ML081070329
| ML081070329 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 04/10/2008 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| SECY RAS | |
| References | |
| 50-293-LR, ASLBP 06-848-02-LR, NRC-2114, RAS J-29 | |
| Download: ML081070329 (320) | |
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Title:
Hearing ITMO Pilgrim Nuclear Power Station DOCKETED USNRC Docket Number: 50-293-LR ASLBP Number: 06-848-02-LR April 15, 2008 (9:45am)
OFFICE OF SECRETARY RULEMAKINGS AND ADJUDICATIONS STAFF Location: Plymouth, Massachusetts Date: Thursday, April 10, 2008 Work Order No.: NRC-2114 Pages 557-874 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
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557 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 3 ATOMIC SAFETY AND LICENSING BOARD 4 HEARING 5
6 In the Ma tter of: Docket No. 50-293-LR 7 ENTERGY NUCLEAR GENERATION 8 COMPANY AND ENTERGY NUCLEAR A SLBP No. 06-848-02-LR 9 OPERATIONS, INC.
10 (Pilgrim Nuclear Power Station) 12 13 Thursday, April 10, 2008 14 15 16 The hearing came to order at ,-6-3--. at the 17 the Radison Hotel, 180 Water Street, Plymouth, 18 Massachusetts Administrative Judge Ann Marshall 19 Young, Chair of the panel, 20 PANEL:
21 22 Ann Marshall Young, Chair, Chair 23 Paul B. Abramson, Ph.D., Judge 24 Richard F. Cole, Ph.D., Judge 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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558 1 APPEARANCES:
2 ON BEHALF OF THE APPLICANT:
3 PAUL A. GAULKER, ESQ.
4 DAVID R. LEWIS, ESQ.
5 - of Pillsbury Winthrop Shaw Pittman, LLP 6 2300 N Street, NW 7 Washington, DC 20037 8 (202) 663-8000 9
10 ON BEHALF OF NRC STAFF:
11 SUSAN UTTAL, ESQ.
12 KIMBERLY A. SEXTON, ESQ.
13 JAMES E. ADLER, ESQ.
14 Of OFFICE OF THE GENERAL COUNSEL 15 UNITED STATES NUCLEAR REGULATORY COMMISSION 16 Mail Stop 015 D21 17 Washington, DC 20555-0001 18 (301) 415-1565 19 20 ON BEHALF OF THE TOWN OF PLYMOUTH:
21 SHEILA SLOCUM HOLLIS 22 of DUANE MORRIS, LLP 23 505 9 Lh Street, NW Suite 1000 24 Washington, DC 20004-2166 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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559 1 ON BEHALF OF THE TOWN OF DUXBURY 2 REBECCA CHEN 3
4 ON BEHALF OF PILGRIM WATCH:
5 MARY LAMPERT, DIRECTOR 6 PILGRIM WATCH 7 148 Washington Street 8 Duxbury, MA 02332 9
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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560 1 TABLE OF CONTENTS 7
2 OPENING STATEMENTS PAGE 3 Applicant ............... ................... 590 4 Pilgrim Watch ............. ................. 593 5 NRC Staff ............... ................... 561 6
7 8 EXHIBITS IDEN RECD 9 Applicant's 1 - 12 572 572 10 Pilgrim Watch's 13 38 581 581 11 NRC Staff's 39 - 66 589 589 12 Applicant's 67 645 645 13 Applicant's 70 745 745 14 Applicant's 71 764 764 15 Applicant's 72 838 838 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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561 1 P-R-O-C-E--E--D-I-N-G-S 2 9:06 a.m.
3 CHAIR YOUNG: Good morning. My name is 4 Ann Marshall Young. I'm the Chair of the Licensing 5 Board. I am the lawyer member. We have one other 6 lawyer who's also a technical person and he will give 7 his expertise. My expertise is in the law, not 8 nuclear physics, or nuclear engineering.. I'd like to 9 start this morning by having everyone introduce 10 themselves and then I'll give a little overview of 11 .what we're going to be doing and then we'll go on with 12 introduction of the pre-file testimony and the 13 exhibits and follow that up with questions of the 14 various parties' experts.
15 This is a little bit different than a 16 normal trial that you might know about from previous 17 experiences in legal proceedings or television law 18 shows. We have already received most of the testimony 19 that will be -- that will make *up this hearing in 20 written form from all the parties. After all of the 21 parties filed their written direct testimony, each 22 party had an opportunity to file written rebuttal 23 testimony and to request that we ask specific 24 questions.
25 To the degree necessary, I'll go into that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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562 1 a little bit more but let's go ahead and do the 2 introductions now and then I'll give you a little bit 3 more of an overview of what we're going to be doing 4 today.
5 Judge Abramson?
6 JUDGE ABRAMSON: I'm just Judge Abramson.
7 Let me just turn my mike on. I'm Judge Abramson.
8 Just for the record, we're here on Entergy Nuclear 9 Generation Company and Entergy Nuclear Operations on 10 the Pilgrim Nuclear Station. It's Docket Number 50-11 293-LR. I'm both an attorney and a scientist. I'm 12 the only member of the panel who happens to straddle 13 that fence and that gives me deniability on both 14 sides. What Judge Young mentioned for you is 15 something that you really need to think very carefully 16 about if you're not familiar with our procedures, and 17 that is that we're -- first of all, we're a body 18 established by the Atomic Energy Act.
19 The Atomic Energy Act permitted the 20 Commission to establish Atomic Safety and Licensing 21 Boards consisting of three judges. We're unique in 22 this country and maybe unique in the world in that we 23 almost always have two scientists acting as Judges who 24 have an equal vote, an equal say on the matters. The 25 other thing that makes us unique is that under the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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563 1 type of proceeding that we're conducting here, all the 2 testimony is provided in writing. That means, the 3 expert witnesses provided all their testimony in 4 writing and the expert witnesses have then provided 5 written rebuttal to that testimony in writing and 6 we've asked questions in writing to which the parties 7 have responded in writing. So we have a great deal of 8 technical information in front of us. And the purpose 9 of this hearing today is simply to allow the Judges to 10 follow-up and try to clarify what needs in our minds 11 to be clarified about the testimony that's in front of 12 us and to follow up with questions as the parties have 13 suggested to us may seem appropriate for the hearing.
14 So that's -- sorry, Ann to just pick up on 15 it but I think it's necessary that everybody 16 understand. What you're going to see today, 17 therefore, is not lawyers putting their witnesses on 18 and examining them and cross examining other parties' 19 witnesses. What you're going to see is us asking the 20 experts questions with a possibility of some 21 additional questions coming from the parties' counsel..
22 CHAIR YOUNG: Judge Cole?
23 JUDGE COLE: My name is Richard F. Cole.
24 I'm an environmental engineer. I'm an Administrative 25 Judge technical. I'm also a registered professional NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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564 1 engineer.
2 CHAIR YOUNG: Let's start over here with 3 the Applicant. Mr. Lewis, could you introduce 4 yourselves and your experts who are going to be 5 testifying today, and then can join you at the table.
6 JUDGE ABRAMSON: He has no room.
7 MR. LEWIS: They will. I thought after 8 the exhibits, the experts would come up. My name is 9 David Lewis and with me is my partner, Paul Gaukler.
10_ We're with the law firm, Pillsbury, Winthrop, Shaw 11 Pittman and we have the privilege of representing 12 Entergy in this proceeding.
13 CHAIR YOUNG: Do you want to go ahead and 14 introduce your experts at this point?
15 MR. LEWIS: Yes, with us as experts are 16 Mr. Brian Sullivan, Mr. Steven Woods, Mr. William 17 Spataro and Mr. Alan Cox.
18 CHAIR YOUNG: Thank you. Ms. Uttal for 19 the staff?
20 MS. UTTAL: Thank you, your Honor. My 21 name is Susan Uttal. I am counsel for the NRC staff.
22 To my right is James Adler who is also counsel for the 23 staff. To my left is Kimbery Sexton, also counsel for 24 the staff.
25 CHAIR YOUNG: And your -- go ahead.
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565 1 MS. UTTAL: My experts are Dr. James 2 Davis, seated right there, Andrea Keim seated next to 3 him and Terrence Chan seated next to him.
4 CHAIR YOUNG: All right, Ms. Hollis?
5 MS. HOLLIS: Yes, I'm Sheila Hollis, I'm 6 counsel to the Town of Plymouth. I'm with the firm of 7 Duane Morris. We are not presenting witnesses today.
8 Thank you.
9 CHAIR YOUNG: Thank you.
10 MS. CHEN: I'm Rebecca Chen, co-chair of 11 the Duxbury Nuclear Advisory Committee.
12 CHAIR YOUNG: You've only got one mike 13 JUDGE ABRAMSON: Speak into the mike or 14 get closer to it, so we can get it on -- can you get 15 this on the record? You're hearing them okay.
16 CHAIR YOUNG: I've just been told the 17 parties don't have your mikes on, so you might want to 18 -- yours is on now? Okay.
19 MS. HOLLIS: All right, this is Sheila 20 Hollis. I'm counsel to the Town of Plymouth and I'm 21 with the firm of Duane Morris in Washington. We will 22 not be presenting witnesses today, however. Thank 23 you.
24 CHAIR YOUNG: Thank you.
25 MS. CHEN: I'm Rebecca Chen. I'm the co-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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566 1 chair of the Duxbury Nuclear Advisory Committee. We 2 will not be presenting witnesses today.
3 CHAIR YOUNG: Ms. Lampert?
4 MS. LAMPERT: Yes, I'm Mary Lampert. I'm 5 representing Pilgrim Watch pro se, and with-me today 6 is Arnold Gundersen, who will be speaking on nuclear 7 issues and Dr. David Ahfeld, a hydrologist who will be 8 speaking on those issues and we appreciate being here.
9 CHAIR YOUNG: Thank you. Let's go in the 10 same order with the introduction of the prefiled 11 testimony and exhibits. Well, no, actually let's go -
12 - start with the applicant and then go to the 13 intervener Pilgrim Watch and the to the staff and 14 we'll conduct our questioning in the same order 15 although there may be some back and forth as we 16 indicated earlier. Mr. Gaukler, are you going to --
17 and let us know as the first exhibit for each party 18 would be your prefiled testimony and let us know right 19 at the outset whether you have any modifications or 20 corrections that you want to make.
21 MR. GAUKLER: Okay, do you want me to read 22 the exhibits that we're going to be introducing?
23 CHAIR YOUNG: Well, yes. Are there any 24 modifications or corrections to the testimony?
25 MR. GAUKLER: There are no modifications NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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567 1 to the testimony and we. have two exhibits of 2 testimony, Exhibit A, which is our testimony of our 3 witnesses of January 8 th, 2008 and we have Exhibit B, 4 which is the rebuttal testimony of our witnesses filed 5 March 6 "h, 2008. We then have all of the exhibits 6 that we prefiled with you. There's no additions.
7 They are Exhibit 1A which is a layout of the plant in 8 terms of the relevant facilities.
9 CHAIR YOUNG: Hold on one second. Do you 10 need to get those as we're going?
11 STAFF: We can't hear in the back of the 12 room.
13 MR. GAUKLER: And if I could, your Honor, 14 I'll hand out the books that you asked us to provide 15 at this time. That will be helpful to follow along.
16 CHAIR YOUNG: Okay, and then as we go, as 17 we give each exhibit an official exhibit number -- do 18 you have a microphone? No, okay. Okay, and I will 19 indicate also. So your testimony would be your 20 Exhibit 1.
21 MR. GAUKLER: No, our Exhibit A.
22 CHAIR YOUNG: Your Exhibit A we will mark 23 as official Exhibit 1. And if everyone wants to 24 follow along and keep track of those in that way. We 25 all have this already in another form but we're now NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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568 1 formally presenting it into the record.
2 MR. GAUKLER: Our exhibit list is in front 3 of that notebook.
4 CHAIR YOUNG: Okay. Does your Exhibit A 5 include your direct and rebuttal or Exhibit B is your 6 rebuttal?
7 MR. GAUKLER: Exhibit B is rebuttal.
8 Exhibit A includes the direct testimony, the signed 9 declarations supporting that testimony and the 10 curriculum vitae of each of our experts.
11 CHAIR YOUNG: Okay.
12 MR. GAUKLER: Exhibit B is our rebuttal 13 testimony of our four experts that we prefiled March 14 6 h, 2008. Our Exhibit 1A is a layout of the plant 15 showing the relevant facilities and buried pipes.
16 CHAIR YOUNG: And that would be official 17 Exhibit Number 3.
18 MR. GAUKLER: Okay, Exhibit lB is a sketch 19 of the buried pipe for the condensate storage system.
20 CHAIR YOUNG: And that would be official 21 Exhibit Number 4. We're just going to go serially 22 through all of them, so we'll only have one numbering 23 system at the end.
24 MS. LAMPERT: Excuse me, Judge. When is 25 it appropriate for me to voice an objection or is that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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569 1 not appropriate?
2 CHAIR YOUNG: To the --
3 MS. LAMPERT: To the exhibits.
4 CHAIR YOUNG: -- prefiled exhibits?
5 MS. LAMPERT: Yeah, yes.
6 CHAIR YOUNG: Did you object to those 7 earlier in the rebuttal at any point?
8 MS. LAMPERT: No, I didn't but I wanted it 9 to get on the record that we don't object to it being 10 filed but we object to the contents and we'd like that 11 on the record.
12 CHAIR YOUNG: Of the last one?
13 MS. LAMPERT: No, that's for 1, 2 -- the 14 first two, their prefiled and their rebuttal.
15 CHAIR YOUNG: Okay, it's on the record.
16 JUDGE ABRAMSON: Excuse me, Ms. Lampert, 17 isn't it correct, more correct to say that you contest 18 the technical content, not that you object to it, but 19 you disagree with it?
20 MS. LAMPERT: I can tell you're a good 21 lawyer. That is true. I disagree with much of what's 22 in it and would like the opportunity --
23 JUDGE ABRAMSON: Yes, we understand that.
24 We understand that and that was the purpose for you 25 having filed your rebuttal testimony and that is in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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570 1 the record. So while we'll accept your statement, 2 it's really unnecessary.
3 MS. LAMPERT: Well, you're going to have 4 to guide me along this process and I appreciate 5 guidance that you do provide.
6 MR. GAUKLER: Next is our Exhibit 2 which 7 are excerpts from the license renewal application 8 concerning the applicable aging management programs.
9 CHAIR YOUNG: And that would be official 10 Exhibit 5. Correct me if I'm wrong, Ms. Teebo 11 (phonetic) as we go along.
12 MR. GAUKLER: Our Exhibit 3 is 13 Specification Number 6498-M-306 which is a 14 specification for external surface treatment of 15 underground metallic pipe for Unit Number 1 Pilgrim 16 Station. That's our Exhibit Number 3.
17 CHAIR YOUNG: And that will be official 18 Exhibit 6.
19 MR. GAUKLER: Our Exhibit Number 4 are 20 excerpts from NUREG 1801 known as the GALL report, 21 excerpts concerning the aging management programs that 22 are relevant to this case.
23 CHAIR YOUNG: Exhibit 7. And if everyone 24 follows along and just marks those, that way when we 25 refer back to these, we won't get into the confusion NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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571 1 of which parties' Exhibit 7, if everyone identifies it 2 as official Exhibit 7 or 8 or whatever the number 3 might be, that will make it a little bit easier to 4 follow. Go ahead.
5 MR. GAUKLER: Our Exhibit Number 5 is 6 Procedure Number EN-DC-340, Rev 0, Varied Pipe and 7 Tanks Inspection and Monitoring Program.
8 CHAIR YOUNG: Official Exhibit 8.
9 MR. GAUKLER: Our Exhibit Number 6 is 10 excerpts from Appendix A of the License Renewal 11 Application concerning commitments.
12 CHAIR YOUNG: That will be Exhibit 9.
13 MR. GAUKLER: Exhibit Number 7 is excerpts 14 from the staff's Safety Evaluation Report Appendix A.
15 CHAIR YOUNG: Exhibit 10.
16 MR. GAUKLER: Our Exhibit Number 8 is 17 Appendix B.0.3 of the License Renewal Application.
18 CHAIR YOUNG: Official Exhibit 11.
19 MR. GAUKLER: And Exhibit Number 9 is 20 Entergy's answers to the Board's questions dated 21 February 1ith, 2008 including the declaration and 22 curriculum vitae of Steven Bathet supporting those 23 answers.
24 CHAIR YOUNG: That would be Exhibit 12.
25 MR. GAUKLER: And that's our exhibits, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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572 1 your Honor.
2 CHAIR YOUNG: All right.
3 MR. GAUKLER: I would move to introduce 4 them into the record.
5 CHAIR -YOUNG: So moved and we will 6 introduce those into the record and they will be a 7 part of the formal record.
8 (Applicant Exhibits 1 through 9 12 were marked for 10 identification and were 11 received in evidence.)
12 CHAIR YOUNG: I guess one thing that 13 jogged my memory on, I'm sure probably all of the 14 parties are aware that the First Circuit has in a case 15 brought by the State of Massachusetts stayed the 16 closing of this hearing, so we will be keeping the 17 record open and adjourning the hearing, not completing 18 it at the end of our proceedings today.
19 Also, Ms. Lampert has filed a motion 20 asking for the same thing in order that she can 21 present something additional to us. Based on the 22 requirements of the motion rule, we will expect 23 responses to that from the parties and rule on that 24 accordingly. Ms. Lampert, why don't you go next?
25 MS. LAMPERT: Yes, the exhibits that we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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573 1 have, we have labeled 1 as 1A, testimony of Arnold 2 Gundersen, supporting Pilgrim Watch Contention 1 of 3 March 6 "h, 2008. We have labeled as lB --
4 CHAIR YOUNG: 1A will be official Exhibit 5 -13.
6 MS. LAMPERT: Are we doing lB now?
7 CHAIR YOUNG: 1B, go ahead.
8 MS. LAMPERT: Yes, again, witness Arnold 9 Gundersen, declaration supporting Pilgrim Watch's 10 Petition for Contention 1, January 2 6 "h, 2008 and is 11 Cv.
12 CHAIR YOUNG: And that will be official 13 Exhibit 14.
14 MS. LAMPERT: Our Number 2 is witness 15 David Ahlfeld, his declaration regarding groundwater 16 monitoring requirements for Pilgrim, January 2 8th, 17 2008 --
18 CHAIR YOUNG: Let's see that would be --
19 MS. LAMPERT: -- and his biographical 20 sketch.
21 CHAIR YOUNG: Exhibit 15.
22 MS. LAMPERT: Correct. The next exhibit 23 that we labeled 3 is 10 CFR 5421.
24 CHAIR YOUNG: That's not necessary but 25 since it's always possible for regulations to change, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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574 1 we'll go ahead and admit that as official Exhibit 16.
2 MS. LAMPERT: For history, I guess. The 3 next one, number 4, Advisory Committee on Reactor 4 Safeguards, official transcript of proceedings 4 8 5 th 5 meeting September 6 th, 2001, which discusses 6 reasonable assurance.
7 CHAIR YOUNG: That will be official 8 Exhibit 17.
9 MS. LAMPERT: The next one is 10 CFR 10 Appendix B to Part 50, Quality Assurance Criteria for 11 Nuclear Power Plants, NRC and NRC Inspection Manual 12 Part 9900, Technical Guidance, Operability, 13 Determination and Functionality Assessments for 14 Resolution of Degraded or Non-Conforming Conditions 15 Adverse to Quality or Safety.
16 CHAIR YOUNG: That will be Exhibit 18.
17 MS. LAMPERT: Our Number 6 is NUREG 1891, 18 Safety Evaluation Report related to the license 19 renewal of Pilgrim Nuclear Power Station, da, da, da, 20 da, buried piping in tanks inspection program.
21 CHAIR YOUNG: Exhibit 19.
22 MS. LAMPERT: Our Number 7 is Liquid 23 Radioactive Release Lessons Learned Task Force Final 24 Report, September 1s', 2006, Sections therein.
25 CHAIR YOUNG: That will be Exhibit 20.
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575 1 MS. LAMPERT: The next one is NUREG 2 CR6876, Risk Informed Assessment of *Degraded Buried 3 Piping Systems in Nuclear Power Plants Brookhaven 4 National Laboratory, there are sections therein.
5 CHAIR YOUNG: Exhibit 21.
6 MS. LAMPERT: Our Number 9 is the 7 declaration of Alan Cox in support of Entergy's motion 8 for summary disposition of Pilgrim Watch Contention 1, 9 June 5, 2007.
10 CHAIR YOUNG: Exhibit 22.
11 MS. LAMPERT: Our Number 10 is US Nuclear 12 Power Plants in the 21"S Century, the Risk of a 13 Lifetime by David Lochbaum, Union of Concerned 14 Scientists and Using Reliability Centered Maintenance 15 as a Foundation for an Efficient and Reliable Overall 16 Maintenance Strategy.
17 CHAIR YOUNG: Go ahead.
18 MS. LAMPERT: I have more to say, National 19 Aeronautics and Space Administration 2001 and 20 Declaration of David Lochbaum, attesting to the facts 21 that stand by the contents of the report.
22 CHAIR YOUNG: Exhibit 23.
23 MS. LAMPERT: The next one that we 24 numbered 11 is a declaration of Alan Cox in support of 25 Entergy's motion for summary disposition of Pilgrim NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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576 1 Watch Contention 1, June 5 th, 2007 and it's simply a 2 footnote number, do you'want me to say all this, 6 on 3 ýpage 11?
4 -CHAIR YOUNG: If you want to. The people 5 here won't have seen it before so if you'd like to, 6 you may.
7 MS. LAMPERT: Yeah, I'm just trying to 8 figure out whether you want me to do-it. It doesn't 9 matter one way-or the other to me.
10 CHAIR YOUNG: Enough to let people know 11 what it is, is basically all that's necessary.
12 MS. LAMPERT: Okay, fine. Our number 12 13 is NRC preliminary notification of event or unusual 14 occurrence.
15 CHAIR YOUNG: The last one was 24. This 16 one will be 25.
17 MS. LAMPERT: Okay. The next one that we 18 labeled 13, Pilgrim Nuclear Power Station, Boston 19 Edison Company Docket 50-293, May 1972.
20 CHAIR YOUNG: That will be Exhibit 26.
21 MS. LAIMPERT: The next one is the Buried 22 Piping and Tanks Inspection and Monitoring Program, a 23 document provided by Entergy.
24 CHAIR YOUNG: Exhibit 27.
25 MS. LAMPERT: Our Number 15 is United NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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577 1 States Government Accounting Office Report to the 2 Chairman' s Committee on Oversight and Investigations 3 on Counterfeit and Substandard Parts.
4 CHAIR YOUNG: Exhibit 28.
5 MS. LAMvPERT: Our Number 16 is an article 6 regarding seismic conditions in Southeastern 7 Massachusetts for all New England. Do you want me to 8 read it or 9 CHAIR YOUNG: Go ahead.
10 MS. LAMPERT: New England Not Immune to Strong Tremblers and Specialists say that a Major 12 Event is only a Matter of time.
13 CHAIR YOUNG: That will be Exhibit 29.
14 MS. LAM4PERT: Our next one is NUREG 1891-15 11M-32.
16 CHAIR YOUNG: That will be Exhibit 30.
17 MS. LAMPERT: Our next one is NUREG 1801 18 Volume 1, Revision 1, the GALL Report sections 19 therein.
20 CHAIR YOUNG: Exhibit 31.
21 MS. LAMPERT: Our next one that we labeled 22 19 is Pilgrim Nuclear Power Station License Renewal 23 Application Sections A and B.
24 CHAIR YOUNG: That will be Exhibit 32.
25 MS. LAIMPERT: Our labeled 20 is again NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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578 1 testimony by Alan Cox, Brian Sullivan and Steve Woods, 2 William Spataro on Pilgrim Watch Contention 1, a 3 section therein.
4 CHAIR YOUNG: That will be Exhibit 33.
5 MS. LAMPERT: The next that we labeled 21 6 is an affidavit of James Davis concerning Entergy's 7 motion for summary disposition of Pilgrim Watch June 8 28th, 2007.
9 CHAIR YOUNG: That will be Exhibit 34.
10 MS. LAMPERT: The next one that we labeled 11 22 is the Office of Inspector General's Audit of NRC's 12 License Renewal Program September 6 th, 2007.
13 CHAIR YOUNG: And that will be Exhibit 35.
14 MS. LAMPERT: The next one that we labeled 15 23 is a -- what is it, an event notification 16 Number 43832 dealing with Palisades 1207.
17 CHAIR YOUNG: And that will be official 18 Exhibit 36.
19 MS. LAMPERT: Our next one labeled 24 was 20 redacted as requested.
21 CHAIR YOUNG: So that's not going to be 22 part of this record.
23 MS. LAMPERT: Right, but I'm just 24 mentioning it because that's what's in there. The 25 next one, 25 --
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-579 1 CHAIR YOUNG: I'm sorry, are there more?
