWs New Contention filed November 29, 2010, Entergy (Entergy Op. 10-14) and the NRC Staff (Staff Op 4-8) and did again in their oppositions to PWs New Contention filed on Cables filed December 13, 2010, we expect once again that Entergy and NRC Staff will start any argument with this contention that PW has not 58

met the requirements for reopening the record under 10 C.F.R. §2,236. As before, Entergy and the Staff would be wrong.

Rule 2.236 is clear. It applies to A motion to reopen a closed record. The Rule does not apply here, for a simple reason - the record in this proceeding has not been closed. The evidentiary record relating to Contention 1 was, as the Staff says, closed some time ago. But Pilgrim Watch does not seek to introduce any new evidence as to Contention 1; rather it seeks to add a new, in scope, contention to the proceeding.

The Staff again fails to recognize that the record in this proceeding (as contrasted with the record for Contention 1) unquestionably has not been closed. As a matter of fact, a hearing at which new evidence as to Contention 3 will be accepted is scheduled for March 9, 2011.

Entergys previous argument was equally wide of the point. Its failure even to mention the third criteria - that a materially different result would be likely - simply shows why Rule 2.236 does not apply; the new contention does not involve any prior result.

In short, the record in this proceeding is open until and unless the Board and the Commission close it with respect to everything involved in this proceeding. At the time PW submitted its new contention, and as of today, the record before this Board remains open. There is no need to reopen it; and Sec. 2.326 is simply inapplicable.

Further, this contention should be accepted even if the record had been closed.

This Board has the duty to reopen sua sponte when [it] becomes aware, from any source, of a significant unresolved safety issue or of possible major changes in facts 59

material to the resolution of major environmental issues. See NRC Practice Manual, Post Hearing Matters, 11-12.22 VI. CONCLUSION With respect to adequate assurance of public health and safety the AMP for Pilgrim must be revised so that either Pilgrim is required to replace all cables (and splices) that may be exposed to submergence with cables procured as submarine cables (IN 2010-26 at 6) or develop a comprehensive aging management program, incorporating recommendations suggested in the foregoing, to assure compliance with existing NRC regulations cited above.23 Signed Electronically, Mary lampert Pilgrim Watch, pro se 148 Washington Street Duxbury, MA 02332 Tel. 781-934-0389 Email mary.lampert@comcast.net January 20, 2011 22 The inclusion of this provision in Post Hearing Matters provides additional evidence that the record is not now closed and 2.236 is not applicable.

23 Honorable Gregory B. Jaczko Chairman speech to INPO on November 9, 2010 said, [Y]ou must remember that compliance with NRC regulations is the foundation for the safety excellence that you strive for. Safety excellence includes more than just compliance, but it starts with compliance.

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ATTACHMENTS x Attachment 1: Declaration of Paul M. Blanch, January 19, 2011 x Attachment 2: Entergy as Exhibit A to Entergys Answer Opposing Pilgrim Watchs Request for Hearing on a New Contention. Entergy Letter No. 2.06.003 x Attachment 3: NRC Information Notice 2010-26: Submerged Electrical Cables, December 2, 2010 (Adams Accession No.

ML102800456) x Attachment 4: NRC Integrated Inspection Report 05000293/2010003, 1RO6 Flood Protection Measures, July 29, 2010 (Adams Accession No. ML102100150) 61

ATTACHMENT 1: Declaration of Paul M. Blanch, January 19, 2011, attached as separate document 62

ATTACHMENT 2: Entergy as Exhibit A to Entergys Answer Opposing Pilgrim Watchs Request for Hearing on a New Contention. Entergy Letter No. 2.06.003, attached as separate document 63

ATTACHMENT 3:

UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION OFFICE OF NEW REACTORS WASHINGTON, DC 20555-0001 December 2, 2010 NRC INFORMATION NOTICE 2010-26: SUBMERGED ELECTRICAL CABLES ADDRESSEES All holders of an operating license or construction permit for a nuclear power reactor issued under Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities, except those who have permanently ceased operations and have certified that fuel has been permanently removed from the reactor vessel.