2 You said that's what's in there meaning that's--
3 MS. LAMPERT: Well, what I did is I 4 submitted a page that said redacted.
5 CHAIR YOUNG: Oh,- okay.
6 JUDGE COLE: The whole page.
7 CHAIR YOUNG: The whole page said 8 redacted, I see what you're saying.
9 JUDGE COLE: It was eliminated.
10 MS. LAMPERT: I wasn't sure, because --
11 CHAIR YOUNG: You substituted a page in 12 place of the previous exhibit.
13 MS. LAMPERT: Yeah.
14 CHAIR YOUNG: Okay, because I thought that 15 would follow what we had submitted as what would be --
16 MS. LAMPERT: I'm being a little creative, 17 as you know, at times, not being a trained lawyer.
18 CHAIR YOUNG: I'm sure you don't mean to 19 suggest that lawyers aren't creative.
20 MS. LAMPERT: Oh, very creative. That's 21 why I think I'm cut out for this.
22 MR. GAUKLER: Your Honor, if she could 23 pass out the copy of her exhibits that would be 24 helpful to us.
25 CHAIR YOUNG: Oh, sure. You have one NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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580 1 more. Why don't you do that-and then pass those to 2 everyone and actually we should have done that before 3 but I didn't catch that. Thank you, Mr. Gaulker.
4 MS. LAMPERT: Actually, I believe I have 5 two more. -
6 CHAIR YOUNG: Two more, you're right, 7 you're right, I'm sorry.
8 MS. LAMPERT: Okay, what we labeled as 25, 9 was the approximate location of the monitoring wells, 10 a document provided by Entergy.
11 CHAIR YOUNG: And that will be Exhibit 37.
12 MS. LAMPERT: Okay, and the last one is --
13 what the heck is it, oh, a combination. It is a 14 Boston Globe article discussing a discovery in Pilgrim 15 Wells fuel debate and the accompanying is a document 16 but the Massachusetts Department of Public Health on 17 that issue.
18 CHAIR YOUNG: And that will be official 19 Exhibit 38.
20 MS. LAMPERT: Great. And now shall I get 21 the documents?
22 CHAIR YOUNG: Yes, why don't you do that 23 and then while you are doing that, if the staff could 24 pass out yours and then we'll start with yours after 25 that.
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581 1 (Pilgrim Watch Exhibits 13 2 through 38 were marked for 3 identification and were 4 received in evidence.)
5 JUDGE ABRAMSON: For those of you who are 6 not familiar with this process, all of this evidence 7 has already been previously submitted to us and we're 8 just formally putting it in the record as Judge Young 9 said, so that we can have a complete record in front 10 of us when we make our decision.
11 CHAIR YOUNG: That's right. This is the 12 NRC revised, its procedural rules in 2004 and we're 13 just now in the last year or so getting to the 14 proceedings in which we're under the new rules, so 15 this is sort of new to some extent for all of us but 16 Judge Abramson is correct, we had received all these 17 exhibits and additional information prior to today's 18 hearing and we've read those and we're now -- we're 19 now entering them all at once into the record, which 20 is a little bit different than would occur in a normal 21 in a traditional hearing setting.
22 Do you have what you need, Ms. Teebo?
23 THE CLERK: I'm just trying to make sure 24 I-25 CHAIR YOUNG: Now, did we get Pilgrim NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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582 1 Watch's notebooks? Judge Abramson pointed out 2 something while we're passing these out, we have three 3 new judges in our office who are here observing this 4 proceeding and while we're doing this, we'll introduce 5 Judge Ryerson, Judge Paul Ryerson, Judge Mike Kennedy, 6 and Judge Ron Spitzer. We're glad to have them here 7 with us today. Spritzer, pardon me, Spritzer.
8 MR. GAUKLER: Your Honor, just for the 9 record, I'd like to make clear objection of exhibits 10 that we objected to in our motion in limine.
11 CHAIR YOUNG: Right.
12 MS. SEXTON: And your Honor, the staff 13 would like to do the same.
14 CHAIR YOUNG: We have previously ruled on 15 motions to exclude certain of the evidence that we 16 have just admitted now and those are not placed on the 17 record. Let me just ask everyone, when I hear someone 18 talking, it's coming from one location, so if you 19 could identify yourself, because sometimes I find 20 myself looking around trying to figure out who's 21 talking. Okay, yes.
22 MS. LAMPERT: Your Honor, when is it 23 appropriate to make a motion, if that's how you do it, 24 to enter other exhibits on the record to assure that 25 the issues that you would like -- we feel that you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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583 1 would like to hear are before you in your decision 2 process? I understand 3 CHAIR YOUNG: Are you talking about the 4 exhibits that you had filed earlier and that we ruled 5 that we would -- that -- I think we ruled that we 6 would not accept those at the time but that during the 7 testimony of your experts, if any of them became 8 relevant in the opinion of the experts that they could 9 present those at that time and then if there are any 10 objections, to those at that time we'll rule on those.
11 MS. LAMPERT: 'Thank you for clarifying 12 that.
13 CHAIR YOUNG: Okay, and that goes for all 14 the parties. I think we said that earlier. Any other 15 clarification on that? Okay, Ms. Uttal or Ms. Sexton 16 or Mr. Adler, whichever one of you is going to present 17 the staff's exhibits.
18 MS. SEXTON: Your Honor, we have a total 19 of 28 exhibits. We'll start with Staff Exhibit Number 20 1, which is the testimony of Dr. James Davis 21 concerning Pilgrim Watch Contention 1 that we filed on 22 January 2 9 th , 2008.
23 CHAIR YOUNG: And that will be official 24 Exhibit 39.
25 MS. SEXTON: Our Exhibit Number 2 is staff NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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584 1 testimony of Terrence Chan and Andrea Keim concerning 2 Pilgrim Watch Contention 1 filed again on January 3 29 t, 2008.
4 CHAIR YOUNG: And that will be Exhibit 40.
5 MS. SEXTON: We next have our rebuttal 6 testimony in responses to Board questions of Dr. James 7 Davis, Terrence Chan and Andrea Keim file on March 8 6th, 2008 .
9 CHAIR YOUNG: And that's Exhibit 41.
10 MS. SEXTON: Next is a portion of that 11 GALL report on buried piping and tanks in section.
12 CHAIR YOUNG: Exhibit 42.
13 MS. SEXTON: Another section of the GALL 14 report on open cycle cooling water system.
15 CHAIR YOUNG: Exhibit 43. Another reason 16 for -- incidentally, going through the numbering of 17 these is when the experts are testifying, if you want 18 to refer to any of these exhibits, if you could maybe, 19 if necessary, the lawyer could whisper in your ear and 20 tell you what number you're talking about so everyone 21 can get to it and be looking at the same thing.
22 What was your next one?
23 MS. SEXTON: The next one is an NRC 24 generic letter, 89-13 regarding service water system 25 problems effecting safety-related equipment.
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585 1 - CHAIR YOUNG: And I believe that was your 2 Exhibit 6 which would make it official Exhibit 44.
3 MS. SEXTON: Correct, your Honor. Next we 4 have our Exhibit 7, which is a portion of the LRA on 5 buried piping and tank inspection program.
6 CHAIR YOUNG: Exhibit 45.
7 MS. SEXTON: Next is Exhibit 8 which is 8 another section of the LRA on the service water 9 integrity program.
10 CHAIR YOUNG: Exhibit 46.
11 MS. SEXTON: Exhibit 9 is a portion of the 12 SER on the service water integrity program.
13 CHAIR YOUNG: Also identified as NUREG 18-14 91, right?
15 MS. SEXTON: Uh-huh, yes.
16 CHAIR YOUNG: Exhibit 47.
17 MS. SEXTON: Exhibit 10 is a Pilgrim 18 Document Number 99-21, "Excavation for Salt Service 19 Water Pipe Replacement".
20 CHAIR YOUNG: And that will be official 21 Exhibit 48.
22 MS. SEXTON: Exhibit 11 is NUREG 18-91 an 23 excerpt from the SER on the water chemistry control 24 BRW program.
25 CHAIR YOUNG: And that will be Exhibit 49.
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586 1 MS. SEXTON: Exhibit 12, again NUREG 18-91 2 and excerpt from the SER, the one time inspection 3 program.
4 CHAIR YOUNG: Exhibit 50.
5 MS. SEXTON: Exhibit 13 is - letter from 6 2002 from Entergy to the NRC regarding Pilgrim Nuclear 7 Power Station Fourth Tenure In-service Testing Program 8 and Request for Approval of IST Relief Requests.
9 CHAIR YOUNG: That will be Exhibit 51.
10 MS. SEXTON: Exhibit 14 is a Pilgrim 11 Technical Specification Amendment Number 176, an 12 excerpt.
13 CHAIR YOUNG: Exhibit 52.
14 MS. SEXTON: Exhibit 15 is an excerpt from 15 Pilgrim FSAR on the condensate storage system.
16 CHAIR YOUNG: Exhibit 53.
17 MS. SEXTON: Number 16, another excerpt 18 from the FSAR on the quality assurance program.
19 CHAIR YOUNG: Exhibit 54.
20 MS. SEXTON: Exhibit 17 is a 2005 letter 21 from Entergy to the NRC regarding Pilgrim Fourth 22 Tenure In-service Inspection Program Plan and the 23 associate relief requests for NRC approval.
24 CHAIR YOUNG: And that will be Exhibit 55.
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587 1 Inspection Procedure Attachment 71111.07 issued in 2 2006 on heat sink performance.
3 CHAIR YOUNG: That will be Exhibit 56.
4 MS. SEXTON: Exhibit Number 19 is a 2006 5 letter from the NRC to Entergy regarding Pilgrim 6 Nuclear Power Station NRC Integrated Inspection 7 Report.
8 CHAIR YOUNG: And that will be Exhibit 57.
9 MS. SEXTON: Exhibit 20 is an excerpt from 10 the FSAR on the salt service water system.
11 CHAIR YOUNG: That will be Exhibit 58.
12 MS. SEXTON: Exhibit 21 is a generic 13 letter from 1991, number 91-18 regarding information 14 to licensees regarding two NRC inspection manual 15 sections on resolution of degraded and non-conforming 16 conditions and on operability.
17 CHAIR YOUNG: That will be Exhibit 59.
18 MS. SEXTON: Number 22 is an NRC 19 regulatory issue summary 2005-20, revision to guidance 20 formerly contained in NRC generic letter 91-18, 21 information to licensees regarding two NRC inspection 22 manual sections on resolution of degraded and non-23 conforming conditions and on operability.
24 CHAIR YOUNG: That will be official 25 Exhibit 60.
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588 1 MS. SEXTON: Exhibit 23, NUREG 1891, an 2 excerpt from the SER, staff's review process.
3 CHAIR YOUNG: That will be official 4 Exhibit 61.
5 MS. SEXTON: Exhibit 24, an NRC bulletin 6 from 1987, Number 87-01, bending of pipe walls in 7 nuclear power plants.
8 CHAIR YOUNG- That will be official 9 Exhibit 62.
10 MS. SEXTON: Number 25 is an excerpt from 11 the book "Corrosion Induced by Lower Energy 12 Radionuclides, Strategy for Controlling Corrosion".
13 CHAIR YOUNG: And that will be Exhibit 63.
14 MS. SEXTON: 26 is an NRC inspection 15 manual from 2007, inspection procedure 35-101 quality 16 assurance program implementation inspection for 17 operational programs.
18 CHAIR YOUNG: That will be official 19 Exhibit 64.
20 MS. SEXTON: Number 27 is the affidavit of 21 Dr. James A. Davis and Andrea Keim in response to 22 Licensing Board questions in the order contained --
23 Board questions for the NRC staff and Applicant.
24 CHAIR YOUNG: That will be Exhibit 65.
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589 1 Region 3 report excerpt from the service water system.
2 CHAIR YOUNG: And that will be official 3 Exhibit 66.
4 MS. SEXTON: And at this time, your Honor, 5 we'd like to move those into the record.
6 (NRC Staff Exhibits 39 through 7 66 were marked for 8 identification and were 9 received in evidence.)
10 CHAIR YOUNG: All the parties' exhibits 11 are now in the official record, in the official 12 evidentiary record. All rejected exhibits are in the 13 record for purposes of appeal as opposed to the 14 evidentiary record which we just entered the exhibits 15 into.
16 Next, if I could have all of the witnesses 17 who are going to be testifying to stand and I'll swear 18 you in.
19 MR. GAUKLER: Your Honor --
20 CHAIR YOUNG: I'm not going to swear you 21 in separately but it's just as if I were. If you 22 could raise your right hand, please.
23 (Witnesses Sworn) 24 CHAIR YOUNG: Thank you, the record 25 reflects that all have said they do. Let's start with NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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".590 1 Entergy's experts and if you could all come up to the 2 table so that you'll have'a microphone to pass around 3 between you as necessary.
4 MS. LAMPERT: Excuse me, your Honor. Is 5 the plan to have opening statements or is that --
6 CHAIR YOUNG: I'm sorry, you're so right.
7 We did promise that each party would have 10 minutes.
8 MS. LAMPERT: I've spent a long time 9 preparing it.
10 CHAIR YOUNG: Thank you. Thank you for 11 bringing that to my attention. You can still come sit 12 up there with your lawyers if you'd like. And we'll 13 do that in the same order as we said before. Again, 14 we're all getting used to this new process. New is a 15 relative term, of course. Okay, Mr. Lewis, go ahead.
16 MR. LEWIS: Good morning and welcome to 17 Plymouth. Entergy is pleased to appear before you 18 today to address the sole remaining contention raised 19 by Pilgrim Watch in this proceeding. This remaining 20 contention is Pilgrim Watch's challenge to the 21 adequacy of Entergy's programs for managing the aging 22 of the buried piping. Entergy's prefile testimony in 23 this proceeding describes those programs and 24 demonstrates the adequacy of those programs and I 25 won't repeat that testimony. I'll just emphasize a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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591 1 couple of points.
2 First, Energy's aging management programs 3 are consistent with the GALL report. The GALL report 4 was the NRC staff's extensive effort to compile aging 5 operating experience and to define the elements of 6 aging management programs that have been shown to be 7 effective based on that operating experience. Entergy 8 is consistent with those programs and we would submit 9 that is substantial evidence of the adequacy of our 10 programs.
11 The GALL report makes clear that an aging 12 management program consisting of coatings and 13 protective features to prevent corrosion from 14 occurring coupled with opportunistic and periodic 15 inspections is an effective program for managing the 16 aging of buried piping and that position in the GALL 17 report is corroborated by the expert testimony of 18 Entergy's witnesses as well as the expert testimony of 19 the NRC staff's witnesses.
20 Entergy's programs have those protective 21 features in them. There are two buried systems within 22 the scope of this proceeding because of the definition 23 of the contention. One is the salt water service 24 system. That salt water service system is protected 25 externally by coatings and wraps and it's protected NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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592 1 internally by a cured in place epoxy liner.
2 Similarly, the condensate storage system lines are 3 stainless steel and even though stainless steel is 4 resistant to corrosion, those are also externally 5 wrapped to prevent corrosion from occurring.
6 Despite those protective features which 7 will prevent corrosion from occurring, we also have 8 committed to the opportunistic and periodic 9 inspections to insure that those coatings remain 10 intact and remain effective in preventing degradation 11 from occurring. Pilgrim Watch wants monitoring wells 12 and I believe it's no secret that they want monitoring 13 wells to protect the environment. We've argued on a 14 number of occasions that that's outside the scope of 15 the proceeding and I believe that's consistent with 16 the Board's rulings. I just want to emphasize though 17 that that does not mean that groundwater protection is 18 unimportant to Entergy. It's very important to 19 Entergy and that is why we've undertaken the 20 groundwater protection issue outside of the license 21 renewal and outside of this proceeding.
22 That's why we've installed monitoring 23 wells, again, and they're not part of our aging 24 management programs and they're not part of -this 25 proceeding but I just want to emphasize that we're not NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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593 i ignoring groundwater protection. It's just an aspect 2 of plant operations that's addressed day to day under 3 our existing programs and the Commission has said, 4 therefore, aren't part of this proceeding.
5 I think Pilgrim Watch is also disappoin-ted 6 that those programs have been voluntary. I don't 7 think that's really -- it doesn't speak badly of 8 Entergy at all. We have done more than we were 9 required by the regulations, but in fact, the 10 Commission has recently promulgated a proposed rule to 11 look at making onsite subsurface surveys part of its 12 requirements. Again, it's not part of this proceeding 13 but it also shows that this is also important to the 14 NRC and it's also being addressed on a real time basis 15 outside this proceeding. That's all I have.
16 CHAIR YOUNG: Thank you. Ms. Lampert.
17 MS. LAMPERT: Yes, first, as everybody 18 knows, I am not a lawyer, so any error I make in this 19 proceeding does not reflect disrespect for the process 20 but my unfamiliarity and I appreciate any guidance, 21 Judge, your Honor, that you feel appropriate to 22 provide.
23 So we feel that the aging management 24 program is insufficient as it stands. The orders 25 question was does it provide appropriate assurance as NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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594 1 required under relevant regulations that the pipes 2 will not develop leaks so great as to cause those 3 pipes to be unable to perform their intended 4 functions. So the order properly assumes that during 5 the license renewal period, it's not acceptable for 6 the pipes to develop significant leaks or otherwise 7 become unable to preform their safety function.
8 Whether there is a backup system is irrelevant.
9 The question is not whether there will be 10 a disaster if the pipes fail; rather it's whether the 11 aging management program provides assurance that they 12 will not fail. In other words, the issue is whether 13 monitoring wells in conjunction with a sufficient 14 aging management program are required to provide 15 appropriate assurance that significant leaks will not 16 develop. And the only way to assure that is to detect 17 small leaks, breaks and significant corrosion before 18 the leaks have had an opportunity to grow.
19 Monitoring wells can detect small leaks 20 before they grow into large ones and proper inspection 21 can help find potential locations of small leaks 22 before there is a large scale failure. The aging 23 management programs can be put into two buckets, 24 inspection and mitigation. The problem with the 25 inspection program is many fold. There is a one-time NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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595 1 inspection during a 10-year period before license 2 renewal, a one-year inspection within the-first 10 3 years of license renewal and inspections that just 4 might happen or might not happen to occur.
5 --What's wrong? First the inspections are 6 too infrequent. It rests upon an incorrect assumption 7 that you can predict corrosion, that it is gradual.
8 We know that there is what is called the bathtub curve 9 as a component becomes older then the corrosion rate 10 increased, it is not linear and therefore, more
-11 frequent inspections are required, irrespective of 12 maintenance.
13 Maintenance can help but maintenance 14 cannot stop corrosion. I am well-maintained. I've 15 had a good diet all my life and I look in the mirror 16 and I'm very different than I was 40 years ago and 17 those buried pipes are very different than they were 18 at that period of time. Further, the inspections are 19 -- the sampling regime is -- does not inspect enough 20 of a component or maybe not all the components. it 21 again, is based upon a improper false assumption that 22 corrosion is even across a component. And we know 23 from their own documents that I would like to 24 introduce that they know this, too. They know that 25 manufacturing errors, installation errors, do not NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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596 1 necessarily happen evenly across a component.
2 They know, too, that in the making of a 3 component, it might look nice and shiny but it is not 4 homogenous across and furthermore, there are areas 5 within a pipe that are more susceptible to damage, so 6 therefore, you have to have more frequent samplings 7 and their excuse that to do so excavation would risk 8 damaging is a false excuse because there are many 9 technologies available that are non-invasive to detect 10 corrosion that do not require digging up and risking 11 the excavation process.
12 Also, and this is key, their program does 13 not require a baseline inspection now so we know what 14 there is now. They define baseline as what it was 15 like before they put it in the ground. No. We're 16 talking about going forward and without knowing where 17 you're starting, just like when you go to buy a house, 18 you have a thorough inspection to plan what you're 19 getting into, to plan your inspections and 20 replacements. They should be required to do this so -
21 - and before the license is granted, so we have an 22 understanding of the exact condition of what these 23 pipes are now and then determine, have you determine 24 whether what they're saying makes sense to develop in 25 other words, a corrosion rate by having a base of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 .RHODE ISLAND AVE., N.W.
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597 1 where we are now and then having progressive records 2 as you move along.
3 Also, they have not had a soil analysis.
4 Soil resistivity is a very important element. They 5 have not done this as they should right now, to 6 determine what, in fact, they would need. And as far 7 as a monitoring well program, Dr. Ahlfeld will discuss 8 what they have and how it is inadequate and how a well 9 designed monitoring well program, you can think of it 10 as guards outside a prison, should be designed.
11 Monitoring wells are an important aspect.
12 They are not by any means of f the record because 13 monitoring wells can serve to detect leaks so that the 14 leaks do not become so great as to interfere with a 15 significant and important functions of these pipes.
16 Monitoring wells have a variety of functions. We 17 aren't talking about it going off site and getting into 18 your lobster that you eat in Washington DC. We're 19 talking about monitoring wells as another arrow in the 20 quiver, if you will, of inspections.
21 Then another aspect of the aging 22 management program is preventative measures, 23 mitigation, again, they've failed. They assume and 24 imply that the metals are corrosion resistant. All 25 metals, all metals corrode period, both the stainless NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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598 1 steel and the carbon steel. They assume and say in 2 their documents that the soil is non-corrosive. The 3 soils here are very acid. The very pipes are besides 4 sea water. Sea water has oxygen, chloride, microbes, 5 whatever you call those things, all of these elements 6 that are highly corrosive and how can they say because 7 the last time they looked, tested soil was in 1992, 8 according to their documents in one area by the south 9 salt water discharge.
10 Wraps and liners, they provide -- they 11 continuously said it right now that they provide 12 assurance. Their own documents that I want to 13 introduce say explicitly that you cannot count on 14 wraps. You cannot count on liners because a, they do 15 not have a guaranteed life because companies won't 16 give it for very obvious reasons. There are too many 17 variables that can deteriorate the. liners, improper 18 putting them in place, et cetera, so we have to see 19 these exhibits because it undercuts one of their main 20 arguments.
21 In fact, they say in their own documents 22 that we can't consider wraps and liners. Instead we 23 have to deal with the corrosion of the metal itself.
24 Cathodic protection is another very important 25 mitigative measure. You heard in their testimony that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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599 1 they are in compliance with the GALL report. The 2 funniest thing., they never mention Section 11M 28 of 3 the GALL report which explicitly says there should be 4 cathodic protection and it also mentions the problems 5 of handling et cetera. Chemistry control, they've 6 had a history of chemistry control, nothing earth-7 shaking but it certainly isn't 100 percent and deals 8 quite obviously simply with one avenue of pipe 9 corrosion which is from the interior,. has nothing to 10 do with the exterior.
11 So what I would say, it's quite clear to 12 us is their program is insufficient. It must be 13 supplemented by establishing critical baseline data 14 requiring corrosion rates, perform a soil resistivity 15 test and prove the surveillance frequency and 16 coverage, install cathodic protection, put in a decent 17 monitoring well program.
18 And our suggestions are not big buck 19 items. This is nothing that's going to cost the 20 industry a great deal of money and it seems to us the 21 only conclusion that they are resisting this is 22 because perhaps they fear finding a hole and having to 23 fix it and so, what they are unwilling to risk is 24 spending extra money and time looking but they're 25 willing to risk our safety and I want to mention NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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600 1 something important.
2 Everyone seems to have forgotten that 3 there are three pipes under consideration here, not 4 simply two pipe systems. There's a salt water service 5 discharge that may have radioactive contamination.
6 There is the condensate system piping that has 7 contamination. No one's disagreeing with that.
8 However, the standby of fgas treatment system piping, 9 again, according to their own documents that I want to 10 be able to present to you today, says that it has the 11 potential for liquid and wetness from the condensation 12 of. the cooler soil and the warmer interior, like the 13 inside of your car.
14 And so in your order, I read it until I 15 had to get stronger glasses actually, it did not 16 indicate how much radioactive liquid. It simply said 17 pipes that have radioactive liquid in them and again, 18 according to their .own documents, we then, must 19 consider the standby offfgas treatment system piping in 20 our review.
21 CHAIR YOUNG: Which order are you 22 referring to?
23 MS. LAMPERT: Which order, I forget all 24 the numbers.
25 CHAIR YOUNG: The original one or the one NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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.601 1 that -
2 MS. LAIMPERT: No, no, no, okay, let me 3 think. It was either the October, November '07.
4 CHAIR YOUNG: The ruling on summary 5 disposition of Contention 1 probably is the one you're 6 -
7 MS. LAMPERT: Yes, probably. And then you 8 reaffirmed it when I submitted a motion saying if you 9 were taking offsite contamination off the table, then 10 we should be able to consider and broaden our view to 11 consider all pipes, all buried pipes and tanks under 12 scope and then again, your response, your denial of 13 the motion was that, 'Oh, no, we are only -- we're 14 sticking to pipes with radioactive liquids". And 15 there was not a determination whether it could be a 16 cup or many gallons, at least that's what I'm 17 suggesting that we consider. So anyway, thank you 18 very much for the opportunity.
19 CHAIR YOUNG: Thank you. Staff?
20 MS. SEXTON: Your Honor, we believe that 21 the staff's position that the aging management 22 programs for buried piping and tanks have been 23 adequately made clear in the staff's initial 24 statements, the rebuttal and in our witness' 25 testimony, thank you.