All current and potential applicants for a combined license or standard design certification for a nuclear power plant under the provisions of 10 CFR Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plants. All current and potential applicants for a construction permit under the provisions of 10 CFR Part 50.

PURPOSE The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice (IN) to inform addressees of observations of protracted cable submergence in water, recent NRC inspection findings, and the results of licensees responses to Generic Letter (GL) 2007-01, Inaccessible or Underground Power Cable Failures That Disable Accident Mitigation Systems or Cause Plant Transients, dated February 7, 2007 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML070360665). Furthermore, this IN provides additional clarification to IN 2002-12, Submerged Safety-Related Electrical Cables, dated March 21, 2002 (ADAMS Accession No. ML020790238), through the NRCs observations of the submergence in water of electrical cables that feed safety-related equipment at certain facilities.

The NRC expects recipients to review the information for applicability to their facilities and consider taking action, as appropriate, to avoid similar problems. The suggestions that appear in this IN are not NRC requirements; therefore, no specific action or written response is required.

DESCRIPTION OF CIRCUMSTANCES Monticello Nuclear Generating Plant On September 11, 2008, a double phase-to-ground fault occurred on the underground feeder cables (offsite power) routed from the 2RS (345-kilovolt (kV)/34.5-kV) transformer to the 2R (34.5-kV/4.16-kV) transformer at the Monticello Nuclear Generating Plant. On December 16, 2008, the NRC issued Inspection Report 05000263/2008-009 (ADAMS Accession No. ML083510254), which documented the results of a special inspection that it performed at the plant. The special inspection evaluated the facts and circumstances surrounding the loss of normal offsite power and resultant reactor trip and other complications that occurred on September 11, 2008. The inspectors identified a violation for the licensees failure to establish an effective monitoring and corrective action plan that included the 34.5-kV underground feeder cables in the scope of a monitoring program that met the requirements of 64

IN 2010-26 Page 2 of 8 10 CFR 50.65(a)(1). This cable was found submerged, as the manhole was full of water above the level of the conduits. The licensees evaluation of the cable failure determined that the faults did not occur in the section of cable that was found submerged.

The inspectors determined that the licensees preventive maintenance and testing methodology for the 34.5-kV cables was not sufficient to establish the condition of the cables, and, therefore, the exemption of 10 CFR 50.65(a)(2) was not applicable. Additionally, the preventive maintenance and testing methodology implemented by the licensee for the 34.5-kV cables did not provide the information necessary to ensure that the 2R transformer was capable of fulfilling its intended function. Therefore, the licensee had not effectively assessed the performance goal before the failure. Thus, the exemption of 10 CFR 50.65(a)(2) was not applicable. Following the cable failure, the licensee performed tan-delta and partial discharge (PD) cable performance monitoring tests to identify the extent of the cable degradation. The tan-delta testing indicated that the A2 phase conductor (which failed on September 11, 2008) had a severe fault at a second splice location, and, therefore, the licensee needed to replace the splice. The PD testing identified termination problems in the B2 and C2 cable conductor splices and at the stress cones. To address these deficiencies, the licensee repaired or replaced the faulted cable. The licensee is implementing a cable monitoring and testing program to monitor the performance of the cables.

Fermi Power Plant, Unit 2 On September 11, 2007, the NRC issued Inspection Report 05000341/2007-003 (DRS)

(ADAMS Accession No. ML072540412), which documented the results of a component design bases inspection that it performed at the Fermi Power Plant, Unit 2. The emergency diesel generator cables installed between the residual heat removal complex and the reactor building, which were located below the maximum ground water level, were not designed for continuous underwater service. The inspectors identified a violation of Criterion III, Design Control, of Appendix B to 10 CFR Part 50, for the licensees failure to implement licensing and design-basis requirements when the licensee specified and purchased safety-related and nonsafety-related cables. The inspectors noted that the licensee failed to ensure that the cables were designed for continuous underwater service, which is contrary to statements made in the licensees updated final safety analysis report. The licensee entered the finding into its corrective action program to investigate the design of the cables and to institute a cable management program.