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-602 1 CHAIR YOUNG: Thank you. All right, we've 2 done al .the introductory things that we need to do at 3 this point. Let's take a five-minute break and then 4 come back and start with the' questioning.
5 (A brief recess was taken.)
6 CHAIR YOUNG: All right, if we could come 7 to order. The way in which we're going to proceed is 8 a little different. Again, we're on somewhat new 9 territory here. The way in which we're going to 10 proceed is a little different than in a traditional 11 hearing. We're going to proceed by topic and then as 12 I had indicated earlier, at some point, we will allow 13 any followup issues to be raised but by addressing 14 things according to topic, that will take us back and 15 forth as we said earlier between the experts of the 16 various parties rather than going completely with 17 Entergy's experts on all topics and then Pilgrim 18 Watch's and then the staff's.
19 Any questions about that? Yes?
20 MS. LAMPERT: You don't even have to ask.
21 When you say you are -- will allow questions, will 22 that follow each subject? You know --
23 JUDGE ABRAMSON: Let me speak to this.
24 I've done a number of proceedings under these rules 25 and our approach has been that at this point, we've NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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603 1 seen everything from all the experts in writing and 2 our approach now is to follow up with questions aimed 3 at helping us understand where there are gaps or where 4 we think we still need further information or we need 5 to-clarify the record.
6 So what I'll be doing, what Judge Cole 7 will be doing, I can't speak for what Judge Young will 8 be doing but what Judge Cole and I will be doing is 9 topically going down areas where we have remaining 10 questions that need clarifying. All the evidence, all 11 the testimony is in front of us. So we're looking for 12 clarifications.
13 If at the end -- what I will do and what 14 I expect Judge Cole will do is at the end of our 15 questions on a particular topic, we will ask all 16 parties whether there is anything particularly focused 17 on the topic we've been making questions on that they 18 think we've missed. That is not an opportunity to 19 broaden the inquiry beyond that in my mind. It's very 20 focused. I'm going to ask questions about specific 21 things and if I've missed something and the lawyers or 22 the experts think we've missed something on that 23 particular topic, we're interested in hearing it but 24 we're not interested in hearing something that's not 25 on a question that we've asked.
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604 1 Now, Judge Cole and Judge Young may take 2 a different approach. That's my approach.
3 MS. LAMPERT: And what about if a topic 4 isn't brought forward, then at the end of this 5 proceeding can we bring up topics from our knowledge 6 of this issue and our assumptions that would be then 7 appropriate to bring forward as a wrap up at the end?
8 CHAIR YOUNG: I think all the way through, 9 the answer to your first question obviously was, yes, 10 we will be trying to wrap up everything on the topics 11 as we go and at the end if there are any additional 12 items that are out there, then we'll hear from the 13 parties on those. And when I say hear from the 14 parties, we may-not agree to address all the issues 15 you would want to raise but we won't foreclose you 16 from at least asking to raise it.
17 MS. LAMPERT: I appreciate it, and I don't 18 mean to be pesty about this but I'm trying to get 19 these rules straight so it will go smoothly.
20 CHAIR YOUNG: All right.
21 JUDGE COLE: And I'll try to comply with 22 that by topic but I prepared my questions slightly 23 differently. I read through a piece of testimony and 24 I prepared my questions as I went through the entire 25 testimony but I will try to comply with keeping it in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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605
- 1. categories.
2 CHAIR YOUNG: All right. So we'll do the 3 best we can. Go ahead, Judge Abramson.
4 JUDGE ABRAMSON: okay, well, let me start 5 with a little background infformation just so you cart 6 understand where I'm coming from with the questions 7 that I have remaining at this point. Under our 8 regulations, in 10 CFR 54.21, there are definitions of 9 what must be *contained in an application. And 10 54.21(a) (1) says that for system structures and 11 components within the scope of this part as delineated 12 in 54.4, list the structures and components that are 13 subject to an aging management review.
14 And what we have is a contention about the 15 aging management program. Going on through 54.21 and 16 54.21 (a) (3) our regulations require that for each 17 structure and component identified in that earlier 10 section, the ap3plicant's application must demonstrate 19 that the effects of aging will be adequately managed 20 so that the intended function, and that's the key, the 21 intended function will be maintained consistent with 22 the current licensing basis for the period of extended 23 operation.
24 Now, Pilgrim Watch, and I'm paraphrasing, 25 in their initial contention, arguing that the aging NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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606 1 management plan was insufficient for a number of 2 reasons. It didn't -- in their view, they argued it 3 didn't provide for adequate inspection of all the 4 systems, structures and components that might contain 5 radioactively contaminated water and there was no 6 adequate monitoring to detect if and when leakage from 7 those areas occurred and that some of them included 8 underground pipes and tanks which the aging management 9 program and inspection programs do not effectively 10 inspect and monitor and then they asserted that 11 monitoring wells should be placed between the plant 12 and the ocean to supplement that aging management 13 program.
14 We went through a lot of iterations trying 15 to get the scope of what was actually in front of us 16 proper and the *best statement in my mind is a 17 statement from a January 1 1 "h order where Judge Cole 18 and I speaking for the majority said, that the 19 determination the agency must make in this instance is 20 whether or not the Applicant has programs and 21 procedures in place which enable it to determine 22 whether buried pipes and tanks containing radioactive 23 fluids are able to satisfy their intended safety 24 function despite leaks, i.e., to determine that there 25 are not leaks at such great rates so as to cause those NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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607 1 pipes and tanks to fail to satisfy those safety 2 functions.
3 Now, the functions are spelled out also in 4 our regulations. In Section 54.4, it says the 5 intended functions are spelled out that the systems 6 have to fulfill are laid out in 54.4(a) and these all 7 relate to design basis events which are very severe.
8 events. So with that, what I'd like to do is to pick 9 up and start with the Applicant and ask counsel and 10 experts for the Applicant to describe for us which 11 components or systems might contain radioactive fluid.
12 that are now left in the scope of the program? Which 13 systems and components are necessary for the purposes 14 described in 54.4 which is the scope of the 15 proceeding. Mr. Sullivan, do you want to talk about 16 that or have one of your experts talk about that.
17 MR. SULLIVAN: Mr. Cox is going to answer 18 that question.
19 JUDGE ABRAMSON: All right, thank you, Mr.
20 Cox.
21 MR. COX: As we've pointed out in the 22 license renewal application, the systems that contain 23 radioactive -- potentially contain radioactive liquid 24 that are needed to meet this requirement are the salt 25 service water system and the condensate storage NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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.608 1 system.
2 JUDGE ABRAMSON: Okay, and help me now,
- 3 .the salt water service system bring water. from 4 basically the o cean into the plant to remove heat 5 through a heat exchanger that takes heat out of. the 6 plant in a primary loop and those two loops are only 7 connected if there's a leak through a heat exchanger; 8 is that correct?
9 MR. COX: That's correct. It actually 10 removes heat from reactor building closed cooling 11 water loop which is an intermediate loop between the
- 12. salt service water system and the systems that are the 13 primary systems.
14 JUDGE ABRAMSON: Now, the pipe that brings 15 the salt water from the sea to the plant would not be 16 expected to contain radioactive water, is that correct 17 or if it did it would be radioactive water that wasn't 18 there as a result of the plant unless it got in and 19 was being pumped back in, right?
20 MR. COX: That's correct.
21 CHAIR YOUNG: I know this is going to be 22 difficult because there's only one microphone for all 23 of you but could you maybe pull it a little bit closer 24 as you talk because you're not coming across real 25 well. Thank you. I probably didn't then either.
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609 1 JUDGE ABRAMSON: What is the safety 2 function of the salt water -- what's the intended 3 function of the salt water service system as it fits 4 within Section 54.4? What brings that within the 5 scope of this? How does the salt water service --
6 where is the salt water service system relied upon to 7 meet on e of the criteria of 54. 4(a) (1) or yeah, 8 (a)(1).
9 MR. COX: We included it in the scope both 10 for 54.4(a) (1) and for 54.4(a) (3). (a) (3) is a 11 regulated event and it's credited in that scenario for 12 safe shutdown considerations after a fire.
13 JUDGE ABRAMSON: After fire.
14 MR. COX: Right.
- 15. JUDGE ABRAMSON: Okay, so the only piece 16 of the salt water service system that might contain 17 radioactive fluid, however, is the pipe taking the 18 effluent back -- taking the water back to the ocean 19 from the heat exchanger; is that correct?
20 MR. COX: That's correct, of the buried 21 piping, that is the only portion that could contain 22 radioactive materials from the plant.
23 JUDGE ABRAMSON: And what kind of failure 24 of that pipe could feasibly under any circumstances, 25 cause it to fail, cause it to cause the salt water NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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610 1 service system to fail to meet its intended function 2 of removing heat from the heat exchanger?
3 MR. COX: The only failure of that portion 4 of the piping that could do that would be a total 5 collapse that- somehow blocked off the flow path so 6 that you could g~et no flow either out on the ground.
7 If the flow runs out on the ground, it still goes to 8 the ocean. If it get through any part of the pipe, 9 it's still at the ocean. So it would take I guess 10 what we believe to be an incredible type of failur~e 11- that's not been seen that it would totally block off 12 the flow of that discharge pipe.
13 JUDGE ABRAMSON: And how big is that pipe, 14 diameter?
15 MR. SULLIVAN: Twenty-two inches.
16 JUDGE ABRAMSON: Twenty-two inches, inside 17 diameter, outside diameter?
18 MR. COX: I believe it's the OD.
19 JUDGE ABRAMSON: OD. So it's something 20 like 20 inches? What's the thickness of the pipe?
21 MR. COX: It's around 20 inches by the 22 time you take in the count, the pipe wall and the pipe 23 -- cure in place pipe lining inside.
24 JUDGE COLE: And there are two of them.
25 MR. COX: That's correct.
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61l 1 JUDGE ABRAMSON: Are they in parallel?
2 Are the redundant systems?
3 MR. COX: There are two loops that are 4 redundant.
-5 CHAIR YOUNG: I'm going to ask just for my 6 purposes, not being a technical person and not being 7 real good with all the acronyms that tend to fly 8 around, they're not as familiar to me, when you use an 9 acronym like OD, overall diameter is that --
10 MR. SULLIVAN: Outside.
11 JUDGE ABRAMSON: Outside diameter, okay.
12 Could you maybe try to remember to include what that 13 acronym stands for just for the record and to assist 14 me? Thanks.
15 JUDGE ABRAM4SON: Yeah, I'll try to do that 16 same in my questioning. Sorry, Judge Young.
17 So it's approximately 22 inches inside 18 diameter, wall thickness is something like an inch; is 19 that correct; or less? What's the approximate wall 20 thickness?
21 MR. SULLIVAN: Three-eighths inch wall 22 thickness.
23 JUDGE ABRAMSON: Three-eighths inch wall 24 thickness and what's the material?
25 MR. SULLIVAN: It's carbon steel.
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-612 1JUDGE ABRAMSON: Carbon steel and how deep 2 is it buried approximately?
3 MR. SU-LLIVAN: I'm going to turn this over 4 to Mr. Woods.
5 MR. WOODS: Salt service, water piping 6 .-
discharge to the outtake is buried at approximately 7 seven to 10 feet below grade level.
8 JUDGE ABRAM4SON: Have you ever in the 9 operating experience or inspection experience, seen 10 any obstruction to that, any material obstruction to 11 that outlet pipe?
12 MR. WOODS: No-.
13 JUDGE ABRAiMSON: Is there any history of 14 events that could cause that kind and size of a pipe 15 to become completely blocked?
16 MR. WOODS: Not that I'm aware of, no.
17 JUDGE ABRAMSON: Let me pick up with the 18 staff. Does the staff have any technical input on the 19 questions I've been asking? Are you -- are the 20 answers that we've had about the regulations that 21 govern this and how this pipe fits, are they the 22 correct regulations?
23 DR. DAVIS: This is Dr. Davis.
24 JUDGE ABRAMSON: Would you get a little 25 closer, Dr. Davis, please? It may not be turned on.
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6413 1DR. DAVIS: I agree with. what they've 2 stated.
3 JUDGE ABRAMASON: A little close, please, 4 Dr. Davis. Let's make sure everybody in the back can 5 hear you.
6 CHAIR YOUNG: Mr. Woods was real good.
7 Try to imitate him.
8 JUDGE ABRAMSON: Good. For those of you 9 in the back who couldn't see, *they disconnected the 10 microphone.
11 CHAIR YOUNG: This is technical stuff.
12 JUDGE ABRAMSON: No, it was the lawyer who 13 disconnected it.
14 (Laughter) 15 JUDGE ABRAMSON: She knew what she was 16 doing. We're going to get you some expert help.
17 CHAIR YOUNG: We're sorry we didn't have 18 more microphones.
19 DR. DAVIS: I agree with everything that 20 they said.
21 JUDGE ABRAMSON: Can you hear in the back?
22 (No) 23 JUDGE ABRAMSON: Get closer, Dr. Davis.
24 Put it right up like you're singing.
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614 1 completely.
2 JUDGE ABRAMSON: Thank you.
13 JUDGE COLE: Can you hear that in the 4 back? Okay.
5 JUDGE ABRAMSON: Does Pilgrim Watch 6 experts have any input as to whether this statement of 7 the regulations was correct?
.8 MS. LAMPERT: No, I don't believe they do 9 but I'll let them speak for themselves. They know the 10 regulation is correct. We wonder about the assumption 11 of going to failure as opposed to preventing a failure 12 to occur.
113 JUDGE ABRAMSON: That's not what I was 14 asking about, though.
15 MS. LAM4PERT: No, I was just --
16 JUDGE ABRAM4SON: I understand where you're 17 coming from.
13 MS. LAMPERT: You know, once I had --
19 JUDGE ABRAMSON: But please let's deal 20 just with the questions I'm asking. I'm trying to 21 clarify some very technical matters.
22 CHAIR YOUNG: Let me interrupt here. I 23 think it would be helpful if we keep in mind that the 24 questions are for the experts. So, you know, if you 25 want them to bring out something, you can say NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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615 1 something to them and they can bring it out, but 2 otherwise, the only thing that constitutes evidence is 3 the testimony of the *experts. And you're doing real 4 well as a lawyer given the fact that you're not a 5 lawyer, but they're the experts., so we'll let them 6 answer the question.
7 MS. LAMPERT: They are experts.
8 CHAIR YOUNG: Yes.
9 JUDGE ABRAMSON: So let me ask the 10 questions and I'm going to ask it in two parts -of the 11 experts. First of all, do you have any opinion as an 12 expert about whether the view of the applicant and the 13 staff of what are the governing regulations is correct 14 or not?
15 MR. GUNDERSEN: i guess I would -- the 16 intended function of the pipe is four-fold and I think 17 the discussion only perhaps discussed three of the 18 four. So I guess what is the intended function I 19 think I have a clarification.
20 JUDGE ABRAMSON: Let's hear it.
21 MR. GUNDERSEN: Okay. And by the way, 22 everybody has gotten my name spelled correctly so far 23 but I am s-e-n, Gundersen, I just want to get that on 24 the record early. I think the pipe has to do four 25 things. One is that it has to get enough water at NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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616 1 enough pressure-.from one point to another.
-2 CHAIR YOUNG: We're on the, service water, 3 right?
- 4. JUDGE ABRAMSON: We're talking about the 5 salt water service discharge pipe only.
6 MR. GUNDERSEN: Yes. The second issue si 7 that a failure cannot create enough back pressure to 8 reduce the, flow through the system. The third is that 9 a structural failure from a design basis event can't 10 be the event which creates that increase in back 11 pressure which may limit the effectiveness of the 12 -system and given that we have the Kapan (phonetic) 13 Earthquake which is less than 300 years old, one of 14 the most severe in New England, I think that a 15 degraded pipe could fail in such as a way as a result 16 of a design basis event that could adversely effect 17 the back pressure on that system which would limit 18 that water through the heat exchanger.
19 JUDGE ABRAM~SON: Now, as I understand 20 there are two parallel systems and let me ask the 21 Applicant, the parallel systems, with either one 22 enable the system to meet its intended function?
23 MR. SULLIVAN: Yes, it will. They are 24 redundant systems.
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617 1 systems. Mr. Gundersen, what in your mind, is the 2 likelihood of one of those earthquake events causing 3 both pipes to fail in a manner that created such back 4 pressure and what's the basis for that view?
5 MR. GUNDERSEN: Well, information provided 6 by Entergy by Pilgrim indicates that the walls are 7 below the standard thickness that they already quoted.
8 We have a document which is not yet on the record 9 which is a condition report from three years ago which 10 indicates that the wall thickness is only .49 and the 11 condition report indicates that the walls in that 12 particular system have degraded to a point where 13 they're below standard. So the initial seismic 14 evaluation of those components at the thicker wall, is 15 now no longer valid and so I think --
16 JUDGE ABRAMSON: So are you saying that 17 the pipe does not conform to the current licensing 18 basis requirement?
19 MR. GUNDERSEN: Well, the condition report 20 is pretty specific. It says that --
21 CHAIR YOUNG: Let me interrupt here. Is 22 this one of the documents that have not yet been 23 placed in the record, or is this one of the other 24 documents, because if you're referring to something 25 that's not yet in the record, this would be the time NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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618 1 to -
2 JUDGE ABRAMSON: Well, let's --
3 CHAIR YOUNG: - present that and ask that 4 it be considered.
5 - JUDGE ABRAMSON: -- let's hear what Mr.
6 Sullivan wants to say about this first and then --
7 MR. LEWIS: Mr. Lewis.
8 JUDGE ABRAMSON: I'm sorry, Mr. Lewis, 9 sorry.
10 MR. LEWIS: We would object to the late 11 exhibit. We also object to the characterization. The 12 condition report that Mr. Gundersen refers to is not 13 related to the pipe metal thickness, it relates to the 14 cured in place piping. It also doesn't relate to 15 degradation. It was a minor discrepancy in the 16 installation that was evaluated in engineering, but 17 again it relates to the interior liner, not the steel 18 and it's the pipe that's relied on to meet the seismic 19 stresses.
20 JUDGE COLE: Excuse me, I thought Mr. Cox 21 said that the diameter of the pipe was three-eighths 22 inches. That's --
23 JUDGE ABRAMSON: No, the thickness of the 24 25 JUDGE COLE: I'm sorry, the thickness of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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619 1 the pipe was three-eighth inches.
2 MR. COX: That's correct. The nominal 3 wall thickness of the pipe is .375 or three-eighths 4 inches. The cured in place pipe that's inside the 5 pipe, the lining is a nominal thickness of 6 approximately a half an inch.
7 JUDGE COLE: Okay, thank you.
8 CHAIR YOUNG: Could I clarify something?
9 JUDGE COLE: So you're referring to the 10 thickness of the liner, sir?
11 MR. GUNDERSEN: Yes, well, the number I 12 heard earlier was three-quarters and that was 13 presented in the initial dialogue. And the 14 combination of the liner and the wall is where the 15 three-quarters came from. I question whether the 16 liner is really as thick as it's --
17 JUDGE ABRAMSON: Mr. Gundersen, let's come 18 back to this. You have a --
19 CHAIR YOUNG: Let me clarify something 20 before we go on. We mentioned two pipe system, a 21 backup system. Are you talking about another service 22 water pipe or are you talking about another pipe that 23 would normally fulfill another function being used as 24 a backup?
25 MR. COX: We're talking about the same NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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620 1 pipe. It's the two loops of the discharge pipe from 2 the salt service water system to the bay.
3 JUDGE COLE: They're referred to as Loops 4 A and B?
- 5. MR. COX- That's correct.
6 JUDGE ABRAMSON: Let's see if I've got 7 this right.
8 CHAIR YOUNG: So the backup -- so that 9 backup that you're talking about is if one failed, the 10 other one would work. They're both service water 11 pipes, discharge pipes.
12 MR. COX: That is correct.
13 JUDGE ABRAMSON: And each of those pipes 14 is approximately 22-inch outside diameter, three-15 eighths inch steel and each has an internal liner
- 16. that's approximately half in thick which is cured in 17 place.
18 MR. COX: That is correct.
19 JUDGE ABRAMSON: Okay, and Mr. Gundersen, 20 as I understand the question that you're raising 21 relates to the thickness of this internal cured in 22 place lining pipe, not to the actual three-eighth inch 23 structural pipe that contains it, is that correct?
24 MR. GUNDERSEN: That particular condition 25 report address the thickness of the liner, yes, yes.
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621 1 CHAIR YOUNG: And Mr. Lewis, did you have
.2 anything to respond to that? I think you raised 3 earlier, that, indeed, was the distinction that you 4 were making.
5 MR. LEWIS: Well, I was objecting one, to 6 the exhibit as untimely, but two,' also as irrelevant 7 because the cured in place piping inside it is not 8 relied on to meet the seismic stresses. The metal, 9 the three-eighths inch thick metal piping on the 10 outside is what's relied on to meet the various 11 stresses that pip~e has to see under its service 12 conditions. ,And therefore, this condition report has 13 *no relevance to the ability to meet seismic stresses.
14 CHAIR YOUNG: But in terms of the overall 15 relevance to the ability of the pipes to withstand or 16 to perform their functions without leaking it would be 17 relevant to that, right?
18 MR. WOODS: The cured in place liner that 19 we're discussing here, the minimum wall thickness 20 required was .45 inches. From that we took 10 percent 21 and added 10 percent to that .45 and came up with a 22 nominal wall thickness of .495 and that was used in 23 the original calculation. From that it was -- you 24 take the closest nominal actual felt thickness that's 25 impregnated with the epoxy which is approximate a half NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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622 1 an inch. So the actual minimum wall required is .45 2 inches and all measurements taken exceed that .45 3 inches that were taken as samples.
4 CHAIR YOUNG: But the thickness of the 5 internal liner, if I'm using the wrong term, correct 6 me, but the thickness of that would be relevant to the 7 ability of the pipe to perform its functions without 8 leaking, right?
9 MR. WOODS: That is correct and .450 10 inches is the minimum required wall thickness.
11 JUDGE ABRAMrSON: Let's pursue this a 12 minute.
13 CHAIR YOUNG: So you're saying that that 14 minimum thickness pertains to what Dr. Gundersen 15 raised because the internal liner had not gone below 16 that thickness. Is that what you're saying?
17 MR. WOODS: That's correct.
18 CHAIR YOUNG: Okay, so we probably need to 19 rule on these proposed exhibits as they come along.
20 JUDGE ABRAMSON: And I'm okay with this 21 particular exhibit and I think I want to pursue this.
22 CHAIR YOUNG: Well, then let's --
23 JUDGE ABRAM4SON: Mr. Lewis, do you have a 24 concern here?
25 MR. LEWIS: No, I would like to see the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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623 1 exhibit. If it does come on, I'd like to make sure 2 it's the complete condition report and also shows the 3 engineering disposition reflecting that it doesn't 4 create a problem.
5 JUDGE ABRAMSON: Do you have a copy of the 6 complete report, Mr. Gundersen, or is it just 7 excerpts?
8 MR. GUNDERSEN: Hang on, we'll see.
9 CHAIR YOUNG: Pass them out to the parties 10 and then --
11 JUDGE ABRAMSON: While you're passing that 12 out, let me pursue this. While you're passing that 13 out, let me pursue this. Mr. Gundersen, you started 14 out by saying that you were concerned that this pipe 15 could collapse because a condition indicated that the 16 pipe itself was much thinner than expected. Now what 17 we're hearing is that, in fact, the condition report 18 that you're concerned about relates to an internal 19 liner inside a three-eighths inch thick, 22-inch 20 outside diameter carbon steel pipe as to which this 21 particular condition report does not apply, right? It 22 only applies to the liner; is that correct?.
23 MR. GUNDERSEN: Does my yes concur with 24 your whole question or just the last part?
25 JUDGE ABRAMSON: No, does it, does it --
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624 1 MR. GUNDERSEN: The condition report 2 relates to the liner, yes.
3 JUDGE ABRAMSON: Okay. And now, would you 4 explain to me why that condition report is relevant to 5 the ability of this particula-r pipe or to the 6 likelihood that this particular pipe within a pipe, if 7 you will, or pipe surrounding a pipe, could become 8 completely blocked in a way that it would fail to 9 allow water to go back from the heat exchanger to the 10 ocean?
11 MR; GUNDERSEN: Okay. If the pipe were at 12 thick as it were designed without any failures, and 13 essentially in its original condition back in '72, or 14 as its designed with the current licensing basis, the 15 thickness were as analyzed, either one of those two 16 pipes would provide the adequate redundancy. My 17 concern is that either one of the --
18 JUDGE ABRAMSON: Loop A or Loop B you 19 mean?
20 MR. GUNDERSEN: Yes, either Loop A or Loop 21 B, if they were as -- if they were in the condition as 22 originally designed, either loop would provide the 23 redundancy to adequately cool the plant if the other 24 loop failed for whatever reason.
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625 1 and failures in that service water system is that the 2 -- and by photographs provided by Pilgrim of what 3 appear to be pinhole leaks ganging up in one area, 4 would weaken the pipe in locations that have not been 5 analyzed in the original design basis calculations.