Point Beach Nuclear Plant On April 21, 2008, the NRC issued Inspection Reports 05000266/2008-007 and 05000301/2008-007 (ADAMS Accession No. ML081130194), which documented the results of the agencys special inspection. The purpose of the special inspection was to review the circumstances surrounding the loss of the Point Beach Nuclear Plant, Unit 1, 1X-04 transformer that resulted in the loss of safety bus 1B-04 at the plant. One of three violations identified during the inspection dealt with the licensees failure to establish a test program that would adequately demonstrate that medium-voltage cables subjected to submergence in water would perform satisfactorily in service. Specifically, the online, energized PD testing methodology that the licensee had adopted in approximately 2001 to periodically assess the condition of submerged power cables failed to provide any indication of declining cable performance or an indication of an imminent failure of the transformer cables before the actual failure on January 15, 2008.

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IN 2010-26 Page 3 of 8 On May 11, 2010, the NRC issued Inspection Reports 05000266/2010-002 and 05000301/2010-002 (ADAMS Accession No. ML101310428), which documented a violation of the requirements in Criterion XVI, Corrective Action, of Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, to 10 CFR Part 50 because of the licensees failure to implement timely corrective actions to address the longstanding issue of submerged, medium-voltage underground cables at the Point Beach Nuclear Plant.

Specifically, the NRC first identified this issue in 1997, with numerous condition reports written by the licensee since that time. The licensee entered this issue into its corrective action program. The licensees corrective actions included the increased monitoring and pumping of manholes, and its proposed actions include design changes to support the automatic monitoring and removal of water from the manholes.

The medium-voltage cable condition monitoring program at the Point Beach Nuclear Plant was subsequently inspected during the Post-Approval Phase 2 License Renewal inspection. The inspection was documented in NRC Inspection Report 05000266/2010-011 (ADAMS Accession No. ML102850469). Inspections of commitments associated with the cable condition monitoring program were concluded to be acceptable.

Beaver Valley Power Station, Units 1 and 2 On August 4, 2009, the NRC issued Inspection Reports 05000334/2009-003 and 5000412/2009-003 (ADAMS Accession No. ML092160021), which documented the results of an inspection at the Beaver Valley Power Station, Units 1 and 2. The inspectors identified a violation of Criterion III, Design Control, of Appendix B to 10 CFR Part 50, whereby First Energy Nuclear Operating Company (FENOC), the licensee for the Beaver Valley Power Station, Units 1 and 2, failed to maintain safety-related cables in an environment for which these cables were designed. Since the NRC issued IN 2002-12, FENOC has had several opportunities to trend as-found data, implement effective maintenance programs, and identify and thoroughly evaluate long-term adverse conditions for underground safety-related cables exposed to continuous submerged environments. The cables affected include those for Unit 1 river water and Unit 2 service water. FENOC entered the issue into its corrective action program to initiate a review of the current manhole and cable monitoring programs, as well as long-term corrective actions.

Wolf Creek Generating Station On November 7, 2008, the NRC issued Inspection Report 05000482/2008-004 (ADAMS Accession No. ML083120336), which documented the results of an inspection at the Wolf Creek Generating Station. The inspectors identified a violation of Criterion III, Design Control, of Appendix B to 10 CFR Part 50 because the licensee failed to adequately demonstrate that submerged 4,160-volt cables are designed or qualified for such service and that they would continue to remain operable. These cables include those of residual heat removal, containment spray, and essential service water. The licensee has subsequently written a condition report and work orders to inspect cables and dewater cable vaults and has conducted tests to monitor the performance of the cables.

IN 2010-26 Page 4 of 8 66

Callaway Plant On October 21, 2009, the NRC issued Inspection Report 05000483/2009-004 (ADAMS Accession No. ML092940774), which documented the results of an inspection at the Callaway Plant. The inspectors identified a violation of Criterion XVI, Corrective Action, of Appendix B to 10 CFR Part 50 because the licensee failed to take prompt corrective actions to prevent continuous submergence of essential service water pump power cables. The licensee initially identified this submergence issue in its corrective action program (action request) in 2002, but it did not complete the corrective actions. The continuously submerged environment for these cables existed because the two vaults containing these cables (MH-01N and MH-01S) had inadequate seals that are needed to protect the vaults from incoming surface water. These cables were not designed to be continuously submerged and could fail over time based on the operating experience examples in GL 2007-01 and IN 2002-12. The licensee failed to correct an inadequate and degraded seal design for underground cable vaults MH-01N and MH-01S and failed to adequately demonstrate operability for the 4.16-kV essential service water pump cables through adequate testing and analysis for a continuously submerged condition. This violation was determined to be of very low safety significance because the degraded seals were a design or qualification deficiency confirmed not to result in loss of operability. The licensee has subsequently taken measures to improve the seals and has created a Callaway corrective action document to further evaluate and correct this issue.

Peach Bottom Atomic Power Station, Units 2 and 3 On February 8, 2010, the NRC issued Inspection Reports 05000277/2009-005 and 05000278/2009-005 (ADAMS Accession No. ML100390108), which documented the results of a routine inspection at the Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3. The inspectors identified a violation of Criterion III, Design Control, of Appendix B to 10 CFR Part 50 because the licensee failed to maintain safety-related power cables (including low-voltage cables) in an environment for which they were designed and tested. Specifically, the licensee did not adequately select and review a 480-volt alternating current power cable for suitability of application of materials. The cable feeds a safety-related motor control center that has been in a submerged environment in a manhole for an extended period of time (at least since 2002). Additionally, PBAPS personnel did not take actions to properly evaluate and mitigate the effects of long-term submergence of these safety-related electrical power cables.

To address this issue, the licensee entered it into its corrective action program.

Three Mile Island Nuclear Station On July 31, 2009, the NRC issued Inspection Report 5000289/2009-003 (ADAMS Accession No. ML092120364), which documented the results of a routine inspection at the Three Mile Island (TMI) Nuclear Station, Unit 1. The inspectors identified a violation of Criterion V, Instructions, Procedures, and Drawings, of Appendix B to 10 CFR Part 50 because the licensee failed to establish and accomplish appropriate work instructions and procedures to inspect underground electrical cables, vaults, and supports for degradation or adverse effects caused by long-term repetitive submergence in water. TMI personnel had not entered the cable vaults, and TMI procedures did not require the actual visual inspection of the cables, supports, or vaults sufficient to determine operability. Furthermore, the licensee did not take action to identify or remediate the cause of the repetitive flooding and to restore the function of the designed cable vault drain systems. The inspectors observed corroded cable tray supports, damaged galvanized armor protective sleeves on cables, and indications of repetitive long-term cable submergence in water. The licensee entered, inspected, and dewatered all affected IN 2010-26 Page 5 of 8 vaults. The licensee initiated work orders to correct all identified discrepancies. Some of the 67

licensees proposed corrective actions included the implementation of a cable vault improvement initiative such as preventing rainwater intrusion, lid repair, installing lid gaskets, applying sealant to the lids, concrete repair, cable support repair, improving the grading/surrounding environment to prevent water runoff into the vaults, and restoring and maintaining French drains and other drains between vaults.

Vermont Yankee Nuclear Power Station On May 10, 2010, the NRC issued Inspection Report 05000271/2010-002 (ADAMS Accession No. ML101300363), which documented the results of an inspection at the Vermont Yankee Nuclear Power Station. The inspectors identified a violation of Criterion III, Design Control, of Appendix B to 10 CFR Part 50 because Entergy (the licensee for the Vermont Yankee Nuclear Power Station) did not select and review safety-related cables suitable for application in the environment in which they were found. Specifically, Entergy allowed the continuous submergence of safety-related cables that were not designed or qualified for continuous submergence and failed to demonstrate that the cables would remain operable. Entergy initiated condition reports to address the issues, commenced the dewatering of the affected manholes, and initiated a preventive maintenance plan to ensure proper design conditions. The finding was determined to be of very low safety significance because it was a design or qualification deficiency which was confirmed to have not resulted in a loss of operability or functionality. Specifically, the continuously submerged cables were not designed or qualified for that environment but were still fully capable of performing their design functions.