6 So it's the liner thickness issues, the fact that 7 these pipes have since about 1998 begun to fail, it's 8 those indications that lead me to be concerned about 9 the integrity of the pipe in the event of a design 10 basis event like a Kapan Earthquake.
11 I ran a structural engineering group of 12 about 70 people at one point and this is an easily 13 testable hypothesis. You could do a finite element 14 analysis on that pipe.
15 JUDGE ABRAMSON: To do a finite element 16 analysis, on the pipe I presume you'd have to know the 17 current state of the pipe, otherwise an analysis would 18 be meaningless, right?
19 MR. GUNDERSEN: That's correct.
20 JUDGE ABRAMSON: And how would you get 21 that current -- the current state of the pipe, go 22 measure it every six inches all the way its entire 23 length?
24 MR. GUNDERSEN: No, I think you could do 25 an internal volumetric inspection or --
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626 1 JUDGE ABRAMSON: And if you did an 2 internal volumetric inspection, this is a lined pipe, 3 would you not get information on the liner and not on 4 the three-eighth inch carbon steel pipe that contains 5 it?
6 MR. GUNDERSEN: No, I think with the 7 internal inspections, especially the face ray 8 approaches I think you could get a good indication of 9 the condition of the entire pipe, not just the liner.
10 CHAIR YOUNG: I am going to interject from 11 time to time to make sure I understand what you are 12 saying, what the various experts are saying from a 13 non-technical standpoint. Is what you. are saying that 14 if there were several places where there was a 15 degradation of the liner so that there could be some 16 lessening of the thickness of the pipe, if there were 17 several places relatively close together, then if 18 there were a design basis event, that would cause that 19 portion of the pipe to fail, sort of to crumple in on 20 itself so that that would block the discharges? Did 21 I understand that correctly?
22 MR. GUNDERSEN: That is correct, Your 23 Honor.
24 CHAIR YOUNG: Okay.
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627 1 because when you say it "could, what would you 2 suspect is -- from the information that you have seen 3 on this pipe, in your professional judgment, what is 4 the likelihood that there are regions of this pipe 5 that are so degraded that in the event of a design 6 basis earthquake, that pipe could wholly collapse on 7 itself, blocking flow?
8 MR. GUNDERSEN: Pilgrim provided two 9 photographs. And we have them. They're not on the 10 docket yet as an exhibit, but we have two photographs 11 provided by Pilgrim which show not a single hole.
12 Even a large single hole is not my concern.
13 These photographs show a broad attack of 14 several smaller holes which have grown into larger 15 holes.
16 JUDGE ABRAMSON: They show that on the 17 liner, correct, or do they show it on the outer pipe?
18 MR. GUNDERSEN: There is not a lot of 19 information with the photographs, Your Honor. So I am 20 really not sure. It appeared to be through-wall to 21 me.
22 CHAIR YOUNG: And we are talking about --
23 MR. GUNDERSEN: And it appeared to be an 24 attack on the metal, not the liner.
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628 1 that we're talking about here, the photographs of --
2 MR. GUNDERSEN: Pilgrim provided 3 photographs. And it is not clear which system those 4 --
5 JUDGE ABRAMSON: And is there a reason 6 that you have not discussed this particular matter in 7 your testimony, either your prefiled testimony or your 8 rebuttal testimony?
9 MR. GUNDERSEN: I think I did discuss the 10 issue of structural weakening of the pipe in my --
11 JUDGE ABRAMSON: And did you refer to 12 either? Did you refer to these photographs or this 13 condition report in your testimony to support it?
14 MR. GUNDERSEN: No, I did not. I wanted 15 to introduce it today.
16 JUDGE ABRAMSON: Why did you not refer to 17 it at that point? This is a very late moment to be
- 18. trying to bring up new information. Now, we are not 19 saying that we can't consider it, but we would 20 certainly like to understand why if you feel so 21 strongly now -- I don't want to hear from you, Ms.
22 Lampert.
23 MS. LAMPERT: Oh, I was going to --
24 JUDGE ABRAMSON: I want to hear from the 25 expert why when you wrote your expert testimony you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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629 1 did not refer to these things.
2 MR. GUNDERSEN: My experience led me to 3 write the expert report just on my experience. And 4 counsel had not provided me with those photographs 5 when I wrote the report. It was based on my 6 experience at other facilities.
7 CHAIR YOUNG: Is this one of the exhibits 8 that you had recently proposed be admitted that were 9
10 MR. GUNDERSEN: Yes, it is.
11 CHAIR YOUNG: -- part of the Entergy 12 disclosures?
13 MR. GUNDERSEN: Yes, it is, Your Honor.
14 JUDGE ABRAMSON: Have you seen these 15 exhibits?
16 MR. SULLIVAN: We have not seen these 17 exhibits. I would like to mention that prior to 18 lining the pipes, we did a complete visual inspection 19 of them looking for any evidence of deterioration, of 20 degradation prior to lining the pipes because we would 21 not want to put the liner in the pipes, you know, 22 covering up something that was degraded.
23 So we did an inspection of the piping and 24 ensured that the piping was in good material condition 25 before we lined the pipes with the epoxy liner.
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630 1 JUDGE ABRAMSON: And what year was that 2 done approximately? -
3 MR. SULLIVAN: Approximately 2001 and 2003 4 on the alpha, bravo loops, not respectively.
5 JUDGE ABRAMSON: Let's come back to this 6 exhibit. And then let's hear about these photographs 7 and find out what they are.
8 CHAIR YOUNG: All right. I think that we 9 are in agreement on 10 JUDGE ABRAM'SON: Well, let's see. Has the 11 applicant had a chance to look at this condition 12 report?
13 MR. LEWIS: It is not a complete document.
14 I will try in a break to obtain the complete document 15 and maybe be able to provide it so a complete document 16 can be put in.
17 I notice that portion that's provided 18 doesn't represent the disposition, which is that this 19 wasn't a condition averse to quality. I think if a 20 document comes in, it ought to be a complete document 2j1 or it's inherently unreliable.
22 JUDGE ABRAMASON: I agree. I would like to 23 -see the whole document.
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631 1 and then submit it later?
2 JUDGE ABRAM4SON: No. Either we get the 3 whole thing or we don't. I think we could do it later.
4 MR. LEWIS: Would you want also the 5 photographs?
6 JUDGE ABRAM4SON: Yes. I would like to see 7 the photographs. Can we get the photographs 8 distributed to everybody so we can see them?
9 MR. LEWIS: Let me just say two things on 10 the photographs. First of all, I don't recall -- I 11 will go back and check, but I don't recall those being 12 one of the supplemental exhibits that the Pilgrim 13 Watch asked to introduce.
14 Second, the photographs that we provided 15 in our disclosures were photographs of the portions of 16 the saltwater service discharge piping that were 17 replaced. So they are not photographs of the existing 18 in-service portions of the pipes.
19 JUDGE ABRAMSON: So let's try to find out 20 what photographs Mr. Gundersen is talking about, and 21 then we can decide. If they were, in fact, parts that 22 were replaced, that gives us useful information. if 23 they are some other photograph, let's find out what 24 the applicant says they are.
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632 1 counsel?
2 MS. LAMPERT: Yes.
3 MR. LEWIS: Yes.
4 JUDGE ABRAMvSON: Okay. Let's get those to 5 the applicant so they can take a look at them.
6 *Does the staff know anything about either 7 this condition report or the photographs that are 8 being discussed?
9 MS. UTTAL: I don't think we got the 10 photographs either because I don't think that they 11 were in the exhibits that she tried to get in late.
12 CHAIR YOUNG: Let's try to clarify that.
13 And also let me just say the procedure here. If you 14 proffer, if you give us an exhibit that you would like 15 to have introduced, either we will allow that or not 16 allow that. If we allow it, we will give it an 17 official exhibit number and place it on the official 18 exhibit list.
19 If we don't and you would like to have it 20 placed in the record as an offer of proof, make that 21 request at the time. And that way it will be in the 22 record for appeal, even though it's not part of the 23 evidentiary record.
24 And could you also refer back after you 25 pass those out to the original list of the proposed NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE-, N.W.
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633 1 late-filed exhibits so that we could identify where 2 that came on that list-if it did?
3 MS. LAiMPERT: Yes. What I did -
4 CHAIR YOUNG: And also when you give them 5 to us, give one to --
6 JUDGE ABRAM'SON: Make sure you give it to 7 the applicant first because they are the ones who are 8 going to have to provide us information on what it is.
9 MS. LAMPERT: Oh, okay. Is that going to 10 be -
11 CHAIR YOUNG: Just give it to everyone, 12 all the parties and then us.
13 JUDGE ABRAMSON: These are exactly what 14 you got. This is not --
15 MS. LAMPERT: This is it. It didn't have 16 any identification on it.
17 JUDGE ABRAMSON: Okay.
18 CHAIR YOUNG: We probably need to avoid 19 talking like this. The court reporter needs to get 20 everything you say.
21 JUDGE ABRAMSON: Ms. Lampert, did these --
22 MS. LAMPERT: Yes?
23 JUDGE ABRAMSON: -- photographs have any 24 identification on them at all?
25 MS. LAMPERT: No. They had that Bates NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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-634 1 number, I believe it's called, on the bottom. And 2 that was it. It didn't say where it was, when it was 3 taken. It just had the Pilgrim identification that 4 was in a disk disclosure that was provided.
5 And I apologize to my witness because when 6 I first got involved in this, I saw the quarter beside 7 it. And I thought, what the heck, you know, this 8 isn't that big, as opposed to a trained expert looking 9 at it and seeing all the pinholes and what it actually 10 does tell. And so I apologize.
11 JUDGE ABRAMSON: That's okay.
12 MS. LAMPERT: But I also want to add that 13 these are numbered, as Judge Young asked me. These 14 are numbered. And so they indicate whether they have 15 been provided as late-filed or not.
16 And those that haven't been provided in, 17 what, 20 days ago, then I thought that the rules say 18 we could offer 'exhibits at the hearing and if they 19 were denied, as you explained, give an offer of proof 20 or whatever that is.
21 CHAIR YOUNG: So you are saying that this 22 -- I think it should be marked 53.
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6"35 I Number 53.)
2 CHAIR YOUNG: This was one of the list?
3 MS. LAMPERT: No.
4 CHAIR YOUNG: This was not one of the 5 list?
6 MS. LAMPERT: No.
7 CHAIR YOUNG: This was something separate?
8 MS. LAMPERT: Right, yes.
9 JUDGE ABRAMSON: This is an exhibit which 10 was not preferred in your last proposed additional 11 exhibits. Is that correct?
12 MS. LAMPERT: That is correct.
13 JUDGE ABRAMSON: What led you to believe 14 that these relate to the saltwater service outlet 15 pipe?
16 MR. GUNDERSEN: They were provided by 17 Entergy as part of this process.
18 JUDGE ABRAMISON: And did Entergy identify 19 them as being related to the saltwater service pipe or 20 could this be a picture of any *piece of plate or 21 anything? What makes you think this is saltwater 22 service piping?
23 MR. GUNDERSEN: I know there have been 24 failures in the saltwater service piping and, among 25 other failures. But that is a system which had NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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636.
-1 failures. And it was provided as part of this docket.
2 Sd, you know, there's --
3 JUDGE ABRAMSON: But could it have been 4 some other pipe in the docket? I am asking a very 5 specific question. What makes you believe this is 6 saltwater service pipe.
7 MR. GUNDERSEN: There's only three pipes 8 on this docket. And the saltwater service pipe is 9 carbon steel. This appears to be an attack in carbon 10 steel.
11 JUDGE ABRAMSON: Okay. So, applicant, do 12 you recognize either of these photographs?
13 MR. SULLIVAN: Yes, Judge, we do recognize 14 these photographs. This was material that was found 15 degraded in 1999. Mr. Woods will speak to that in a 16 moment, to the details of it.
17 It was found as part of our salt service 18 water system integrity program that will show us that 19 we do periodic monitoring of the integrity of the 20 piping and the integrity of the salt service water 21 system.
22 The specific details of this Mr. Woods 23 will discuss.
24 JUDGE ABRAMSON: Okay. Please?
25 CHAIR YOUNG: Just to clarify, you found NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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637 1 this during a periodic inspection?
2 MR. WOODS: That is correct.
3 CHAIR YOUNG: And how frequent was that 4 particular type of periodic inspection?
5 MR. WOODS: We originally did an 6 inspection in 1995 of the internal existing rubber 7 liner that was in the salt service water discharge.
8 CHAIR YOUNG: That was originally --
9 MR. WOODS: Original rubber liner. That 10 is correct.
11 JUDGE ABRAMSON: And what are these 12 photographs of?
13 MR. WOODS: These photographs are from 14 1999, when an inspection was done and they found 15 degraded through-wall leak. And that spool piece was 16 actually dug up and removed and replaced.
17 JUDGE ABRAMNSON: What was this? Is this 18 a photograph of the pipe, --
19 MR. WOODS: This is a photograph --
20 JUDGE ABRAMSON: -- 3/18 pipe?
21 MR. WOODS: -- of the three-eighths-inch 22 pipe with the rubber liner removed. And the external 23 surface of the carbon steel is coated. And that was 24 removed basically to look at the external portion of 25 the pipe to see how the pipe wrap did and identified NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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638
- 1. that it was from the internal to the external 2 through-wall leak.
3 CHAIR YOUNG: You used the term "spool 4 piece."
5 MR. WOODS: Section of pipe.
6 CHAIR YOUNG: Okay. And as to the 7 periodicity of it, if that's the right term, how often 8 did you do those?.
9 JUDGE ABRAMSON: Frequency.
10 CHAIR YOUNG: Frequency.
11 MR. WOODS: In 1995, an inspection was 12 done and noted a little bit of degradation on the 13 existing rubber lining. And then it was determined to 14 go ahead and do another inspection in 1997 to monitor 15 that area. And that was okay at the time.
16 And then we looked at it again in 1999 and 17 found that the rubber lining had actually -- a portion 18 of the rubber had delaminated and actually torn away 19 from it and, as a result, had the through-wall leak.
20 So at that point in time, we replaced that section of 21 pipe.
22 CHAIR YOUNG: Did you do the periodic 23 inspection --
24 AUDIENCE MEMBER: Can you get the 25 microphone? Can you speak into the microphone?
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639 1 CHAIR YOUNG: Did you do the periodic 2 inspections every two years as a matter of course or 3 did you do them in '97 and '99 because you had noticed 4 something in '95? What I was trying to get at is, how 5 often would you normally do these periodic inspections 6 of that pipe?
7 MR. SULLIVAN: Well, in a general sense, 8 we would inspect it as much as we thought we needed to 9 inspect it. But, just to provide some clarification, 10 this section of piping was cut out, was replaced, as 11 Steve discussed.. And the piping has subsequently been 12 lined with the epoxy liner. And the current 13 inspection period is ten years on epoxy.
14 CHAIR YOUNG: It's ten years. That's what 15 I was trying to get to. Thank you.
16 JUDGE ABRAMSON: Now, this was discovered 17 as part of your ongoing operation and maintenance 18 process. Is that correct?
19 MR. SULLIVAN: That is correct.
20 JUDGE ABRAMSON: And before you lined it, 21 you inspected the entire length of the pipe of both 22 loop A and loop B?
23 MR. SULLIVAN: That is also correct.
24 JUDGE ABRAMSON: And did you f ind any 25 degradation of either pipe?
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640 1MR. SULLIVAN: We did not find any 2 degradation. We were looking for degradation of-the 3 rubber lining.
- 4. JUDGE ABRAMASON:- Of the rubber lining?
5 MR;, SULLIVAN: Of the rubber lining.
6 That's correct.
7 JUDGE ABRAMSON: And then was the rubber 8 lining removed and the new failed epoxy lining put in?
9 MR. SULLIVAN: The rubber lining --
10 MR. WOODS: We did find one area of 11 degradation approximately eight foot in from the very 12 end of the discharge. UT readings were taken. And 13 that was slightly below the min. wall. And welded 14 overlay was done.
15 CHAIR YOUNG: Minimum wall?
16 MR. WOODS: Minimum wall thickness. A 17 weld overlay was performed on that area to build that 18 wall back up. So the entire pipe that was exposed 19 from the rubber lining missing did meet the wall 20 thickness required.
21 JUDGE ABRAMSON: And then tell us a little 22 bit about how you put the new cured-in-place lining.
23 And did you take the rubber liner out or did you put 24 -
25 MR. WOODS: No. The rubber liner stayed NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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641 1 in place. And that was inspected 1-00 percent visually 2 to make sure it was intact and in good shape. And 3 that's where we found the one place that was torn. We 4 did the weld overlay to build up the wall thickness of 5- the existing steel pipe.
6 And then the cured-in-place liner was put 7 in on top of the existing rubber liner.
8 JUDGE ABRAMSON: So the existing rubber 9 liner was at that point complete and intact. So you 10 had no evidence of any leaks in that liner at that 11 point?
12 MR. WOODS: That is correct.
13 JUDGE ABRAMSON: Visual evidence was what 14 we got. And then you installed inside that a new 15 epoxy-impregnated felt liner. Is that correct?
16 MR.-WOODS: Yes, that is correct.
17 JUDGE ABRAMSON: Okay. So what we have 18 now is three-eighth-inch thick, 22-inch outside 19 diameter carbon steel pipe lined by a rubber liner.
20 And that is lined by this epoxy liner, which is 21 impregnated into felt. Is that correct?
22 MR. WOODS: Yes.
23 JUDGE ABRAMSON: And what is the -- okay.
24 So is there any evidence that would lead you to 25 believe there is degradation of the three-eighth-inch NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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642 1 carbon steel pipe to a state which would cause it not 2 to meet its current licensing basis?
3 MR. WOODS: No, not at all.
4 JUDGE ABRAMSON: Does the staff have any 5 comment on that? Staff does oversight here.
6 DR. DAVIS: Yes. I agree with what they 7 say.
8 JUDGE ABRAMSON: Speak into the mike 9 again, Dr. Davis, please.
10 DR. DAVIS: Every time they have looked at 11 the external coating, which is in the buried pipe and 12 tanks inspection program, it has been intact after 36 13 years with no degradation. The only degradation they 14 have seen is from the inside.
15 CHAIR YOUNG: We are talking about the 16 inside now, though, right?
17 DR. DAVIS: Yes.
18 JUDGE ABRAMSON: Yes.
19 DR. DAVIS: But that is not part of the 20 buried pipe and tanks inspection program, just to make 21 it clear. It's part of --
22 JUDGE COLE: That just deals with the 23 outside of the pipe.
24 DR. DAVIS: That's right.. This is part of 25 the service water integrity program.
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643 1 JUDGE ABRAMSON: So, just to repeat, we 2 have got parallel systems, both at this point 3 identical with the exception of whatever aging might 4 have happened to them. Is that correct?
5 So that we have got two pipes, two 6 parallel systems, which can remove the heat. Each one 7 of them has this same configuration: An outside 8 carbon steel pipe, lined by rubber, lined by an 9 epoxy-impregnated felt liner.
10 DR. DAVIS: That is correct.
11 JUDGE ABRAMSON: That is correct? And 12 those liners were installed, the new liners were 13 installed, in '01 and '03?
14 DR. DAVIS: That's correct.
15 JUDGE ABRAMSON: Mr. Gundersen -- Judge 16 Young, what do we want to do about these photographs?
17 Does the applicant, now having discussed these 18 photographs, have any objection to these being 19 admitted into evidence.
20 MR. LEWIS: No objection.
21 JUDGE COLE: Are these photographs part of 22 the 40-foot section that was replaced?
23 MR. WOODS: Yes.
24 JUDGE COLE: And there were 2 40-foot 25 sections?
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644 1 MR. WOODS: That is correct.
2 JUDGE COLE: Is this a photograph from 3 each of the separate sections?
4 MR. WOODS: No. This is a photograph of 5 both sides of that piece of metal.
6 JUDGE COLE: Okay. Same piece, then?
7 MR. WOODS: Right.
8 JUDGE COLE: Thank you.
9 MR. WOODS: On one side is the internal 10 diameter portion, and the other picture is the 11 external diameter portion of the --
12 JUDGE ABRAMSON: When those 2 40-foot 13 sections were removed, were there any other 14 through-wall penetrations?
15 MR. WOODS: No.
16 JUDGE ABRAMASON: This is the only one?
17 MR. WOODS: Yes.
18 JUDGE ABRAMSON: What diameter is this is 19 approximately a quarter? That was at a quarter 20 sitting on there that I can see for comparison?
21 CHAIR YOUNG: I think that's what they 22 said.
23 MR. WOODS: Yes, that's a quarter.
24 JUDGE ABRAMSON: Okay. So we are looking 25 at something that is maybe three-quarters of an inch NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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645 1 in diameter for all-, no other evidence of degradation?
2 JUDGE COLE: You know', looking at these 3 two photographs, both of them look like the top side 4 of the pipe based upon the curvature.
5 CHAIR YOUNG: I think this was more 6 just to take care of this formality here, I am going 7 to be interrupting when we need to do this. The pipe 8 has been identified. You have indicated that there is 9 no objection to-it.
10 Did staff have any objection?
11 MS. UTTAL: No objection.
12 CHAIR YOUNG: All right. Then that will 13 be entered as exhibit 67.
14 (Whereupon, the aforementioned 15 item was marked for 16 identification as Exhibit 17 Number 67 and was received in 18 evidence.)
19 CHAIR YOUNG: Do we have original photos 20 or are we putting in a copy like the one we --
21 JUDGE ABRAMSON: Is this what was actually 22 distributed to them, do you think, in the record?
23 These came off a disk, you said, right?
24 MR. LEWIS: I know the photograph -- yes, 25 we produced our documents in disclosure on CDs. I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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646 1 know the document that we produced was a color 2 photograph that had much better clarity than this.
3 CHAIR YOUNG: If you want to substitute 4 that, you can do that. We will go ahead and introduce 5 it now. And if you want to substitute the actual 6 photograph or a better printout of what is on the CD, 7 I think that would be appropriate.
8 MR. LEWIS: And I also would if this is 9 coming in like to suggest to the Board a follow-up 10 question at some point to put this in perspective.
11 JUDGE ABRAIMSON: Yes, that's fine. Let me 12 follow up.
13 CHAIR YOUNG: I think we need to wrap up 14 on all of this.
15 JUDGE ABRAMSON: Well, we will do each 16 point.
17 CHAIR YOUNG: So there will be several.
18 There will be several.
19 JUDGE ABRAMSON: Mr. Gundersen, what we 20 are hearing now from the applicant is that this was 21 degraded pipe that was replaced. And you have heard 22 their description of the pipe and their assertion that 23 there is no reason to believe that the external pipe 24 doesn't satisfy the current licensing basis. If the 25 pipe satisfied the current licensing basis, would you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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647 1 be concerned about this potential failure. that could 2 block both loops on the outlet pipe?
3 MR. GJNDERSEN: if -- I think there is -
.4 if the pipe satisfied its current licensing basis for 5 the 60 years of the plant's life, there would be no 6 need for an aging management program and I would have 7 no concerns.
8 The fact of this matter is, though, that 9 their own -- and, frankly, it was wonderful that they 10 did both a visual inspection from the inside and an 11 ultrasonic inspection -- I think that has been 12 acknowledged this morning -- from the inside, both of 13 which I have been advocating for as part of the 14 overall aging management plan, as opposed to just 15 opportunistic looks at the outside.
- 16. So I think that if we had a commitment to 17 -- and not every ten years, but if we had a commitment 18 to do a volumetric inspection of the pipe and a visual 19 inspection of the pipe -- this is a large pipe.
20 You can crawl in this pipe. Then that 21 would be a much better piece of an overall inspection 22 program to make sure that the pipe remains within its 23 current licensing basis.
24 JUDGE ABRAMSON: Okay. Now, we have been 25 discussing -- and there is a lot of testimony in the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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648 1 record about the buried pipe inspection program, which 2 looks at it from the outside. What we don't know is 3 what they are proposing to do on the internal 4 inspections as part of their ongoing operation and 5 maintenance procedure. So perhaps we should hear 6 that.
7 What is the plan of the applicant? What 8 would your ordinary ongoing operation and maintenance 9 programs tell you to do with these pipes?
10 MR. GUNDERSEN: For the very discharged 11 pipe with the new cured-in-place liners, we have got 12 a ten-year inspection frequency right now. When we 13 first put the liners in, we proposed a 10 or a 20-year 14 frequency. We have gone with a ten-year frequency 15 just to verify and assure that there are no changes in 16 the cured-in-place liner.
17 JUDGE ABRAMSON: So they went in in '03.
18 And when would your next -- the latest one went in in 19 20 MR. GUNDERSEN: Two thousand and one and 21 2003. So it would be 2011 and 2013.
22 JUDGE ABRAMSON: So we're talking about 23 four or five years from now. This is before the 24 license extension actually commences. Is that 25 correct?
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.649 1 MR. GUNDERSEN: One will be.
2 JUDGE ABRAMSON: One would be before, and 3 one would be after. And what would the licensee do if 4 at that point your inspection indicated that there was 5 beginning to be failure, there was some degradation of 6 the cured-in-place liner?