BACKGROUND Cable failures have a variety of causes, including manufacturing defects, damage caused by shipping and installation, and exposure to electrical transients or abnormal environmental conditions during operation. Latent shield or insulation damage could result from errors during cable installation, which could be caused by cable jamming, cable pull-bys, cable sidewall bearing pressure, pulling cables through conduits and flexible conduit, or computerized cable routing system software routing cables through the wrong raceway. The likelihood of failure from any of these factors increases over time as the cable insulation degrades and/or is exposed to water.

During the license renewal and routine baseline inspections, NRC inspectors identified numerous inspection findings that indicate that some licensees are not maintaining cables important to safety in an environment for which they were designed.

On March 21, 2002, the NRC staff issued IN 2002-12, which described medium-voltage cable failures at the Oyster Creek Nuclear Generating Station and the Davis-Besse Nuclear Power Station. The cable failures resulted from submerged safety-related cables in manholes and duct banks that were subjected to long-term flooding problems. Based on the operating experience described in IN 2002-12, several licensees began manhole restoration projects, replaced faulty dewatering equipment and cable supports, and made other modifications.

During a meeting on the license renewal application for the St. Lucie Plant in April 2003, members of the Advisory Committee on Reactor Safeguards questioned whether cable issues were also applicable in accordance with 10 CFR Part 50. The NRC staff responded that the staff of the Office of Nuclear Reactor Regulation (NRR) would evaluate the Committees concerns. The NRR staff reviewed the available operating experience of cable failures and IN 2010-26 Page 6 of 8 68

observed that some cables at nuclear power plants, which were qualified for 40 years through licensees equipment qualification programs, were failing before the end of the qualified life of the cables. The staff identified 23 licensee event reports and two morning reports from 1988 to 2004 that described failures of buried medium-voltage alternating current and low-voltage direct current power cables that resulted from insulation failure. In most of the reported cases, the failed cables had been in service for 10 years or more. The NRR staff confirmed that the subject issue was applicable in accordance with 10 CFR Part 50 for operating reactors.

In 2006, the NRC began a detailed review of underground electrical power cables after moisture-induced cable failures were identified at some plants. The cables were exposed to submergence in water, condensation, wetting, and other environmental stresses. Because these cables are not designed or qualified for submerged or moist environments, the possibility that more than one cable could fail has increased; this failure could disable safety-related accident mitigation systems. On February 7, 2007, the NRC issued GL 2007-01 to gather information on inaccessible or underground power cable failures for all cables that are within the scope of the Maintenance Rule (10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants).

DISCUSSION Based on the above, the NRC expects licensees to identify conditions that are adverse to quality for cables, such as long-term submergence in water. Upon discovery of a submerged condition, the licensee should take prompt corrective actions to restore the environment to within the cables design specifications, immediately determine the operability of the cable(s) to perform its intended design function, and determine the impact of the adverse environment on the design life of the cable. These corrective actions typically involve the removal of water, the installation of a sump pump or the repair of the drainage conditions, and evaluation of the operability of the cable(s) including testing where appropriate. The long-term corrective actions could involve establishment of a condition monitoring program for all cables which are inaccessible and underground and under the maintenance rule, including testing of cables to verify the cables are not degraded and visual inspection of manholes for water accumulation to ensure continued operability.

Cables are not typically designed or qualified for submergence unless they are procured as submarine cables. Demonstration that a cable is designed or qualified for long-term submergence (i.e., submerged in water continuously or for extended periods of time) requires a qualification test report or certification from the cable vendor. The industrys previously conducted post-loss-of-coolant accident cable submergence tests do not demonstrate qualification for long-term cable submergence, and the use of the Arrhenius methodology by some licensees to demonstrate qualification for long-term cable submergence is invalid. For areas in which cables could be submerged, the licensee should identify and demonstrate that these cables are designed or qualified by documented testing for the required duration.