7 MR. SULLIVAN: As demonstrated by what we 8 did when we found degradation in the rubber lining, we 9 would do the inspections that were necessary to be 10 done to ensure that we meet our current licensing 11 basis.
12 We would write a condition report, enter 13 into our corrective action program, and we would 14 disposition it to ensure that the system continues to 15 meet its safety function.
16 JUDGE ABRAMSON: Staff, what would be the 17 staff's response to this condition report that 18 indicates that they are beginning to see some 19 degradation? Would you then iterate with the licensee 20 on what was the proper procedure going forward or how 21 would that work?
22 MR. CHAN: I am Terrence Chan.
23 We would not iterate with the licensee 24 with respect to this non-conformance. They would 25 themselves analyze the situation and determine by NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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-650 1 their own analyses as to what is the appropriate 2 reinspection frequency to ensure that all regulatory 3 requirements are met.
4 JUDGE ABRAM~SON: And you would not verify 5 that? You would just take it in and file it 6 somewhere?
7 MR. CHAN: No. Our inspectors would 8 review those condition reports.
9 JUDGE ABRAMSON: And what do -the 10 inspectors -- what is their responses? They review it 11 and put it in a file or do they do something with it?
.12 MR. CHAN: I am not an inspector. So I 13 can't speak to what the inspectors would say or what 14 they would do with it, but they would evaluate the 15 adequacy of the corrective a ction that was taken. They 16 would -- from what I have seen, they validate or -
17 excuse me -- they verify that the analyses and the 18 evaluations have been conducted properly. And they 19 would if there were any questions raised regarding the 20 actions that the licensee took, this is part of -- all 21 of this is part of the -ongoing operation and 22 maintenance and the agency's oversight. Is that 23 correct?
24 DR. DAVIS: Yes. Every condition report 25 has a cursory review by the resident inspectors. They NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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6-51 1 look at every single one. And then the region comes 2 in on a periodic basis. And they select certain 3 condition reports, and they do a thorough 4 investigation-of those. That's part of our looking at 5 the appendix B quality assurance program.
6 So not all condition reports are reported 7 to the NRC, only certain ones. And they have to 8 exceed a threshold before they are reported to the 9 NRC.
10 CHAIR YOUNG: To the regional inspector or 11 12 DR. DAVIS: Or to the headquarters. If 13 they meet a certain threshold, then they have to be 14 reported on the licensee of that report.
15 JUDGE COLE: But they are all seen by the 16 inspector on site?
17 DR. DAVIS: Yes.
18 CHAIR YOUNG: Okay. That is what I was 19 trying to clarify, that they do a condition report, 20 the applicant does a condition report, no matter what.
21 The resident inspector would see all of those.
22 DR. DAVIS: Yes.
23 CHAIR YOUNG: Not all of those would 24 necessarily be forwarded to the office. What's the 25 name of the office that they would come to that sounds NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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652 1 -
2 JUDGE ABRAMSON: NRR.
3 DR. DAVIS: NRR, yes.
4 CHAIR YOUNG: NRR. Not all of them would 5 be forwarded to NRR.
6 DR. DAVIS: That's correct.
7 CHAIR YOUNG: That is what you are saying?
8 DR. DAVIS: That's correct.
9 JUDGE COLE: And we are talking about the 10 NRC inspector on site?
11 DR. DAVIS: Yes.
12 CHAIR YOUNG: I would like to just clarify 13 something at this point about the periodic 14 inspections. But first, even more simple 15 clarification, the rubber liner that you are referring 16 to -- I want to see if I understand this -- the 17 original pipes had a rubber liner, correct?
18 MR. SULLIVAN: That's correct.
19 CHAIR YOUNG: And that rubber liner, was 20 that something that was a separate piece put inside 21 the pipe or was that something that was applied and 22 then somehow cured or allowed to --
23 MR. SULLIVAN: The original rubber lining 24 was applied as part of the manufacturing process for 25 the pipe. So we receive it with a pipe with a rubber NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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653 1 liner.
2 CHAIR YOUNG: Okay. But it's something 3 that's applied to the inside of the pipe? It's not a 4 separate piece?
5 MR. SULLIVAN: That's correct.
6 CHAIR YOUNG: So that it adheres to the 7 inside of the pipe?
8 MR. SULLIVAN: That's correct.
9 CHAIR YOUNG: And then you say later you 10 added on an additional coating over all of the 11 interior of the pipe or just part of it?
12 MR. SULLIVAN: Yes, over the entire run of 13 the discharge piping. And that was because the rubber 14 lining was nearing end of life. And based on our 15 inspections that we had been performing, we knew that 16 we had to -- we had to deal with the degradation of 17 the rubber lining.
18 CHAIR YOUNG: Okay. So the original pipes 19 with the rubber liner, that was at the -- when the 20 plant was built?
21 MR. SULLIVAN: That's correct.
22 CHAIR YOUNG: And then the additional 23 application was done when again?
24 MR. SULLIVAN: The cured-in-place --
25 CHAIR YOUNG: Cured-in-place.
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-6.54 1 MR. SULLIVAN: -- pipe liner was done in 2 2001 and 2.003 on one of the loops in '01 and the other 3 loop in '03.
4 CHAIR YOUN~G: Right. Okay. Thank you.
5 That clarified that basic informat-ion.
6 The other question I have is -- and if you 7 could help me understand it? I would also like to 8 hear from the staff and the intervenor' s experts as 9 well. If the periodic inspection is every ten years 10 and, as I understand it, as one of those periodic 11 inspections, it *was discovered that there was some 12 indication-of the liner wearing away or whatever the 13 correct term is and then you looked at it again two 14 years later and it might have been a little worse, but 15 it wasn't bad enough to do anything about it at that 16 point. And then two more years later, you found that 17 it actually had gone through to the metal of the pipe, 18 and you replaced that part.
19 The question that comes to my mind and 20 -that I would like to get some clarification on is if 21 that could occur in a space of six years, what 22 assurance do you have that you would catch anything 23 like that in ten years? Would it be possible that 24 some level of degradation could start occurring in 25 year one? And then if you add six years to that, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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- 655 1 which is the progression that we talked about before 2 or, actually, only four years from the initial 3 discovery, how would you assure that it wouldn't be 4 possible that something could reach the level that you 5 discovered in 1999 before you did your next ten-year 6 inspection?
7 MR. SULLIVAN: The rubber lining has a 8 life of approximately 20 years. And when we began, 9 when we did the inspections, we found degradation. So 10 we increased the inspection frequency, and we looked 11 at --
12 CHAIR YOUNG: From what to what?
13 MR. SULLIVAN: Well, we started looking at 14 it every refueling outage, every two years. That's 15 for the rubber lining. The cured-in-place lining is, 16 as we discussed, an epoxy coating liner that has a 17 life expectancy of approximately 35 years.
18 And that system of pipe lining is used 19 extensively in industry. And by "industry, " I mean 20 waste water systems, public water supply systems, et 21 cetera. So there's a fairly large experience base for 22 the use of that piping system, if you will.
23 We chose just because we don't have a lot 24 of experience with it at the power plant to --
25 CHAIR YOUNG: With?
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656 1 MR. SULLIVAN: With pipe lining systems to 2 inspect it every ten years. And we believe that that 3 is a conservative, proactive inspection frequency so 4 that we can detect any degradation if it's occurring.
5 CHAIR YOUNG: Let me see again if I can 6 understand. Let me just follow this up. I would like 7 to get my understanding clear at least on what the 8 situation is.
9 So tell me if I am understanding this 10 correctly. You're saying that the degradation that 11 was discovered to be starting in '95 and that you left 12 in place in '97 and that you then replaced in '99, 13 that was to the rubber liner.
14 And so you're saying that the assurance 15 that you have that a similar degradation happening 16 over that space of time would not occur because, in 17 addition to the rubber liner, now there is this epoxy 18 coating.
19 And just to see if I understand, the epoxy 20 coating is on top of the rubber liner. And then it's?
21 How is it cured? Does it become bonded with the 22 rubber liner? How does that work?
23 And basically so I am asking two 24 questions. one, how does that work? And, two, is 25 your answer about the assurance based on the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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657 1 experience with the epoxy, suggesting that the epoxy 2 would not degrade as quickly once something is started 3 as the rubber would? Does that make sense?
4 MR. SULLIVAN: It makes sense. Let me 5 describe how the liner was put in. And, Steve, I am 6 going to need you to speak to the bonding aspects of 7 it. The liner looked like a big sock, if you will, 8 when you -
9 CHAIR YOUNG: The rubber?
10 MR. SULLIVAN: No, no. The epoxy lining.
11 I'm sorry.
12 CHAIR YOUNG: Say whichever one you're 13 talking about so I -
14 MR. SULLIVAN: Yes. I will.
15 CHAIR YOUNG: Thanks.
16 MR. SULLIVAN: The epoxy liner system 17 looks like a big sock. And that is taken, and it's 18 dipped in the epoxy solution. It's pulled through the 19 piping. And the piping lengths are 240 feet and 225 20 feet if I recall the numbers correctly. It's pulled 21 throughthe piping, that length of piping.
22 So what was the carbon steel rubber-lined 23 piping now has this sock pulled through it. It's 24 impregnated with epoxy. That sock is then filled with 25 hot water, and it's pressurized. And it's left there NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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658 1 to cure for a period of time and --
2 CHAIR YOUNG: How long?
3 MR. WOODS: A number of hours.
4 CHAIR YOUNG: A number of hours.
5 MR. SULLIVAN: I'm not sure. A number of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
7 CHAIR YOUNG: And how thick is the epoxy 8 sock that you called that?
9 MR. WOODS: Normally a half an inch.
10 CHAIR YOUNG: Okay. Go ahead.
11 MR. SULLIVAN: That is left there for the 12 -- to cure in place. And then the water is drained 13 out. And then the ends are trimmed back around the 14 ends of the rubber-lined piping.
15 So now what was a 240-foot length of pipe 16 or 225-foot length of pipe that was, you know, carbon 17 steel with a rubber liner now has this impregnated 18 sock or cured-in-place liner inside the pipe as well.
19 CHAIR YOUNG: And that's done while it's 20 underground?
21 MR. SULLIVAN: That's done while it's 22 underground. That's correct.
23 CHAIR YOUNG: And then you were going to 24 talk to the bonding, Mr. Woods?
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659 1 and filling it with water and pressurizing it, that -
2 CHAIR YOUNG: When you say "the inversion 3 process," what do you mean by -
4 MR. WOODS-: Well, as part of the -- as the 5 sock is inserted into the pipe, the -- you use water.
6 As you pump it in, it actually draws the sock down.
7 And it inverts it so that you have the wetted surface 8 going against the rubber liner.
9 CHAIR YOUNG: The wet -
10 MR. WOODS: The wetted felt with epoxy.
11 CHAIR YOUNG: And so it's -- okay. Okay.
12 MR. WOODS: So that wet epoxy is actually 13 up against, tight up against, the rubber liner. So 14 when the entire piping is filled with water to cure, 15 you assure you have got a good, tight seal between the 16 epoxy liner and the rubber liner, the existing rubber 17 liner.
13 CHAIR YOUNG: The word you were using was 19 .'wet." It was wet. So it sticks. Did I understand 20 that right?
21 MR. WOODS: Yes. The epoxy is wet. It is 22 in a liquid form when it is impregnated into the felt.
23 And then as it cures, it turns in toward a hard 24 composite.
25 CHAIR YOUNG: And sticks to the rubber, --
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660 1 MR. WOODS: Yes. I'm not sure what the --
2 CHAIR YOUNG: -- to use a layman's term?
3 MR. WOODS: Yes.
4 CHAIR YOUNG: Okay. Go ahead. Any 5 further clarification? And I appreciate your helping 6 me understand this.
7 MR. SPATARO: Yes. As a practical 8 example, let's say you took one of your socks and you 9 dipped it in honey and the sock was -- you pulled the 10 toe back towards your hand and then dipped the whole 11 thing in honey. Then you placed this inside a glass 12 and then took your hand and pushed the inside of your 13 sock, which was dry, and kept pushing it until the 14 entire sock was through to the bottom of the glass.
15 CHAIR YOUNG: Okay.
16 MR. SPATARO: That is exactly what 17 happens. And then you turned --
18 CHAIR YOUNG: That is inversion.
19 MR. SPATARO: Then you fill the -- yes, 20 that's right. That's the inversion process. Then you 21 fill it with hot water. You let it sit. And the hot 22 water cures the honey, as it were, but it also bonds 23 to the rubber, the existing rubber. And that is 24 basically the process.
25 CHAIR YOUNG: Thank you very much.
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661 1 Any follow-up from the staff or intervenor 2 on that, just those questions about the process and 3 the time period that I had asked about?
4 JUDGE COLE: Could I make a comment here 5 or a question? The original rubber liner was 6 installed at the time the plant started operation. Is 7 that correct?
8 MR. SULLIVAN: That is correct.
9 JUDGE COLE: And that was pre-1972, 10 possibly maybe two years before you started operating?
11 MR. SULLIVAN: *That is correct.
12 JUDGE COLE: So that by the time you found 13 a problem, that was 1995? And that was 23 years after 14 the liner, rubber liner, the pipe with the rubber 15 liner., was installed?
16 MR. SULLIVAN: That is correct.
17 JUDGE COLE: Are you satisfied with that 18 time life of the rubber liner?
19 JUDGE ABRAMSON: Was that consistent with 20 what you expected for the life?
21 MR. SULLIVAN: That is actually better 22 than what we expected and because it was greater than 23 the 20-year lifetime.
24 JUDGE COLE: So that in 1999, you replaced 25 2 40-foot sections. And then were they installed with NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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662 1 a rubber. liner or with some other material?
2 MR. SULLIVAN: They were installed with a 3 rubber liner.
4 JUDGE COLE: Okay. Then in 2001 and 2003 5 -- did you want to add something?
6 MR. SULLIVAN: Excuse me.
7 MR. WOODS: The 40-foot spools that were
- 8) replaced, instead of the --
9 CHAIR YOUNG: When you say, "spools," you 10 mean pipes?
11 MR. WOODS: I'm sorry. Pipe sections.
12 CHAIR YOUNG: Pipe sections. Okay.
13 MR. WOODS: They were epoxy-coated, both 14 interior and exterior.
15 JUDGE COLE: Okay.
16 MR. WOODS: A rubber liner was not reused 17 on that. An epoxy was used both the internal surface 18 and the external surface.
19 JUDGE COLE: So when you then resurfaced 20 the inside of the pipes in 2001 for one of the legs 21 and 2003 for the other leg, you covered the entire 22 inside of the pipe with this new cured-in-place epoxy 23 lining?
24 MR. WOODS: That's correct.
25 JUDGE COLE: All right, sir. Thank you.
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663 1 JUDGE ABRAMASON: Let me just well, does 2 staff or intervenor have any comment on this specific 3 series of questions about how this was done and what's 4 done?
5 DR. DAVIS: The ten-year interval seems 6 reasonable to the staff. And if they do find any 7 problems, then that is going to trigger a condition 8 report. And it's going to -- they will then increase 9 the frequency of events.
10 JUDGE ABRAMSON: And the first inspection 11 will be before the commencement of the license 12 extension period. The second one is right after. Is 13 that correct?
14 DR. DAVIS: That is correct.
15 JUDGE ABRAMSON: Assuming the license 16 extension is granted in 12?
17 DR. DAVIS: But the quality assurance 18 program is in place to ensure that if they find 19 something wrong, that they will follow up on it.
20 JUDGE ABRAMSON: Mr. Gundersen, any 21 comment on this particular --
22 MR. GUNDERSEN: Just three, I think quick.
23 First off, I am pleased that there is a commitment to 24 a visual and/or volumetric inspection from the inside.
25 My problem is the ten-year interval. And I think Judge NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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664 1 Young brought up my problem. If a problem can occur 2 over a four-year period, then a ten-year interval is 3 going to allow the problem to become significant.
4 So I advocate for more frequent 5 inspections of the type that they did. But the 6 frequency in light of the testimony seems to me to be 7 a little bit short.
8 CHAIR YOUNG: Short?
9 MR. GUNDERSEN: I'm sorry. Yeah. A 10 little bit long. And I think in my testimony I 11 suggested a more frequent testing schedule.
12 The other thing is that this 13 cured-in-place sock, honey sock, is applied to a 14 coating which under testimony here today is at the end 15 of its useful life.
16 So my -- you know, there's -- this is not 17 a -- I'm not aware of a manufacturer's guarantee that 18 this is a 35-year process. This is done in the field 19 by qualified tradesmen. And you run into field 20 problems.
21 So, again, I think that, given it's in the 22 field applied on top of a liner which is at the end of 23 its useful life, that a more frequent volumetric and 24 visual inspection would be appropriate.
25 JUDGE ABRAMSON: Let me ask you --
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665 1 MR. GUNDERSEN: There is indications in 2 that liner before the sock was pulled that there were 3 other problems. Now --
4 JUDGE COLE: You are talking about the 5 rubber liner?
6 MR. GUNDERSEN: Yes, which is now covered.
7 JUDGE ABRAMSON: Let's assume --
8 CHAIR YOUNG: Can I just get a 9 clarification. What do you mean by "volumetric 10 testing," just to clarify for me.
11 MR. GUNDERSEN: They suggested that they 12 had done ultrasonic testing, which is sending a sound 13 beam in and bouncing it back in portions of the pipe.
14 CHAIR YOUNG: So that's what you mean by 15 16 MR. GUNDERSEN: Yes, yes, yes.
17 CHAIR YOUNG: Okay. That's all.
18 MR. GUNDERSEN: And the visual, of course, 19 is --
20 CHAIR YOUNG: Right.
21 MR. GUNDERSEN: -- either with cameras or 22 eyeballs.
23 JUDGE ABRAMSON: Let's assume for a moment 24 just so we can discuss this rationally that the rubber 25 liner is just there and isn't providing any NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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666 1 protection, what we now have is a pipe with an 2 epoxy- impregnated fiber liner that is bonded to the 3 rubber, that is bonded to the pipe. So you may have 4 a gap, but you have this epoxy.
5 Do you have any experience with these 6 kinds of epoxy liners?
7 MR. GUNDERSEN: No, I do not any 8 experience with this type of epoxy liner. I would 9 disagree that the old liner is still bonded. I mean, 10 there's --
11 JUDGE ABRAMSON: Okay. But let's assume 12 it's totally ineffective. What I am interested in is 13 the applicant's proposed -- and let's remember this is 14 part of its ongoing operation and maintenance program, 15 not part of its aging management program.
16 Arnd this is the reason we are in this odd 17 circumstance here, because in order for them to get 18 the license extension, they are required to 19 demonstrate a sufficient aging management program.
20 And the aging management program has to focus -- is 21 only focused upon components or structures whose 22 failure to perform their function would make them 23 unable to handle one of these very severe accidents 24 that's set out in our regulations as the requirements.
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667 1 ongoing maintenance because that's handled by another 2 part of the agency under other regulations.
3 But the questions that you all raised 4 require at least that we understand how these two sets 5 of programs interact because you are suggesting that 6 their ongoing operations and maintenance programs 7 should have more frequent inspections in order to 8 assure that's exactly what Mr. Gundersen suggested, 9 that the inspection program be more frequent.
10 MR. GUNDERSEN: I am suggesting that as 11 part of their aging management, that they look at the 12 inside of the pipe as well as the outside of the pipe.
13 JUDGE ABRAMSON: Okay.
14 MR. GUNDERSEN: But not that it's ongoing.
15 It should be a commitment as part of the ongoing into 16 the future, commitment into the future to extend the 17 life of this plant.
18 CHAIR YOUNG: Actually, give her the 19 microphone if she is saying anything so it can be on 20 the record.
21 MS. LAMPERT: Be patient, please. Our 22 contention has been all along that the aging 23 management program itself is insufficient and has to 24 be supplemented with more frequent inspections. That 25 is what we have been talking about.
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668ý 1 We are not saying that the maintenance 2 program has to be beefed up. We are saying you have 3 to require supplements to more frequent inspections 4 and monitoring wells to detect that leaks do not grow 5 so big to interfere with the safety functions. We do 6 not assume that aging is gradual so that small leaks
.7 will go -
8 JUDGE ABRAMSON: We've heard that. Can we 9 move on?
10 MS. LAMPERT: Okay. But I was clarifying 11 because you see to be boxing us into where we were 12 not.
13 JUDGE ABRAMSON: I understand your 14 clarification.
15 Mr. Gundersen, once more, for the record, 16 do you have any experience with epoxy coatings of this 17 nature?
18 MR. GUNDERSEN: No, I do not.
19 JUDGE ABRAMSON: Thank you.
20 Back to the staff for a moment. Is this 21 sort of epoxy coating in common use in the industry?
22 We'll get there. We'll get there.
23 DR. DAVIS: There are a number of 24 different kinds used in service water. This 25 particular one I'm not aware if it's used anywhere NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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669-1 else, but it's almost like creating a ship hull inside 2 of the --
3 CHAIR YOUNG: Could you speak up a little 4- bit and also say creating a what?
5 DR. DAVIS: Of the hull of a boat, a ship.
6 It's a very similar process.
7 CHAIR YOUNG: Ship hull? Okay.
8 DR. DAVIS: Yes, a hull. So it's a much 9 better coating than the rubber lining. The rubber 10 lining will oxidize with time and will degrade.
11 JUDGE-ABRAMSON: And the epoxy?
12 DR. DAVIS: The epoxies are much more 13 resistant.
14 JUDGE ABRAMSON: So when the applicant 15 says that the useful life of this epoxy coating is 16 something like 35 years, is that consistent with your 17 understanding of these?
18 DR. DAVIS: Yes. And a frequency of ten 19 years of inspection seems very reasonable. But I 20 would like to add that a volumetric examination of 21 this system is not currently possible.
22 JUDGE ABRAMSON: Because?
23 DR.-DAVIS: Because you're going through 24 -- try to go through three layers with a UT probe.
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670 1 interface between the different layers. And it's 2 going to be just -- at this point a UT technique has 3 not been developed that would be -
4 CHAIR YOUNG: Ultrasonic testing 5 technique?
6 DR. DAVIS: Ultrasonic test technique.
7 JUDGE ABRAMSON: So, if I understand you 8 correctly, ultrasonic testing would not yield any 9 useful information. So what would the staff think is 10 appropriate: Visual inspection of the liner?
11 DR. DAVIS: Yes, visual inspection.
12 JUDGE ABRAMSON: Let's come back to what 13 is really underlying all of this. This is not 14 relevant for small leaks. This is only relevant for 15 degradation of this pipe that carries service water 16 back to the ocean so great that it is in danger of 17 structural failure if a design basis earthquake 18 happens and, thus, the one at least that Mr. Gundersen 19 is proposing.
20 The holes that you found and the 40-foot 21 section that you replaced, which were the worst 22 degraded portions of the pipe in the middle 1990s, 23 were any of those portions of those pipes degraded to 24 the point where a structural analysis would indicate 25 it could not withstand a design basis earthquake or NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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671 1 was that analysis done or not done?
2'MR. WOODS: I don't believe that an 3 analysis was done on the failed -- on the through-hole
- 4. leak on that pipe. In, my. opinion., no, I don't see 5 where that could lead to a catastrophic failure of the 6 entire piping section.
7 JUDGE ABRA.MSON: *This was a hole about the 8 -diameter of a quarter, two holes adjacent to each 9 other, which might in the. total add up 'to three or 10 four quarters worth judging from the picture, in a 11 pipe whose inside. diameter is 21 inches, 21-plus 12 inches.
13 So we've got something this big around 14 with a hole like that on it. And we're talking about 15 compressive failure that would cause that to collapse 16 and choke the flow off.
17 What is the staff's view of this? Was 18 this level of degradation, could this level of 19 degradation have endangered the ability of the pipe to 20 meet the current licensing basis vis-a-vis design 21 basis events?
22 MR. CHAN:, In my judgment, that could not 23 happen. That would not happen, -
24 JUDGE ABRAMSON: So this -
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672 1 single failure and failure of the other train as well.
21 That is extremely, extremely unlikely.
3 JUDGE ABRAMSON: And when you replaced the 4 2 40-foot sections, was there any through-hole damage 5 to the other -- this was in one loop. What about the 6 other loop?
7 MR. WOODS: There was no through-wall 8 degradation in the other loop.
9 JUDGE ABRAMSON: Was there degradation at 10 all?
11 MR. WOODS: There was some degradation 12 from min. wall. So i~t was easy just to replace that 13 section of pipe.
14 CHAIR YOUNG: Minimal walls. There was 15 some degradation from minimum?.
16 MR. WOODS: From minimum wall. That's 17 correct.
18 CHAIR YOUNG: Explain what you mean by 19 saying that.
20 MR. WOODS: Wall thinning.
21 CHAIR YOUNG: Wall thinning of the actual 22 metal?
23 MR. WOODS: Of the metal because the 24 rubber liner was torn away.
25 JUDGE COLE: This sock liner is placed in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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673 1 the entire length of the pipe on each of the two 2 loops, correct?