While the initial NRC inspection findings discussed in IN 2002-12 at Beaver Valley Power Station, Oyster Creek Nuclear Power Plant, Pilgrim Nuclear Power Station, Brunswick Steam Electric Plant, Davis-Besse Nuclear Power Station, and Millstone Power Station, Unit 2, did not identify any specific violations of NRC requirements, the NRC staff will evaluate future cable submergence issues to determine whether NRC regulations are being met.

IN 2010-26 Page 7 of 8 The NRC issued GL 2007-01 to gather information on inaccessible or underground power cable 69

failures for all cables within the scope of the Maintenance Rule. The NRC staff identified 269 cable failures based on its review of responses from all licensees (65 sites and 104 reactor units). These failure data indicated an increasing trend in underground cable failures, and the predominant contributing factor was submergence or moisture intrusion that degraded the insulation. The staff noted that the cables are failing within the plants 40-year licensing periods.

Some of the cable failures have resulted in plant transients and shutdowns, loss of safety redundancy, entries into limiting conditions for operation, and challenges to plant operators.

The NRC staff published the summary report that captured the review of responses from all licensees on November 12, 2008 (ADAMS Accession No. ML082760385).

The NRC regulations require licensees to assess the condition of their components; monitor the performance or condition of structures, systems, and components in a manner sufficient to provide reasonable assurance that they are capable of fulfilling their intended functions; and establish a suitable test program to ensure that all testing necessary to demonstrate that components will perform satisfactorily in service is identified and performed. To date, NRC inspectors have identified various violations of NRC requirements at several facilities. Appendix A to this IN lists NRC inspection reports from 2008-2010 that identified inspection findings related to cable submergence.

Cables not designed or qualified for, but exposed to, wet or submerged environments have the potential to degrade. Cable degradation increases the probability that more than one cable will fail on demand because of a cable fault, lightning surge, or a switching transient. Although a single failure is within the plant design basis, multiple failures of this kind would be challenging for plant operators. Also, an increased potential exists for a common-mode failure of accident mitigating system cables if they are subjected to the same environment and degradation mechanism for which they are not designed or qualified for. Some licensees have attempted to periodically drain the accumulated water from the cable surroundings to avoid cable failures. In some cases, the water quickly refilled the cavity in areas in which the water table was above the base level of a cable trench or underground vault. In other cases, water accumulated seasonally (e.g., because of snowfall or rain), filling the conduit or raceways. In both cases, periodic draining could slow the rate of insulation degradation, but it may not prevent cable degradation. Licensees should ensure that cables that could become submerged are adequately monitored.

IN 2010-26 Page 8 of 8 CONTACT This IN requires no specific action or written response. Please direct any questions about this matter to the technical contacts listed below or to the appropriate NRR project manager.

/RA by TBlount for/ /RA by JTappert for/

Timothy McGinty, Director Glenn Tracy, Director Division of Policy and Rulemaking Division of Construction Inspection and Office of Nuclear Reactor Regulation Operational Programs Office of New Reactors Technical Contacts: Matthew McConnell, NRR Amar Pal, NRO 301-415-1597 301-415-2760 E-mail: Matthew.McConnell@nrc.gov Amar.Pal@nrc.gov Note: NRC generic communications may be found on the NRC public Web site, http://www.nrc.gov, under Electronic Reading Room/Document Collection 70

ATTACHMENT 4 UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I July 29, 2010

SUBJECT:

PILGRIM NUCLEAR POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000293/2010003 1 R06 Flood Protection Measures (71111.06)

Underground Cable Inspection

a. Inspection Scope (1 sample)

The inspectors reviewed a sample of flood protection measures affecting cables located in underground manholes. The inspectors selected an inspection of cable pits 2A, 4, and 5 that contain underground non-safety related power cables (from the start-up transformer to electrical buses A2 and A4) near the main transformer and the south side of the switchyard near the start-up transformer. The inspectors monitored Entergy's maintenance inspection and dewatering activities associated with each manhole to evaluate the as-found condition and corrective actions. The inspectors assessed the condition of power cables, splices, and supports. The inspectors also reviewed Entergy's Cable Reliability Program and corrective actions taken for this issue and the Cable Reliability Program in general. The documents reviewed during this inspection are listed in the Attachment.

b. Findings

==

Introduction:==

The inspectors identified a finding (FIN) of very low safety significance (Green) for improper maintenance of underground non-safety related medium voltage electric cables. The inspectors observed partially and fully submerged medium voltage cables during the regularly scheduled monthly dewatering and inspection of three cable vaults.