3 MR. WOODS: Yes.
4 JUDGE COLE: And you say it is bound to 5 the pipe. What is the probability of that coming 6 loose at one end and then just blocking up -the whole 7 pipe with the sock?
8 MR. SPATARO: The way in which the epoxy 9 liner is applied dictates that, first of all, you 10 examine the remaining rubber lining for integrity.
11 Now, it doesn't mean that the liner is failing or has 12 failed completely. It simply means that the liner has 13 degraded but is still useful. Otherwise the liner 14 should be taken out. That surface is then prepared by 15 scraping --
16 CHAIR YOUNG: Could I interrupt?
17 MR. SPATARO: Yes.
18 CHAIR YOUNG: You say the rubber liner is 19 examined before you put the epoxy coating in or the --
20 MR. SPATARO: That's correct.
21 CHAIR YOUNG: How is that examination 22 done?
23 MR. SPATARO: Okay. There are two ways to 24 do that. One is to do a visual examination of the 25 surface because any aging effect that is going to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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674 i- happen to the. rubber lining is going to be evidenced 2 on the surface and work its way down.
3 CHAIR YOUNG: And how is the, visual 4 examination done?
5 MR. SPATARO: Well, a number-of ways. I 6 was not involved in the actual inspection. Brian, do 7 we know how they inspected the liner?
8 MR. WOODS: I believe the inspection was 9 done -- a crawler was sent down with a video camera.
10 And also portions of it, an actual person went into 11 the pipe.
12 MR. SULLIVAN: A slim fellow.
13 MR. WOODS: Yes.
14 CHAIR YOUNG: A crawler is a machine or a 15 slim fellow?
16 (Laughter.)
17 MR. WOODS: Both.
18 MR. SPATARO: When the integrity of the 19 rubber liner is assured, the surface is then prepared 20 by either scraping or what we call scarfing, where you 21 remove any debris or form formations of any kind of 22 marine growth or anything that might be on the surface 23 of the pipe. You take that all off.
24 CHAIR YOUNG: Let me back up again. I'm 25 sorry, but I do want to understand. One of the things NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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- " 675 1 that was raised was the possibility of the rubber 2 coming away from the metal. When the visual 3 inspection is done, how would you determine whether 4 the connection between the rubber liner and the metal 5 pipe was still that it still adhered?
6 CHAIR YOUNG:
7 MR. SPATARO: Okay. the way that you 8 determine that is you look at the contour of the 9 surface itself. If delamination had occurred, the 10 rubber lining would have started to belly into the 11 pipe, and it would be readily seen.
12 Another way to do that, too, is as you are 13 crawling down the pipe, you just simply press some 14 sort of -- any kind of instrument you want -- it could 15 be simply a pencil if you wish -- against the liner 16 itself. There should be some little bit of give. If 17 that liner has pulled away, you're really going to be 18 able to move it. So that gives you an indication of 19 any delamination that might be occurring.
20 Once that has been verified that the liner 21 is still intact --
22 CHAIR YOUNG: And you scrape off the --
23 MR. SPATARO: Yep. You scrape off 24 everything there. Now, the object of scarfing that 25 surface is to provide, number one, a roughened surface NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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676 1 for the epoxy to bond to. So it's a mechanical bond.
2 CHAIR YOUNG: So you do it for the whole
.3 4 . MR. SPATARO: The whole thing, absolutely, 5 frofn start to finish. Then the sock is inverted, 6 placed through the piping. And the action of curing 7 is-such that there is a mechanical bond, a very,- very 8 tight mechanical bond between the liquid epoxy. to the 9 scarfed and abraded rubber. So that there is a strong 10 mechanical bond.
11 Now, bear in mind that all of this is 12 occurring in an outward pressure pattern so that when 13 it does cure, it is literally a pipe within a pipe.ý 14 And it is not going anywhere.
15 There is no way that it could suddenly 16 break off and a whole piece walk down the pipe because 17 the pipe is -- the two pieces are actually so tightly 18 bonded that they are not going to move. They are not 19 going to move in a lateral motion.
20 JUDGE ABRAMSON: Let me ask you a question 21 or two about the structure of this epoxy-impregnated 22 sock. Is this akin to the shell of a Corvette, where 23 there are fibers that are bonded together by epoxy?
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677' 1 concrete. And the epoxy, therefore, in combination 2 with this fibrous mat forms a relatively rigid shell.
3 Is that correct?
4 MR. SPATARO: You have got it. Generally, 5 though, with rebar and with the Corvette shell, you 6 are dealing 'with either fibers or a rod that is 7 surrounded by the epoxy resin. In this case, we have 8 a mat that is the entire length, the entire 9 circumference of the pipe. That is impregnated.
10 So you get both the value of the strength 11 of the fibers and the fact that it is literally a 12 complete system of fibers interwoven into this mat 13 that run the whole length of the pipe.
14 JUDGE ABRAMSON: So this becomes like a 15 relatively rigid fiberglass shell, if you will, except 16 that it's not fiberglass. It's a felt shell, 17 impregnated felt shell.
18 MR. SPATARO: Exactly, yes.
19 JUDGE ABRAMSON: So the scenario that Dr.
20 Cole was asking about, where a piece of this could 21 come loose and plug the entire pipe, would be a rather 22 remarkable event. Is that --
23 MR. COX: I think that is right. I will 24 let Bill answer that, but I did want to make one 25 clarification. The cured-in-place pipe, we have been NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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678 1 calling it cured-in-place pipe lining. The literature 2 actually refers to that as a cured-in-place pipe.
3 And it's actually analyzed to be able to 4 stand the pressure loads and the loads from outside 5 the hydraulic pressures of the water above it as if 6 there was no outside pipe. It's actually a pipe 7 within a pipe. It is rigid.
8 CHAIR YOUNG: So you are saying it is 9 analyzed separately from the metal pipe. It's 10 analyzed as a separate pipe that would need to 11 withstand pressures. What sort of pressures are you 12 talking about?
13 MR. COX: It is analyzed for the head of 14 water above it and the -- because the pipe runs 15 downhill, it actually draws a vacuum in parts of it.
16 So it's analyzed to a negative 11 pounds per square 17 inch from the outside, and it's analyzed to -- I can't 18 remember the -- whatever the design pressure is from 19 the inside.
20 But it is -- I mean, it's not -- we credit 21 both the metal and the pipe, but it does -- the pipe 22 does have its own separate analysis. The 23 cured-in-place pipe has a separate analysis. It says 24 it can withstand the normal pressure loads acting 25 within and from the outside.
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679 1 CHAIR YOUNG: Since you have raised this, 2 let me just clarify another thing that I was wondering 3 about that has been raised. And that is the timing 4 again, going back to that.
5 It's been said -- well, the issue of 6 experience with epoxy coatings was raised, and then 7 also the timing was raised. I want to ask about those 8 two things since you have sort of brought up what kind 9 of expectations you. have about the epoxy lining.
10 First of all, what experience do Entergy's 11 experts and the staff's experts have with this? And 12 what experience is out there, operating experience, 13 with this kind of epoxy coating? And in that context, 14 what knowledge is there about the progression of any 15 degradation once it occurs, how fast that could occur, 16 and also this bathtub curve phenomenon that has been 17 described?
18 So that is about four questions. Do I 19 need to go back with them separately?
20 MR. SPATARO: I will take it from the 21 metallurgical portion, and I will hand it back to Alan 22 for the rest. The epoxy materials that we are talking 23 about and this process have been on the market at 24 least 20 years, at least that long.
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680 1 used. And where it really has its benefit is if you 2 have a degraded piping system. In this instance, it 3 happened to be a firewater system that had degraded 4 and was very, very expensive to dig up. There was 5 concrete and buildings over it and parking lots, that 6 kind of thing.
7 What they did was send a pig through 8 there, which is just a machine that runs through the 9 pipe. And they literally machined out all the debris, 10 all the corrosion product and then examined the wall 11 thickness of the piping.
12 And this is firewater. So the wall 13 thickness and the pressures were not as great as what 14 we are talking about in the plant.
15 CHAIR YOUNG: So let me understand. You 16 are talking about a pipe that has this coating?
17 MR. SPATARO: No. This is just a pipe 18 that was buried in the ground as an example from my 19 experience.
20 CHAIR YOUNG: Without the coating. Okay.
21 MR. SPATARO: This liner was then run 22 through that pipe in order to make a pipe within a 23 pipe such that that pipe did not have to be dug up and 24 replaced. And this was approved by the national fire 25 protection code.
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681 1 CHAIR YOUNG: So the metal pipe had 2 degradation --
3 MR. SPATARO: Exactly.
4 CHAIR YOUNG: -- the extent of holes or --
5 MR. SPATARO: Possibly, yes. Yes.
6 CHAIR YOUNG: And then the epoxy liner was 7 put in.
8 MR. SPATARO: Uh-huh.
9 CHAIR YOUNG: Go ahead.
10 MR. SPATARO: And met the code 11 requirements, the piping code requirements, for fire 12 protection, which essentially were that you should be 13 able to deliver the firewater from the tank to 14 wherever the sprinkler system is in whatever that 15 volume is that is required of you. And the liner 16 performed that function very well.
17 CHAIR YOUNG: And was there a time line on 18 that fire protection requirement that addressed how 19 long you would be able to rely on it?
20 MR. SPATARO: Not to my knowledge, no.
21 This was, as I say, some 20 years ago. However, 22 addressing the material itself, the experience with 23 the material shows that a life of at least 35 years is 24 expected of this.
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682 1 interval that Entergy has chosen to perform here --
2 CHAIR YOUNG: And also the progression of 3 how fast.
4 MR. SPATARO: Uh-huh. The failure 5 mechanism of any of these types of epoxies is by 6 flaking. In other words, the surface itself dries out 7 over time. And that usually occurs more readily in a 8 volumetric airflow system or exposure to ultraviolet 9 radiation, neither of which exist.
10 CHAIR YOUNG: Volumetric airflow system.
11 What do you mean by 12 MR. SPATARO: Volume of air flowing across 13 the surface so as to dry it out.
14 CHAIR YOUNG: Okay.
15 MR. SPATARO: Like blowing across your 16 hand, that type of thing.
17 CHAIR YOUNG: Okay.
18 MR. SPATARO: Neither one of those 19 situations exists here. So the general degradation 20 environment that cause epoxies to fail over time don't 21 exist.
22 CHAIR YOUNG: So you're saying the flaking 23 is caused by the drying out?
24 MR. SPATARO: Yes, which will occur either 25 by an airflow -- and hot air, of course, is more NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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&683 1 damaging than cold air -- and by ultraviolet exposure.
2 CHAIR YOUNG: Is there experience with.
3 what would cause degradation in a wet environment?
4- MR. SPATARO: Almost *no degradation at 5 all.
6 CHAIR YOUNG: My question-is 7 MR. SPATARO: But if it was to degrade at 8 all, it would degrade by flaking-.
9 CHAIR YOUNG: What is the experience of 10 how degradation would occur in a wet environment?
11 MR. SPATARO: There is very little 12 degradation that has been reported in a wet 13 environment, in a flowing water-type environment.
14 CHAIR YOUNG: And how widely is it used so 15 that -- I guess what I am trying to get at is, you are 16 saying there is little experience of degradation.
17 MR. SPATARO: Exactly.
18 CHAIR YOUNG: What is the context? How 19 much experience is there of using it over what periods 20 of time without the degradation?
21 MR. SPATARO: Well, the epoxy resins that 22 are used here have been in existence for -- oh, my God 23 -- 50 years.
24 CHAIR YOUNG: And you said 20 years --
25 MR. SPATARO: Twenty years that I -- my NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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684 1 experience in this type of. application using the 2 fiberglass or the felt sock approach to that, to 3 lining a pipe.
4 CHAIR YOUNG: And a lot of power plants 5 used --
6 MR.- SPATARO: I've seen it in power 7 plants, nuclear, hydro, and fossil. I have seen it in 8 waste water treatment facilities. Any place where 9 there is an aggressive environment, either you're 10 using city water or river water, lake water, 11 estuaries, the Bay, for instance, ocean water, any of 12 those types of things, this really, really holds up 13 well. And that is why it is used.
14 CHAIR YOUNG: And when it does occur, even 15 when it is wet, it would occur by some kind of 16 flaking?
17 MR. SPATARO: Flaking, yes. In other 18 words, the surface of the epoxy dries out. Now you 19 say, how can that happen in a wet environment?
20 Normally it doesn't. Okay? But generally you lose a 21 certain amount of the material, and it flakes off.
22 CHAIR YOUNG: Do you know of any 23 situations where it has degraded enough where there 24 could be a hole through to the metal and then --
25 MR. SPATARO: No.
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685 1 CHAIR YOUNG: You don't know of any?
2 MR. SPATARO: No because in order for that 3 to happen, you would have to degrade by layers the 4 resin itself. Then you get to the mat. And you, have, 5 to somehow get through that mat. And that's 6 impregnated with the epoxy also. So the only way that 7 is going to happen again is by drying out.
8 The flow that is running through these 9 pipes should not have much of an effect on an epoxy 10 liner, which is a very dense, very smooth surfaced 11 material. So that there are very, very little 12 friction effects that would cause particles of the 13 thing to be scarfed off over time so that it would 14 wear out with the flow itself.
15 CHAIR YOUNG: Okay. Now, my memory may 16 not be right on this,, but I think the one other thing 17 that I was wondering about was, once there was 18 degradation, what information and experience is there 19 about how fast that would then progress, either as a 20 function of having been started and then continuing to 21 degrade or as a function of age and being later on 22 down the line of its life, so to speak?
23 MR. SPATARO: Well, as this material would 24 degrade -- assume it's degrading. As it degrades, you 25 have this flaking that occurs. You then see a change NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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686 1 in the surf ace contour not being shiny anymore but 2 being undulated, having certain areas that are 3 slightly depressed that are no longer shiny.
4 The expectation is that this will probably 5 not occur for at least 35 years. But going in in ten 6 years will give you an idea of how it is holding up.
7 If there -- by any chance there were 8 degradation in between those ten-year inspections, 9 what would generally happen is that the epoxy would 10 flake off. But then the surface below it is fully 11 cured resin. That resin would have to go through the 12 same degradation mechanism.
13 So that in order for the failure to occur 14 from the time you notice it or don't notice it after 15 your last inspection, you have got to lose a certain 16 layer of the material. And this is not going to occur 17 over long, long lengths of it. It is going to occur 18 in certain small areas.
19 That has to go first. Then you have got 20 to dry out and degrade the next layer of material.
21 And this is we're talking mls here, thousandths of an 22 inch of degraded material coming off.
23 CHAIR YOUNG: And it is a half-inch thick.
24 MR. SPATARO: And then you've still got to 25 go all the way down. Then you've got to get through NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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687 1 the mat. That is not going to occur. That is going 2 to be something that is going to take an awfully long 3 time. And when I say, "awfully long, many years, 4: many, many years, only because. of the way the material 5 is. It's a felt-type fibered material that is 6 impregnated with the epoxy. It's basically the 7 CHAIR YOUNG: What is the material that 8 the felt is made of?
9 MR. SPATARO: We would have to get back to 10 you on that. My assumption is some sort of a 11 fiberglass because it has to be such a material that 12 would. be able to absorb the epoxy resin in its liquid 13 form and hold it and then on curing be actually part 14 of the system itself.
15 CHAIR YOUNG: So, if I understand you 16 correctly, you are saying that the flaking would come 17 off, but then there would be the remaining epoxy 18 itself. And then you would get down to the felt, 19 which would have a greater durability than the epoxy 20 itself.
21 MR. SPATARO: Precisely.
22 CHAIR YOUNG: And the total thickness of 23 it is. about a half an inch. And when the flaking 24 comes off and you see the undulation that you are 25 talking about, do you know what thickness that would NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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688 1 involve?
2 MR. SPATARO: Sure, only a few 3 thousandths.
4 CHAIR YOUNG: Okay. And then once 5 something progressed, what experience or knowledge do 6 you have on how fast -- I mean, once something has 7 degraded how fast the degradation would progress and 8 how much difference there would be in that earlier or 9 middle aged, as opposed to near the end of its life?
10 MR. SPATARO: Sure. A lot of that, all of 11 it, actually, depends on the environment, what is-12 actually causing the degradation. In this instance, 13 there is nothing that I can think of that would cause 14 the degradation.
15 We're speaking hypothetically, should the 16 degradation occur. One has to look at why the resin 17 is degrading. There's nothing that I know of in a 18 water environment that would cause the epoxy to 19 degrade.
20 Given that we're going to make that 21 hypothetical a judgment, -- okay? -- let's say I lose 22 ten mls in three, four years. Then I would have to 23 lose at least 30 mls in 9 years to get down to --
24 CHAIR YOUNG: Mls, millimeters?
25 MR. SPATARO: Yes. No, not millimeters.
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689 1 Thousandths of an inch.
2 CHAIR YOUN~G: Okay.
3 MR. SPATARO: So nine thousandths of an 4 inch would have to be lost by the next ten-year. -- and 5 the next ten-year inspection, of course, would show 6 that. We would go in and repair it. So we would be 7 back to square one.
8 Given that that happened and we still had 9 some time to go, you still have the mat in place, 10 which given a rough estimate on my experience would.
11 take -- oh, good God -- at least ten years, if not 12 more, to degrade simply because of what it is, the 13 material that it's made of.
14 There is nothing there that really is 15 going to degrade the felt itself or the fiberglass.
16 We're talking only about the resin itself degrading so 17 that when you got to the felt, you're literally 18 saying, 'Well, I'm expecting the resin *that's 19 impregnated in the felt to degrade." That's perhaps 20 not the same degradation mechanism as the thickness of 21 the resin that was above that felt or that, you know, 22 actually encapsulates that.
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690 1 felt would really go.
2 CHAIR YOUNG: Thank you very much. I 3 appreciate your clarification.
4 MR. SPATARO: You're welcome.
5 CHAIR YOUNG: Let me just ask one last 6 question on this line. And maybe it should go to the 7 NRC, although if Entergy experts know the answer, that 8 would be fine. And that is, is there any experience, 9 is there any knowledge in the field of any degradation 10 or events or anything that has actually caused any 11 degradation or break or holes in this epoxy liner?
12 DR. DAVIS: I don't have any experience 13 with this type of coating in the field. I know there 14 have been other linings that have failed, but it was 15 usually for mechanical reasons.
16 CHAIR YOUNG: Being something in it that 17 hit it or something, the pipe was broken from the 18 outside or -
19 DR. DAVIS: The liner was inserted into a 20 service water line. And it was actually too long. And 21 when they folded the flanges up, the bro~ke the-lining.
22 It was just a measurement error.
23 CHAIR YOUNG: So anyone else know of any 24 experience on that from other plants? There are these 25 reports that come out letting plants know about NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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691 1 experience that may have occurred at one plant, for 2 example.
3 MR. COX: As part of doing the license 4 renewal application,- we looked at the industry 5 experience in a lot of areas of aging degradation.
6 And I don't recall finding anything that related to a 7 failure of this type of lining.
8 I believe we have this type of lining in 9 some of our other plants within the system. I am from 10 Arkansas nuclear 1. I believe we used that in the 11 service water system. I've not heard of any failures 12 or any significant degradation of this type of 13 cured-in-place lining.
14 CHAIR YOUNG: What plant did you say?
15 MR. COX: Arkansas nuclear 1.
16 CHAIR YOUNG: Okay. Thank you. Thank you 17 very much.
18 MR. SULLIVAN: Let me just add that the 19 INPO, the Institute of Nuclear Power Operations, does 20 conduct --
21 CHAIR YOUNG: Right.
22 MR. SULLIVAN: -- an operating experience 23 program.
24 CHAIR YOUNG: Right.
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692 1 operating experience in a nuclear power plant with 2 this type of material failing, we would be notified of 3 it. We would enter it into our corrective action 4 process and take corrective actions.
5 CHAIR YOUNG: And the industry has used 6 this type of liner for the 20 -- how long has the 7 industry used it?
8 MR. SPATARO: My experience was with 9 Indian Point 3. So I can go back at least 20 years on 10 a nuclear plant and say yes, we have used it.
11 CHAIR YOUNG: Okay.
12 MR. SPATARO: And, by the way, no reported 13 failure of that particular application to this date.
14 CHAIR YOUNG: Okay. Any follow-up on 15 that?
16 JUDGE ABRAMSON: I want to come back on 17 the other one. And I want to talk to Mr. Gundersen a 18 little bit, too.
19 CHAIR YOUNG: We'll get back to you on 20 this one.
21 JUDGE ABRAMSON: So let me come back.
22 This is all very interesting information about how the 23 liner is put in and how it might fail, but the issue 24 in front of us is what can cause this pipe to fail to 25 meet its intended safety function when it's redundant.
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693 1 MS. LAMPERT: Excuse me, Judge. I 2 understood that both sides could respond. So there 3 were questions asked to Entergy and NRC. And it seems 4 like the democratic debates, that we haven't had a 5 chance --
6 CHAIR YOUNG: I'll make sure you get the 7 opportunity.
8 MS. LAMPERT: -- to respond --
9 CHAIR YOUNG: I'll make --
10 MS. LAMPERT: - to those specific 11 questions that he asked.
12 JUDGE ABRAMSON: We will ask your expert 13 if you'll just let me follow up, please.
14 CHAIR YOUNG: We will get to you.
15 JUDGE ABRAMSON: Mr. Gundersen, we have 16 heard from the applicant that this size hole in their 17 opinion, they cannot think of a way that the size of 18 hole that they found in a 40-foot pipe they took out 19 could have led to catastrophic failure.
20 In your testimony, you said that these 21 holes can act as stress risers and increase the 22 likelihood of gross failure under the stress of 23 accident conditions. How much stress would be added 24 to this 20-inch internal diameter, three-eighth-inch 25 thick steel pipe by the kinds of holes that we have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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694 1 seen in these pictures, a couple of quarter-size 2 holes?
3 MR. GUNDERSEN: I don't think that picture
- 4. is the greatest picture in the world. It indicates 5 between the holes wall thinning as well.
6 JUDGE ABRAMSON: Okay.
7 MR. GUNDERSEN: So, I mean, you are 8 talking about something --
9 JUDGE ABRAMSON:, So let's say it was a 10 four-inch-diameter hole. How much would that increase 11 the local stressors or what would that do to the 12 probability of this pipe being unable to withstand a 13 design basis earthquake, which is the worst case 14 scenario you are painting, I think? Is that correct?
15 MR. GUNDERSEN: I believe a defect of that 16 size in that pipe, if there were a design basis event 17 could cause a pipe to collapse.
18 JUDGE ABRAMSON: And what analysis have 19 you done to support that belief or what analysis have 20 you seen to support that belief?
21 MR. GUNDERSEN: I think when the crack was 22 detected, the burden was on the licensee to actually 23 analyze that. And they didn't.
24 JUDGE ABRAMSON: That's not my question.
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-695 1 I have not run a supercomputer model, and I don't --
2 JUDGE ABRAMSON: Have you ever seen any 3 analysis of this? I'm sorry. Let me pursue the 4 question..
5 CHAIR YOUNG: Let him finish his answers.
6 I'm not hearing all of his answers.
7 JUDGE ABRAMSON: You have not run a 8 supercomputer model. I understand that. Have you 9 done any analysis at all of this kind of failure on 10 this kind of pipe to help you make a determination of 11 whether it would or would not cause that pipe to not 12 be able to withstand a design basis earthquake?
13 MR. GUNDERSEN: My experience in other 14 seismic analysis of pipe would indicate that a hole 15 that size in the wall of a pipe that thin would cause 16 it to fail in a design basis event.
17 JUDGE ABRAMSON: Have you done analysis to 18 that effect or have you seen analysis?
19 MR. GUNDERSEN: I already said I have not 20 done an analysis on that pipe.
21 JUDGE ABRAMSON: You have not done 22 analysis. You are saying your experience with other 23 pipes with similar holes. Tell me about what that 24 experience is. I would like to know.
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696 1 seismic analysis of pipes, not with a hole that big 2 because nobody postulates a hole that bi,_ would 3 indicate that should there be a flaw of that size in 4- that-pipe, it would fail in a seismic event.
5 JUDGE ABRAMSON: And is that because of 6 analysis you have done or people who have worked for 7 you have done?
8 MR. GUNDERSEN: Yes.
9 JUDGE ABRAMSON: What is the basis of your 10 11 MR. GUNDERSEN: It's based on analysis the 12 people who have worked for me have done.
13 CHAIR YOUNG: Do you have something to 14 follow up? I wanted to give him a chance to follow 15 up.
16 JUDGE ABRAMSON: Go ahead. Go ahead.
17 CHAIR YOUNG: What is your comment on the 18 testimony that the applicant and the staff to some 19 degree gave about the experience with the epoxy liner?
20 MR. GUNDERSEN: Well, first off, most of 21 the testimony was based apparently on experience of 22 Indian Point 3. That is not a saltwater plant. That 23 is brackish water and is nowhere near the conditions 24 we are seeing here.