Enclosure 8

==

Description:==

The electric power distribution system provides electric power to safety and non-safety related distribution buses in the plant. Off-site power is provided to the system by two independent circuits through non-safety related, medium voltage (typically those rated from 2 kilovolts to 35 kilovolts), Kerite cables that are routed through underground vaults and ducts. These cables are not rated for continuous submergence in water.

On April 28, 2010, the inspectors observed water in each of the manholes and vaults listed above. The inspectors noted that no dewatering or drainage systems existed in the manholes. Entergy procedure EN-DC-346, Revision 0, "Cable Reliability Program," was issued and effective on December 31,2009. This procedure discusses manhole inspections and dewatering, and requires, in part, "If manual inspections and pumping are used to maintain a cable system dry, the intervals must be sufficient to keep the cables dry. Adjust intervals as necessary, based on inspection results." Discussions with Entergy personnel involved with these inspections indicated that cables in Manhole 2A were periodically found submerged or partially submerged, and that cables in Manholes 4 and 5 were always found submerged. The cables that were submerged 71

included cables that were installed from the 4160V, non-safety related startup transformer and connected to the A2 and A4 non-safety related busses. The inspectors identified that Entergy had previously identified submerged cables in August and September of 2009, however, corrective actions were not sufficient to preclude these cables from being submerged. The inspectors also determined that Entergy had not implemented the Cable Reliability Program guidance in a timely manner to ensure that the degrading effects of this environmental condition were minimized (Le., pumping intervals were not sufficient to maintain the cables dry).

Entergy generated Condition Report (CR) CR-PNP-201 0-1529, and specified actions to identify all underground medium voltage cables included in the Cable Reliability Program, and to identify which manholes should have dewatering capability. Entergy also created a corrective action to increase the frequency of the dewatering activities for these areas.

In addition, the Electric Power Research Institute has generated a cable testing database that will be used to compare the test results of cables that have been removed from service to evaluate the potential for degradation of in-service cables.

Analysis: The inspectors determined that allowing medium voltage cables to remain submerged for extended periods of time was a performance deficiency. The cause of the issue was within Entergy's ability to foresee and correct, and should have been prevented. Traditional Enforcement did not apply, as the issue did not have actual or potential safety consequence, had no willful aspects, nor did it impact the NRC's ability to perform its regulatory function.

A review of NRC Inspection Manual Chapter (IMC) 0612, Appendix E, "Minor Examples,"

revealed that no minor examples were applicable to this finding. The finding was more than minor because it was associated with the design control attribute of the Initiating Events cornerstone, and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, continued submergence of the nonsafety related power cables (from the start-up transformer to electrical buses A2 and A4)

Enclosure 9

could lead to cable failure and cause an event that would affect plant stability. The inspectors performed a Phase 1 Significance Determination Process screening of the finding in accordance with NRC Inspection Manual Chapter 0609, Attachment 4, "Phase 1 - Initial Screening and Characterization of Findings," and determined that the finding was of very low safety significance because the condition did not contribute to both the likelihood of a reactor trip and the unavailability of mitigating systems equipment.

The inspectors determined that this finding had a cross-cutting aspect in the Problem Identification and Resolution cross-cutting area, Corrective Action Program component, because Entergy personnel did not thoroughly evaluate the problem when submerged cabling was initially identified P.1(c).

Enforcement: This finding does not involve enforcement action because no regulatory requirement violation was identified. Because this finding does not involve a violation and has very low safety significance, it is identified as FIN 05000293/2010003-01, Submerged Medium Voltage Cables.

72