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697 1 definitively that we had a total through-wall failure 2 in one system and a failure below min. wall in the 3 other simultaneously. That is already on the record 4- for the Pilgrim plant as having occurred. So we have 5 got --
6 CHAIR YOUNG: You are talking about this 7 one?
8 MR. GUNDERSEN: When they were -- when 9 that leak was developing separately in the other leg, 10 the testimony indicated this morning that there was a 11 through-wall -- not a through-wall crack but a crack 12 in the wall below min. wall in the other train. So we 13 have on the record a situation where both the trains 14 were degraded: one leaking and the other with a 15 below-min. wall indication.
16 JUDGE COLE: Degradation of the liner?
17 MR. GUNDERSEN: No. They were -- no. The 18 degradation was of the pipe.
19 JUDGE COLE: They measured both the pipe 20 and the liner at the same time. And that is what they 21 compared, wasn't it?
22 MR. GUNDERSEN: They took out the liner, 23 and they did an ultrasonic exam on the pipe. And they 24 did a weld overlay to bring the pipe back up to true 25 thickness.
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698 1 JUDGE COLE: All right.
2 JUDGE ABRAMSON: That was out at the end 3 of the pipe, as opposed to the 40-foot section they 4 took out, I think. Is that --
5 MR. GUNDERSEN: Right. But it was in the 6 other train is my point.
7 JUDGE ABRAMSON: Yes.
8 MR. GUNDERSEN: We've got a situation 9 where both trains were in a degraded condition, which 10 I think about an hour ago was one of the issues. You 11 know, can you postulate a situation? And it's already 12 occurred here at Pilgrim, where both trains were in a 13 degraded condition.
14 We also have on the record that a flaw can 15 progress from barely seeable to through-wall in under 16 four years. I actually think there was an indication 17 there might even have been -- there was an inspection 18 in '95, where there was a little failure in the liner 19 and then in '97 and then in '99. It might even be 20 those holes developed in two years. So very quickly 21 22 CHAIR YOUNG: Let me just interrupt. It 23 would be helpful to me again. I am not the technical 24 person.
25 MR. GUNDERSEN: Yes.
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699 1 CHAIR YOUNG: So when you are talking 2 about degradation or events, at this point for me it 3 would be helpful if you would describe whether it took 4 place before the epoxy lining was put in there or 5 after and then what effect the epoxy lining would 6 have.
7 MR. GUNDERSEN: Right. The experience 8 with the epoxy liner is less than -- is several years 9 old. And the testimony is about Indian Point 3, which 10 is not a saltwater plant, but the --
11 CHAIR YOUNG: Is there anything --
12 MR. GUNDERSEN: -- experience with the 13 failures was on the rubber-lined system.
14 CHAIR YOUNG: Okay. You just reminded me 15 of another question. I will just ask it now to try to 16 clarify everything as we go. Is there any experience 17 or knowledge of the extent to which saltwater, 18 brackish water, the chemistry of that on degradation 19 of epoxy? I mean, is there any general knowledge on 20 that? I don't --
21 MR. GUNDERSEN: Yes. That gets to -- I 22 was actually going to say that next.
23 CHAIR YOUNG: Okay. Good.
24 MR. GUNDERSEN: You know, in the nuclear 25 industry, we have equipment qualification. If it's an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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700 1 electrical component, you have got to show that it is 2 going to withstand 40 years of radiation inside the 3 containment, including a large exposure after an 4 accident or something like that.
5 We have an EQ program, equipment 6 qualification. I have -- well, I heard an infomercial 7 this morning on how wonderful the pipe is. I haven't 8 seen a quality assurance document that says that this 9 is a 35-year product. It's not on the record, Your 10 Honor.
11 We have got testimony based on a brackish 12 water plant. And this is saltwater. That is a 13 wonderful product. And, yet, in the nuclear industry 14 on safety-related pipe, there is a procedure where one 15 qualifies this stuff for the -- I've heard 35 years.
16 I haven't seen either manufacturer's 17 qualifications or the Pilgrim qualifications on a pipe 18 that -- on an old pipe that had an old liner that then 19 on that liner had applied this epoxy coating to give 20 me any bases to say it had a 35-year life.
21 This is testable. You can do this in a 22 lab. You can pull it out. You can check it and then 23 say, "Okay. It's got a 35-year life." But that's not 24 on the record. I mean, we have heard individuals 25 speak about experience at Indian Point but not in this NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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701 1 environment. And it is a testable thing. To my 2 knowledge, that document's not on the record. So 3 we're hanging our hat on an infomercial.
4 CHAIR YOUNG: Okay. Let me just ask a 5 couple of questions and --
6 MR. LEWIS: Judge Young, could I -- this 7 is a funny process because -
8 CHAIR YOUNG: It is. It is unusual, but 9
10 MR. LEWIS: But I actually never heard the 11 answer to the question, which I believe you asked, 12 which is, did he have any data indicating that 13 saltwater has an effect on epoxy?
14 if it was a procedure where we were being 15 cross-examined, I would move to strike it all as being 16 non-responsive. And I guess I still would like to 17 know if he is aware of any data that shows saltwater 18 degraded epoxy.
19 MS. LAMPERT: Well, could I just say in 20 response because he had his response --
21 CHAIR YOUNG: Go ahead.
22 MS. LAMPERT: -- that we were considerate 23 of the regulations or, you know, the order. And we 24 did not respond as they were responding, which would 25 have been very appropriate.
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702 1 CHAIR YOUNG: I'm sorry. I didn't 2 understand what you just said.
3 MS. LAMPERT: No, I'm not being picky.
4 What I. was saying is I assumed that we were not 5 supposed to question until the end and make that 6 comment.
7 CHAIR YOUNG: It's a different process --
8 MR. GUNDERSEN: There is no document on 9 the record.
10 CHAIR YOUNG: -- in any event. But let's 11 stop because I wanted to ask you a question. And it 12 sort of takes into account what Mr. Lewis was raising.
13 What I understood your answer to be was that there's 14 no information on the extent to which saltwater, 15 brackish water would degrade this kind of epoxy liner 16 because there hasn't been what you termed an equipment 17 qualification for this particular use of this 18 material.
19 And I also think I understood you to say 20 that the normal course of action for any new type of 21 equipment or if you called a lining equipment, that 22 that is a -- you were suggesting that that is a 23 general requirement or industry standard of practice 24 or is that basically what you're saying? And where 25 does that requirement or standard of practice come NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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703 1 from?
2 MR. GUNDERSEN: I've heard this morning 3 that this liner is qualified for 35 years. I have 4 seen no documentation to indicate that. I have heard 5 people talk about experiences in firewater systems and
- 6. things like that.
7 CHAIR YOUNG: Okay. Let me interrupt you 8 again.
9 MR. GUNDERSEN: So I --
10 CHAIR YOUNG: I am going to interrupt you 11 again. Okay? Because my question is where the 12 requirement for equipment qualification comes from.
13 And that is a purely informational -- I am seeking 14 information by that question.
15 What I heard the energies expert say was 16 -- I don't think they ever used the word 17 "qualification." I think what they said was that 18 there is 20-some years experience in the industry 19 using it and that there's more experience than that 20 using it in other contexts. I don't think I heard them 21 use the word "qualification."
22 So for purposes of explaining to you how 23 we operate, everything that is said here today is on 24 the record for purposes of the evidence before us.
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704 1 make it any less worthy as evidence for us to 2 consider. What we look at is how much it holds 3 together, how relevant it is, how much weight we 4 should give. it. So that is sort of a basis from which 5 to talk.
6 Now, as to your answer about qualification 7 of equipment, to use an analogy, we hear about drug 8 testing. There are requirements that drugs before 9 they go on the market have certain testing that has to 10 be done.
11 Are you talking about a formal process 12 that is required either by NRC requirements and 13 regulations or NUREGs or is there some. standard 14 industry practice or is it an INPO, I-N-P-O, standard?
15 I'm trying to understand what you are 16 talking about when you talk about equipment 17 qualification, not to challenge you, just to try to 18 understand what you are talking about.
19 MR. GUNDERSEN: Yes. I'm drawing a blank 20 on the -- within 10 CFR where it is. There are 21 industry experience bases that are used in different 22 inspections. For instance, every weld in a nuclear 23 reactor is inspected every ten years. For instance, 24 the recirculation pump seals are known to fail every 25 maybe five or six years or whatever. And they are on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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705 1 a program of periodic replacement based on an industry 2 standard.
3 Obviously if a short-lived component gets
- 4. either inspected or replaced frequently, a long-lived 5 one can have a longer inspection period. And I am 6 aware of nothing that shows that this 35-year life in 7 a plant in this environment with a coating applied 8 over top of a rubber liner that is already at the end 9 of its life, that -- the expectancy that that liner 10 would last 35 years.
11 So my suggestion is that -- not that the 12 liner is poor but that it should be inspected more 13 frequently than ten years.
14 CHAIR YOUNG: Okay.
15 MR. GUNDERSEN: I had a couple of other 16 things, but --
17 CHAIR YOUNG: Go ahead. Go ahead.
18 JUDGE ABRAMSON: Let's pursue the question 19 that Mr. Lewis wanted to ask, which is, do you have 20 any data to support the proposition that saltwater 21 would degrade epoxy at a more rapid rate than 22 freshwater?
23 MR. GUNDERSEN: My experience on salt, 24 brackish, and freshwater plants indicates that in 25 general saltwater is the worst for any component.
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706 1 JUDGE ABRAMSON: Do you have any 2 experience with those on epoxy?
3 MR. GUNDERSEN: I already indicated that 4 I don't have experience on epoxy liners.
5 CHAIR YOUNG: You said you had more that 6 you wanted to tell us in follow-up to the earlier 7 discussion.
8 MR. GUNDERSEN: Yeah. I actually just 9 have a few more issues. Thank you.
10 Two things. My concern remains that if 11 there is a leak, that it could cause catastrophic 12 failure, as I have discussed earlier. This liner, just 13 to make sure, is not a seismic barrier. It is a 14 pressure barrier.
15 And I want to make sure that we all 16 understand that when you are doing the seismic 17 analysis, you are assuming the pipe is relatively 18 ductile and this liner is more brittle. So it is the 19 pipe that has to withstand the motion.
20 So adding this liner doesn't strengthen 21 the pipe from a seismic standpoint but, rather, seems 22 to be better than the thing which went before, 23 although I haven't seen, you know, a lot of data in 24 that regard.
25 Secondly --
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707 1 CHAIR YOUNG: In the seismic context, you 2 are talking about if there were holes that were either 3 big enough on their own or several small ones 4 together, that that is what you are worried about from.
5 a seismic standpoint, correct?
6 MR. GUNDERSEN: Correct. That could cause 7 the pipe to collapse, which would affect the back 8 pressure on the system and, hence, the relative flow 9 through the heat exchanger.
10 CHAIR YOUNG: So do you have anything to 11 raise a doubt about whether when they discovered these 12 holes they took out the parts with the holes or that 13 what remained didn't have either holes or thinning to 14 the extent that they would be susceptible to damage in 15 a seismic event?
16 MR. GUNDERSEN: There's documentation in 17 the file which has not been provided. It's our 18 exhibits. Thirty-four is one of them about the 19 coating and how the applicant didn't ever assume that 20 the coating was there, that it was nice to have but --
21 CHAIR YOUNG: The rubber or the epoxy?
22 MR. GUNDERSEN: Well, at the time those 23 reports were written, it was when both were in play.
24 And it's not clear. Certainly the rubber, but I'm not 25 sure that it also relates -- that the applicant's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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708 1 questions relate to that liner as well.
But prior to 2 that liner being sold, they were not taking credit for 3 the rubber to which the liner is now attached. -
4 1 do have a concern that a visual 5 inspection of this pipe, which was done before this 6 sock was applied -- we already have indications that 7 the liner peeled. And it's not clear to me that there 8 might not be moisture behind that liner in other 9 places that were undetected. So that the possibility 10 of a through-wall for moisture that remains there when 11 the sock was put on to me is real.
12 There was one comment by the NRC about 13 ultrasound. And I would agree that a perpendicular 14 ultrasound would be impossible to detect any problem 15 because you are going through several layers of 16 varying thicknesses and roughnesses and things like 17 that.
18 However, there is a parallel wave 19 ultrasound which sends a wave through the pipe. And 20 for short lengths like we're talking about, a parallel 21 wave ultrasound would likely -- and, again, I haven't 22 spent the hundreds of hours to analyze it, but the 23 parallel wave ultrasound could indicate the wall 24 failures that are no longer detectable by ultrasound 25 because of the liner put in place.
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709 1 CHAIR YOUNG: Did you understand that the 2 inspection they described, the visual inspection 3 before they put the epoxy liner -- did you understand 4 them to say that they had left anything in place where 5 there would be a possibility of that moisture being 6 behind the rubber lining or was there something --
7 'what mechanism would cause that to --
8 MR. GUNDERSEN: Right. I understood it 9 that they would send a crawler. with cameras on it, 10 which looked for deformations in the liner. And I 11 also understood this is -- when. I ran an ultrasonic 12 business, we had skinny guys. That was their job, to 13 crawl inside pipes. This pipe is -- large portions of 14 it are reachable by skinny people.
15 A visual inspection -- we paid them well, 16 by the way.
17 (Laughter.)
18 MR. GUNDERSEN: A visual inspection --
19 CHAIR YOUNG: They have a better 20 experience than the old chimney sweeps. That's what 21 it reminds me of. Anyway --
22 (Laughter.)
23 MR. GUNDERSEN: But, anyway, I don't 24 believe that that technique -- the technique they used 25 would detect gross deformities in the wall. And by NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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710 1 "gross," you know, I am thinking about a bubble that 2 might be six inches around and maybe a half-inch. But 3 smaller bubbles I'm not convinced would be detected by
.4 that technique, which would mean there is still 5 moisture behind that rubber barrier.
6 CHAIR YOUNG: What would cause you to 7 think that there would necessarily be moisture, as 8 opposed to just air? I mean, maybe that's an ignorant 9 question, but I'll ask it anyway.
10 MR. GUNDERSEN: Yeah. It may not be all 11 water. It could be water and air. But given that the 12 system had water behind it, I would expect it could be 13 moisture bubbles behind the rubber, which is now 14 covered by the sock.
15 And given that we already have a history 16 that can break through that wall, you know, I think 17 that 18 CHAIR YOUNG: A history of?
19 MR. GUNDERSEN: Of once moisture gets 20 behind that rubber, that the pipe can degrade. I 21 think a more frequent than ten-year inspection is 22 appropriate.
23 CHAIR YOUNG: I don't want to interrupt or 24 belabor the point, but for me it is helpful -- and I 25 appreciate it -- to explain it from a lay person's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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711 S1 viewpoint.
2 Did we have information that the 3 degradation of the metal pipe was when water got 4 behind the rubber coating or when the rubber coating 5 developed a hole so that -- and I understand, 6 obviously, that there could be a very, very small 7 hole, but if there could be a way for moisture to get 8 behind the rubber lining without there actually being 9 a visible hole in the rubber lining, how would that 10 occur?
11 MR. GUNDERSEN: I guess if there were no 12 visible hole and if the inspection really was capable 13 of finding every visible hole, you are correct. It 14 could be just laminated with a void behind it.
15 CHAIR YOUNG: A what?
16 MR. GUNDERSEN: A void --
17 CHAIR YOUNG: A void?
18 MR. GUNDERSEN: -- of some type. I think 19 you're correct. This is a 2001 document that I would 20 like to refer to. And they're talking about the 21 lining. So 2001 is about the time the sock is -- but 22 I'm not clear that it's --
23 CHAIR YOUNG: Why don't you go ahead and 24 distribute that if we're talking about a document --
25 MR. GUNDERSEN: Okay.
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712 1 CHAIR YOUNG: -- so everyone can see?
2 MR. GUNDERSEN: Can I read while she's 3 doing that or do you want to wait?
4 JUDGE ABRAMSON: Please. Let's keep 5 moving.
6 CHAIR YOUNG: If you're reading from it.
7 MR. GUNDERSEN: It's on page -- well, it's 8 got a Bates number on it. It's PILLR. Oh, my God.
9 There's a whole bunch of zeroes. And then it's 665.
10 MR. LEWIS: Judge --
11 MR. GUNDERSEN: The third paragraph says 12 13 MR. LEWIS: Judge, I'm --
14 CHAIR YOUNG: Hold on.
15 MR. LEWIS: I would object to this 16 document. Mr. Gundersen is referring to a draft 17 document and a partial document. And there is no 18 showing that this document is reliable or admissible.
19 I understand we disclosed it. We 20 disclosed every document that was relevant. But the 21 question is not relevance. The question is whether 22 this is an admissible, reliable document.
23 CHAIR YOUNG: What is the basis of the 24 objection because it is not a final document?
25 JUDGE ABRAMSON: It is incomplete.
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713 1 MR. LEWIS: It is a draft document. It is 2 a partial document. And, therefore, it is not 3 reliable.
4 MS. LAMPERT: May I please?
5 CHAIR YOUNG: Go back and speak into the 6 microphone. My question is, what is the basis --
7 MR.. LEWIS: We --
8 CHAIR YOUNG: Let me finish my question.
9 MR. LEWIS: Yes.
10 CHAIR YOUNG: What is the basis of the 11 objection simply because it is a draft document?
12 Obviously if it is not complete, you could add 13 whatever there would be necessary to complete it. But 14 is there an evidentiary rule that prohibits the 15 admission of drafts, as opposed to final documents?
16 MR. LEWIS: Normally a document has to be 17 sponsored with a showing that it is accurate and 18 reliable for it to be admissible. Mr. Gundersen is 19 certainly not sponsoring it or identifying it as 20 reliable.
21 CHAIR YOUNG: But it is your document, 22 right?
23 MS. LAMPERT: It is your document.
24 MR. LEWIS: It is our document, but it is 25 a draft and it is a partial document.
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714 1 CHAIR YOUNG: And what's -
2 MR. LEWIS: And, therefore, it is not 3 necessarily accurate.
ý4. CHAIR YOUNG: -What is -the evidentiary rule 5 that pertains to draft documents?
6 MR. LEWIS: The NRC rules 7 CHAIR YOUNG: I'm not aware of any.
8 MR. LEWIS: NRC rules of practice allow 9 the Board to admit documents that aren't reliable. I 10 mean -
11 CHAIR, YOUNG: What I am saying is, .we 12 don't follow the rules of evidence here. However, in 13 another life I did. And in other forums, they do.
14 And there are rules of evidence out there to which we 15 can look for guidance.
16 So if you are making an objection-on the 17 basis of this document being a draft, what is the 18 evidentiary basis for that objection?
19 MR. LEWIS: Simply that there has been no 20 foundation to establish that it is either accurate or 21 reliable. And there is no authentication.
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715 1 interest.
2 So what is the basis for the unreliability 3 of the document in your view?
4 MR. LEWIS: The fact that it hasn't been 5 validated by the company. It. was a draft work in 6 process by one individual. It's certainly not an 7 admission by the company.
8 MS. LAMPERT: Can I say something?
9 MR. LEWIS: We have provided the full and 10 final document. Maybe the same statement is in there.
11 And I would not object to the full and final document 12 being admitted. I do object when Ms. Lampert takes 13 some portion of a draft, instead of the full and final 14 document.
15 JUDGE ABRAMSON: Let's pursue this.
16 CHAIR YOUNG: Do we have the full one? Do 17 we have the final?
18 MS. LAMPERT: Okay. First let's address 19 why it is part of the document and not the whole.
20 CHAIR YOUNG: Okay.
21 MS. LAMPERT: What?
22 CHAIR YOUNG: First, before you do that, 23 do you have the full document?
24 MS. LAMPERT: Not with me today because it 25 said the same thing and --
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716 1 JUDGE ABRAMSON: Do you have the final 2 document with you, Mr. Lewis?
3 MR. LEWIS: We can provide it.
4 JUDGE ABRAM'SON: Fine. Let's get the
.5 final document.
6 CHAIR YOUNG: Why don't we put this aside.
7 And when we break for lunch, can you get it during 8 lunch and then bring it back? Because that would 9 obviate a lot of this argument.
10 MR. LEWIS: Yes.
11 CHAIR YOUNG: Okay. And also at lunch --
12 we probably need to break soon for lunch -- also we 13 need to get the complete version of the condition 14 report. At this point it might be good to ask, how 15 close are we to finishing up the service water issues?
16 And at what point would it be good to break? Can we 17 finish before lunch on this?
18 JUDGE ABRAMSON: We should be able to 19 finish before lunch, but I want to hear what Mr.
20 Gundersen was starting to use this for. Do you want 21 to wait until after lunch or is this a big point or a 22 little point?
23 MR. GUNDERSEN: I think it will be quick.
24 First of all, this quote appears in two other 25 documents as well.
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717 1 JUDGE ABRAMSON: Okay. So tell us about 2 the gist of it and what you --
3 MR. GUNDERSEN: The quote simply says, 4 "The piping that is underground is protected by. a 5 coating, but since the coating does not have a 6 specified life, the aging effects will be evaluated 7 for carbon steel." Again, we get back to the fact of 8
9 CHAIR YOUNG: I'm sorry.
10 MR. GUNDERSEN: -- a specified life of a 11 coating and --
12 CHAIR YOUNG: I'm sorry. Again, being the 13 lay person, I have to understand what I am hearing.
14 Are you talking about the exterior or interior 15 coating?
16 MR. GUNDERSEN: It's unclear with the 17 document.
18 CHAIR YOUNG: Okay. Thank you.
19 JUDGE ABRAMSON: Are we done?
20 MR. GUNDERSEN: There's also two other 21 documents with that identical quote in them.
22 CHAIR YOUNG: Okay.
23 MR. GUNDERSEN: Yes, I'm done.
24 JUDGE ABRAMSON: Okay. So, Mr. Gundersen, 25 let's come back for a minute to what I keep trying to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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718 1 drag us back to, which is, can this component satisfy 2 its intended safety function, which is to make sure it 3 doesn't get blocked and make sure that both trains 4 don't get blocked by some event.. ..
5 You have suggested that the event that we 6 need to. worry about is the earthquake event. Is that 7 correct? Is there some other event that you. think 8 might also present this kind of challenge?
- 9. MR. GUNDERSEN: The most likely one in my 10 mind is a design basis earthquake, yes.
11 JUDGE ABRAMSON: Design basis earthquake.
12 Okay. So now let me come to the applicant and the 13 staff and let's go to the --
14 CHAIR YOUNG: He asked you, is there any 15 other? You said that --
16 MR. GUNDERSEN: I think they're much more 17 remote.
18 CHAIR YOUNG: Okay.
19 JUDGE ABRAMSON: So let me come to the 20 applicant and the staff. Let's turn to 10 CFR 54.4.
21 And let's talk about which of these criteria we're 22 worrying about.
23 54.4 says that the intended functions that 24 we're worrying about could be safety-relates systems 25 that have to remain functional during and following a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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719 1 design basis event. Do both of these pipes need to 2 remain functional during a design basis earthquake?
3 MR. COX: Yes, that's correct.
4 JUDGE ABRAMSON: Plant would be shut down 5 at the design basis earthquake, right?
6 MR. SULLIVAN: That is correct.
7 JUDGE ABRAMSON: And when it is shut down, 8 do you need to have both trains? Will one train 9 suffice or do you need either of these to continue to 10 remove heat?
11 MR. SULLIVAN: Either of these. The plant 12 is designed to be single failure.
13 JUDGE ABRAMSON: But you must have one of 14 these functional after the design basis. earthquake to 15 remove the heat?
16 MR. SULLIVAN: That's correct.
17 JUDGE ABRAMSON: Okay. So the question 18 that we're addressing is whether there needs to be a 19 component in the aging management program that would 20 do something in the way of inspection to assure that 21 this pipe doesn't get plugged by a design basis 22 earthquake. Is that really where we are going.here?
23 Mr. Gundersen, is that correct?
24 MR. GUNDERSEN: Yes.
25 MR. SULLIVAN: I am sorry. Was there a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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720 1 question?
2 JUDGE ABRAMVSONE No. I am trying to 3 understand what Mr. Gundersen is suggesting. And it
.4 seems to me what it is arguing is that the aging 5 management program needs to have more frequent 6 inspections or some more frequent inspection of these 7 pipes to ensure that degradation, aging-related 8 degradation, isn't taking place in this pipe such that 9 the pipe might fail in a design basis earthquake in a 10 manner that would cause the pipe to be fully blocked 11 and not let water out of the heat exchanger.
12 What does the plant do about the inlet 13 pipe? It's not carrying radioactive water. But what 14 is your program for the pipe bringing in that water?
15 That's to me if you have a significant break in that, 16 you've got a problem, more likely problem, than a plug 17 of the outlet pipe.
18 MR. SULLIVAN: That is correct. The inlet 19 piping is titanium piping. It is analyzed for seismic 20 loading.
21 JUDGE ABRAMSON: And it's titanium. So 22 the corrosion and the failure problems are much 23 smaller? Is that the --
24 MR. SULLIVAN: Although they are much 25 smaller because it is titanium, that piping was NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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721 1 wrapped with a protective coating as well.
2 JUDGE ABRAMSON: Now, it's not in this 3 proceeding because it doesn't carry radioactive water, 4 but what is your inspection program for that?
5 MR. SULLIVAN: The aging management 6 program for the external surface is the same as for 7 the discharge piping.
8 JUDGE ABRAMSON: So it's a buried pipe 9 tanks inspection program?
10 MR. SULLIVAN: That's correct.
11 JUDGE ABRAMSON: Okay. Mr. Gundersen, 12 early in the life of this epoxy coating, one of these 13 -- well, not early, actually. One of these systems is 14 going to be inspected right before the license 15 extension would begin if it's granted. The other 16 system would be in the year following the grant of the 17 license extension.
18 If you were running a program, what 19 assumptions or how would you approach the question of 20 degradation of the epoxy and how would you determine 21 how frequently it needed to be inspected? Would it 22 vary with the life? Would you do it once early on to 23 see things were right and then give it a bigger 24 period? How would you address the problem?
25 MR. GUNDERSEN: I think it is in my NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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722 1 testimony. And it is pretty straightforward. I have 2 no problem wfth a ten-year inspection interval for the 3 whole pipe. However, I think it should be done like 4 ASME 11 does for a nuclear reactor, which breaks that 5 overall tenure up into segment, so essentially every 6 refueling outage, do a portion of it.
7 And that would allow essentially six 8 refueling outages in ten years approximately. That 9 would allow one-sixth of the pipe to be inspected 10 every 18 months.
11 JUDGE ABRAMSON: And you would be 12 satisfied with a visual inspection at this point given 13 that there's some uncertainty about whether a UT 14 inspection would work?
15 MR. GUNDERSEN: There's another issue, 16 which probably has to wait until after lunch. You can 17 apply cathodic on the outside with an impressed 18 current. That combination of a visual on the inside 19 and an impressed current, cathodic protection on the 20 outside would satisfy me.
21 And we get back to the monitoring well 22 issue, but within.--
23 JUDGE ABRAMSON: No. That's all right.
24 I'm just --
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723 1 expertise, impressed current, cathodic protection on 2 the outside, and a one-sixth every refueling outage 3 interior inspection would -
4 JUDGE ABRAMSON: So let me ask the 5 applicant, what you have is you do the whole pipe once 6 every ten years with some sort of a -- I've forgotten 7 what the word you -
8 MR. SULLIVAN: A crawler.
9 JUDGE ABRAMSON: Crawler, right. That can 10 be accomplished entirely within a refueling outage?
11 MR. SULLIVAN: Yes, it can.
12 JUDGE ABRAMSON: And what would your 13 reaction be to some proposal to do part of it more 14 frequently? Would that be --
15 MR. SULLIVAN: Creates an undue burden, an 16 unjustified burden for the station. And that's based 17 on the experience base used in epoxy linings, our 18 discussions with the vendor of the epoxy piping system 19 that they should be good for approximately 35 years.
20 We have accelerated that to take a look at the lining 21 every ten years. And we believe that that is 22 adequate.
23 JUDGE ABRAMSON: And I understand the 24 staff is in agreement that ten years is appropriate 25 for this type of lining?
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724 1 DR. DAVIS: That is correct.
2 JUDGE ABRAMSON; Dick, do you have any 3 follow-up on this?
4 JUDGE COLE: I have just got a general 5- question on corrosion. We have a couple of corrosion 6 experts here, and I would like them to respond to it 7 because it pertains to the strength of the pipe.
8 Corrosion being an electrical phenomenon 9 and looking at the Entergy exhibit 67, I notice there 10 are several holes in the pipe where the thickness of 11 the metal is zero.
12 Considering the way corrosion takes place 13 in the pipe, what does that say about the thickness 14 over the other sections of the pipe? What would they 15 likely be considering the fact of the way corrosion 16 generally operates?
17 MR. SPATARO: Are we talking about the 18 rubber lining failures?
19 JUDGE COLE: No. I'm talking about the 20 metal pipe.
21 JUDGE ABRAMSON: The piece that was cut 22 out, Dick, or the pipe? Yes.
23 JUDGE COLE: Or any pipe that has a thin 24 hole leak in it or a quarter-size hole in it.
25 MR. SPATARO: Okay. What exactly is the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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.725 1 question, then?
2 JUDGE COLE: What does- that say about the 3 thickness of the rest of the pipe? What is that 4 likely to be as compared to the zero thickness at the 5 hole?
6 MR. SPATARO: Okay.
7 JUDGE COLE: In other words, when you see 8 a hole in a pipe and if you've looked at a lot of 9 pipes, what would you say about the thickness of the 10 pipe as you or the thinness of the pipe as you depart 11 from the point where most of the corrosion has taken 12 place?
13 MR. SPATARO: Okay. In this instance, let 14 me start by saying that the rubber lining is placed in 15 a specially prepared surface of the inside of the 16 pipe. The rubber lining has a special adhesive that 17 is placed on this clean internal surface of the pipe.
18 The rubber lining is then inserted and 19 vulcanized. It's a curing process that's done with 20 heat, generally if it's a fairly small component in a 21 furnace. otherwise it's done in place by insulating 22 the pipe and providing a heat source to the internals 23 of the pipe.
24 Should the liner fail -- and we saw it 25 fail here. It fails by chipping out pieces of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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726 1 liner. The corrosion would occur at the point where 2 the substrate metal is exposed. That corrosion would 3 continue.
4 And, as we. see here, -it continued -through 5 the wall and did not really progress outward from the 6 wall to any great extent such that as the liner fails, 7 one would expect corrosion product to go under the 8 liner in an attempt to delaminate that liner.
.9 Because the liner is vulcanized to the 10 metal surface, that process is going to be severely 11 restricted. It is not quite the same as an ordinary 12 coating would be placed on that because that is 13 strictly a mechanical bond.
14 Here the bond is not only mechanical, but 15 as the liner expands under the vulcanizing process, it 16 presses it. It exerts a pressure against the pipe 17 itself. So that you have a pressure bond as well as 18 the adhesive bond of the material itself.
19 The corrosion process would have to 20 undermine that by deteriorating the pipe. The amount 21 of lateral degradation is much, much smaller than the 22 penetrating degradation of the pipe, such that you 23 would get a hole first. And then the corrosion 24 process would continue apace by enlarging that hole, 25 rather than proceeding under the liner, causing it to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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727-1 lift.
2 JUDGE COLE: And not by causing an overall 3 thinning of all the rest of the pipe?
4 MR.. SPATARO: No, not at all. Not at all.
5 JUDGE COLE: So what does that say about 6 the strength of the pipe with a hole in it?
7 MR. SPATARO: It's not degraded except 8 where the hole is.
9 JUDGE COLE: All right, sir.
10 MR. COX: Let me add a little bit just 11 based on my experience as an operator. We have had
- 12 service water pipe leaks within the plant at Arkansas 13 that are in piping that is not buried. It's above the 14 ground.
15 Typically those leaks are in holes.
16 They're fairly localized. Of course, when you have 17 that leak, you have to turn it over to your structural 18 engineers. They do operability evaluations.
19 The experience that I have from dealing 20 with those folks on these kinds of issues is that when 21 you say "minimal wall, " they are looking at -- minimal 22 wall is based on if the whole pipe was at that minimum 23 wall thickness.
24 And generally when you have this type of 25 corrosion, you're looking at a fairly localized area.
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728 1 I don't know of any cases where we found through-wall 2 leaks in piping where there has been a problem with 3 satisfying the seismic criteria with the remaining 4 metal because generally the rest of the pipe.* most of 5 the pipe, away from that through-wall leak is greater 6 than min. wall. And it's. generally not a problem to 7 satisfy seismic pressure.
8 CHAIR YOUNG: When you say, "greater than 9 min. wall," you mean there is still some coating.
10 JUDGE ABRAMSON: It's closer to the 11 design. No. It means the difference --
12 MR. COX: No. The pipe itself.
13 JUDGE ABRAMSON: -- is closer to the 14 original design. It's not worn down to the minimum.
15 MR. COX: That's correct. There is a 16 nominal wall thickness. The minimum wall is generally 17 something less than what you get when you receive the 18 pipe.
19 CHAIR YOUNG: Okay.
20 JUDGE COLE: Do any of the staff corrosion 21 experts have any comment on that?
22 DR. DAVIS: What he says is correct. I've 23 looked at buried pipe for many, many, too many years.
24 And the National Bureau of Standards, which is now 25 NIST, did a very extensive study. What they found was NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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729 1 in the United States, on average a bare steel pipe 2 will corrode through in 28 years.
3 JUDGE COLE: Carbon steel?
DR.. DAVIS: Carbon steel.
5 CHAIR YOUNG: How thick?
6 DR. DAVIS: It really doesn't matter much.
7 Once the corrosion starts, it goes fairly quickly.
8 CHAIR YOUNG: Oh, okay. I see.
9 DR. DAVIS: In the coated pipe, you get 10 holes with no loss of material other than where the 11 defect in the coating is, which is-the case here. And 12 so I would not expect to see any of the other wall 13 thickness reduced except for you have defects in the 14 coating.
15 And it is very localized. You could have 16 possibly some under-coat corrosion, but it would be 17 very minor.
18 JUDGE ABRAMSON: If you had that sort of 19 degradation, what would it do to the structure, to the 20 ability of that pipe to withstand the design basis 21 earthquake?
22 DR. DAVIS: I'm not really a seismic 23 person.
24 JUDGE ABRAMSON: You're not a seismic?
25 DR. DAVIS: But, in my opinion, it would NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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.730 1 have very little effect. You can actually have holes 2 in pipe for cross Iconnections. And it doesn't affect 3 the strength. But maybe Terrence.
4 MR. CHAN: When I had members of my staff 5 review, do their seismic analyses, I1 have not seen an 6 instance where localized holes have significantly 7 affected the ability of a piping system to withstand 8 a seismic event.
9 JUDGE ABRAMSON: And have you seen 10 analyses or had your staff performed analyses for 11 pipes that were degraded greater than what we're being 12 told happened here? In other words, we've got a 13 quarter-inch or several quarter-inch holes or maybe an 14 area that that's big?
15 For the record, that is a couple of inches 16 in diameter. Several quarter size holes within close 17 proximity to each other over a pipe that is on the 18 average 20 inches diameter.
19 MR. CHAN: Well, that is -- the 20 significance 'of a particular hole is dependent upon 21 the loading that is imposed on that pipe as well as 22 other parameters.
23 JUDGE ABRAM4SON: Right.
24 MR. CHAN: Now, but the analyses that I 25 have had staff look at, they have looked at degraded NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N-W.
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731 1 conditions, whether it's localized thinning or whether 2 there is more global thinning with no through-wall, no 3 through-wall penetration or no through-wall leakage.
4 And those analyses, to *the best of my 5 recollection, have not indicated that those pipes 6 would not be able to withstand the design basis 7 earthquake.
- 8 JUDGE COLE: Mr. Gundersen, you would like 9 to comment?
10 MR. GUNDERSEN: Thank you.
11 You could probably take a drill and put a 12 three-quarter- inch hole in this pipe, and it would be 13 just fine. My concern is that when smaller holes gang 14 up in a more diffuse pattern, as indicated in that 15 picture, that there is a broader area of wall 16 thickening that can lead to stress risers in the event 17 of a design basis event as that pipe flexes.
18 So it is not about a single hole. It is 19 about numerous small holes, maybe through-wall, but, 20 as that picture indicates, too, where there are 21 through-wall small holes, there is -- also between 22 them the wall becomes much, much thinner. So that 23 essentially while it may not be leaking that much 24 water, in fact, there is no pipe there.
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732 1 consistent with what we heard the staff and the 2 applicant's experts tell us about how corrosion moves 3 parallel to the surface underneath the coating? Do 4 you have experience where you are worried about 5 corrosion that might move underneath the coating, 6 which is what is being speculated here, not normal to 7 the coating but underneath it, right? So you've got 8 a --
9 MR. GUNDERSEN: Yeah. I understand.
10 JUDGE ABRAMSON: You understand?
11 MR. GUNDERSEN: I think the picture 12 indicates that, you know, there was maybe a six by 13 six-inch piece that had been -- maybe four by 14 four-inch that was attacked. There's not much 15 indication out beyond that in the photograph that the 16 attack extended beyond, you know, four by four or six 17 by six.
18 So I would -- where both surfaces, where 19 the liner is intact on one side and where the 20 protective coating on the outside is intact, where 21 both of those phenomena exist, the parallel 22 degradation would be less than the transverse 23 degradation.
24 Did I answer that?
25 JUDGE ABRAMSON: I think so.
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733 1 MR. GUNDERSEN: Okay.
2 CHAIR YOUNG: I have three follow-up 3 questions. And then as far as I know, except for 4 these two exhibits that we need to take care of, that 5 I hope will maybe cover the service water, although if 6 anything else comes up, we won't foreclose that.
7 The first is you heard Dr. Gundersen talk 8 about the equipment qualification, his argument about 9 the equipment qualification and I guess what 10 manufacturer's information is provided with regard to 11 the epoxy liner and that in the of a saltwater 12 environment, as opposed to a brackish or freshwater 13 environment.
14 Can you follow up on that and give us any 15 information that you have that would be relevant to 16 that?
17 MR. SPATARO: Yes, I can. The resins in 18 question have been in use throughout the industries 19 for well over 50 years. That's first. Second --
20 CHAIR YOUNG: Industries you mean other 21 than nuclear?
22 MR. SPATARO: Oh, absolutely, yeah.
23 Power, water treatment, chemical factories, you name 24 it. The second thing is that the tests show because 25 each of the manufacturers does provide what the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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734 1 coatings or what the resins will withstand and what 2 they will not withstand.
3 And these epoxies are totally immune to 4 all waters, does not matter whether it's brackish, 5 fresh, lake, sea, does not matter at all. What is 6 more important is that they have limits on temperature 7 applications and on certain types of chemicals, which 8 will break down the resins, but not waters at all, not 9 any of the waters.
10 CHAIR YOUNG: These are the manufacturer's 11 guidelines for using it, in other words?
12 MR. SPATARO: That's true. That's true.
13 CHAIR YOUNG: Okay. And the chemical 14 things that you're worried about, could that include 15 saltwater or --
16 MR. SPATARO: No, not at all, absolutely 17 not.
18 CHAIR YOUNG: So different sorts of --
19 MR. SPATARO: We're talking acids bases, 20 chemical compounds of an aggressive nature. For 21 instance, if I were using the epoxy in a chemical 22 factory, they would definitely tell me "Whoa. You 23 can't use it there."
24 If I were using it, say, at Pilgrim, where 25 we use sulfuric acid and sodium hydroxide in the water NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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735 1 purification process through the filtration systems, 2 there would be guidelines as to which epoxies would 3 work and which ones would not work. And. we would not 4 use them in those instances.
5 But when you are talking about waters in 6 general, all types of water, no, there are no 7 limitations to the use.
8 CHAIR YOUNG: My second question is you 9 heard Dr. Gundersen talk about the possibility of 10 using parallel wave ultrasound. Can you address that?
11 I don't know which one of you would be the one?
12 JUDGE ABRAMSON: Do any of you have any 13 expertise in it?
14 MR. SULLIVAN: Before we move on to that 15 question, I would like to clarify that at Pilgrim, we 16 do not use sulfuric acid or hydroxides for water 17 treatment systems. We do use a sodium hypochlorite in 18 our service water system to control microfouling.
19 CHAIR YOUNG: Would that fall under any of 20 the warnings from the manufacturer?
21 MR. SULLIVAN: We don't use this piping 22 system in that.
23 CHAIR YOUNG: You don't use that with 24 these pipes?
25 MR. SULLIVAN: Yes.
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736 1 CHAIR YOUNG: Okay.
2 MR. SULLIVAN: That's correct.
3 MR. COX: I don't have much experience 4 with the ultrasonic method that Mr. Gundersen referred 5 to. We did include in our license renewal application 6 -- we actually called it an exception to the program 7 because we wanted to provide a provision to use a more 8 advanced technique.
9 If something is developed and is proven to 10 be effective that would allow you to do that whole 11 length of discharge piping without digging it up, we 12 would certainly want to be able to take advantage of 13 that. So we did allow for that option.
14 I think we called or we mentioned one 15 example as a phased array, ultrasonic technology. I'm 16 not sure if that's the same as the parallel wave that 17 Mr. Gundersen mentioned, but if a parallel wave 18 technology proves to be better and more effective at 19 evaluating that piping and we can do that without 20 digging up the piping, we certainly wanted to be able 21 to take advantage of that.
22 JUDGE ABRAMSON: Mr. Gundersen, would you 23 provide some information to the applicant on that 24 technique, please, not now at this moment but when you 25 get a chance?
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737 1 MR. GUNDERSEN: Yeah. My comment about 2 the parallel wave was in response to I think an NRC 3 question. I would -- and I agree that the normal 4 perpendicular portion -- but I do agree with Entergy 5 that the phase array approach that they have proposed -
6 as an exception would detect leaks in the wall.
7 Again, my problem is not with that 8 technique. It's that I don't think you should wait 9 ten years to apply it.
10 CHAIR YOUNG: Anything further on that?
11 I have one more question if not.
12 MR. SPATARO: Judge Young?
13 CHAIR YOUNG: Yes?
14 MR. SPATARO: May I provide two 15 clarifications, please?
16 CHAIR YOUNG: Yes.
17 MR. SPATARO: My use of the sulfuric acid 18 and the sodium hydroxide comes from pressurized water 19 reactors and not boiling water reactors. So their 20 correction of my statement is absolutely true.
21 The second is that Mr. Gundersen pointed 22 out that the specimen you are looking at in that 23 picture is four by four or six by six inches. That's 24 the specimen size that we chose to examine with 25 respect to the degradation.
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738 1 The degraded area is far less than four by 2 four and six by. six, showing and proving that the 3 lateral degradation is really quite small with respect 4.. to the amount of penetration, the area of penetration 5 through the wall.
6 CHAIR YOUNG: My last question has to do 7 with a reference in Entergy's testimony to the salt 8 service water system being credited in the safe 9 shutdown analysis for fire protection.
10 And my question, first of all, is, could 11 you just explain where that would fall? It's a backup 12 system, I presume. And what other protections would 13 come into place before you had to reach that?
14 And then are there any -- I don't know, 15 but I was recently involved in another proceeding 16 where Shearon Harris was one of several plants that 17 had had some problems with the fire protection systems 18 that they had in place. And I think there's a new 19 rule that's being worked out at the NRC on that. Does 20 that come into play in any way with the fire 21 protection issue?
22 And the reason I am asking that is because 23 obviously that relates to peripheral safety functions, 24 but it's something that is related to safety. Can you 25 just provide any clarification on that?
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739 1 MR. SULLIVAN: The salt service water 2 function for appendix R purposes is heat removal when 3 we are in pressure control mode or level control with 4 HPSI and RPSI systems in operation.
5 MR. COX: We wouldn't treat the -- whether 6 it was in-scope for A-1, which is a safety-related 7 function, or for A-3, we would -- essentially its 8 function in both cases is heat removal from 9 safety-related equipment. So we wouldn't treat it any 10 differently based on those two different intended 11 functions.
12 CHAIR YOUNG: Let's see. A, B, C, and 13 BRS.
14 MR. SULLIVAN: That's Alan Cox and myself.
15 CHAIR YOUNG: Okay. You said that the 16 same is also credited under A-3 because the salt 17 service water is credited in the 10 CFR Part 50, 18 appendix R, safe shutdown analysis for fire 19 protection, 10 CFR 50.48.
20 I guess what I thought that meant was that 21 if, for some reason, you needed to use this to 22 supplement the normal or the regular fire protection 23 system. Am I not understanding this or what?
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740 1 require you to be able to achieve safe shutdown when.
2 you have a fire that affects another part of the 3 plant.
4 This system is not used to put out the S - fire or provide any kind of fire protection. It is 6 used to get the safe shutdown when you have had a fire
'7 that affected something else.
8 CHAIR YOUNG: Okay. Okay. Now I 9 understand better anyway.
10 Any follow-up on any of those three things 11 that I had asked? Yes?
12 MR. GUNDERSEN: The experience in Japan 13 two years ago after that large earthquake, so we had 14 a design basis earthquake, which caused a fire. So, 15 you know, it's important that just we have a situation 16 already on the record where a design basis earthquake 17 caused a fire. So that the two are not sort of 18 separate events.
19 Separately, just one last thought on this, 20 the epoxy liner. There's a long industry experience 21 with it. I cannot believe that 50 years experience, 22 as quoted, has had no flaws. And, really, that seems 23 to be *out there. I can put this in, and this works 24 flawlessly.
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741 1 field application on an old pipe. And given that, .a 2 more frequent inspection program I think is 3 appropriate along with the issue of monitoring wells 4 as well.
5 CHAIR YOUNG: Thank you.
6 Do the manufacturers' guidance and 7 specifications, whatever you call it, have any -- did 8 they address using it on old surfaces, like this type 9 that would already have a rubber liner? Does it --
10 MR. SPATARO: Yes, Your Honor, absolutely.
11 The product was designed to be used on old piping 12 systems. That's its claim to fame. That's what's 13 given it a niche in the industry that we can use it on 14 systems negating the fact that we have to dig them up 15 and replace them or dig them up and repair them. it 16 saves the user a tremendous amount of money and cost 17 and aggravation and you name it.
18 So yes, that is why it has been used 19 extensively, because it is designed exactly for that, 20 for old pipes.
21 CHAIR YOUNG: And then on the fire issue, 22 did I understand you correctly that the function that 23 it serves, the same function that it normally serves 24 is a cooling function? Is that right?
25 MR. SULLIVAN: That's right. It's what NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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742 1 you need to maintain the plant in -safe shutdown 2 condition.
3 CHAIR YOUNG: Okay. Why don't we take a 4 lunch break. And when we come back, we will deal with 5 these two exhibits.
6 JUDGE ABRAMSON: *Set a time to get back so 7 we can keep moving.
8 CHAIR YOUNG: Right. And in addition to 9 dealing with these two exhibits, if there is any final 10 follow-up on the salt service water. otherwise we'll 11 move directly to the condensate storage system.
12 It is now about 1:00 o'clock. Come back 13 at 2:00 o'clock. I don't know how fast people can eat 14 or how long it takes to go places.
15 (Whereupon, the foregoing matter was 16 concluded at 12:59 p.m.)
17 CHAIR YOUNG: Back on the record.
18 Mr. Lewis, you have --
19 MR. LEWIS: Shall I identify what I have 20 given you, Judge Young?
21 CHAIR YOUNG: Pardon me?
22 MR. LEWIS: Shall I identify the documents 23 I've given you?
24 CHAIR YOUNG: I'm just trying to make sure 25 which ones -
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743 1 JUDGE ABRAMSON: You should have three, *a 2 condition report, a nonconformance report sheet, and 3 the verification. That's it.
4 CHAIR YOUNG: I have three documents.
5 MR. LEWIS: I'll explain them.
6 CHAIR YOUNG: Okay.
7 MR. LEWIS: Are we on the record?
8 CHAIR YOUNG: I was expecting two, that's 9 why.
10 MR. LEWIS: Yes.
11 CHAIR YOUNG: All right, yes, I think 12 we've already gone on the record. So go ahead.
13 MR. LEWIS: I have provided a condition 14 report, the full copy which is four pages, not the two 15 that were previously provided. And included in the 16 pages is a statement that the noted condition is not 17 a condition adverse to quality and therefore will be 18 dispositioned by a nonconformance report so I've also 19 conducted the nonconformance report which actually 20 dispositions this issue for completeness.
21 CHAIR YOUNG: Okay, so you want to combine 22 those two into one exhibit?
23 MR. LEWIS: Yes, if you want the full 24 story on how this issue was resolved?
25 CHAIR YOUNG: Okay, so we'll combine the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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744 1 condition report, and the nonconformance report form 2 which has several pages. Ms. Tebo do you have copies
-3 of these?
4 Combine those.
5 THE CLERK: Would you like these entered 6 in as the Applicant's exhibits or the Appellant's 7 Exhibits?
8 JUDGE ABRAMSON: Let's make it Applicant's 9 exhibits and they can refer to them. That works. All 10 you need is the document.
11 CHAIR YOUNG: And they'll be Exhibit 68.-
12 We're going to combine them. Do you want to make them 13 two separate ones? Sixty-eight and 69 then. The 14 condition report is 68 and the nonconformance report 15 form that relates to that is 69.
16 MR. LEWIS: And then for the record I've 17 also provided a complete copy of a document that's 18 Report No. AMRM-II, the aging management review of the 19 saltwater service system. This is Revision 1 in and 20 I guess approved November 2, 2007. I note that on 21 page 10 it still has the same statement that Pilgrim 22 Watch was referring to, so this is just the complete 23 copy and it hasn't prevented Pilgrim Watch from 24 referring to the specific statement that Mr. Gundersen 25 was referring to.
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745 1 CHAIR YOUNG: okay, so it's a more 2 complete form of the earlier exhibit* proposed by 13 Pilgrim Watch. There's no differences actually 4 between the relevant pages, between the information on 5 the relevant pages.
6 MR. LEWIS: I would request just with 7 respect to this one statement, since this is an 8 additional document to allow our witnesses just to 9 explain what the statement means.
10 CHAIR YOUNG: The statement that was 11 brought out earlier?
12 MR. LEWIS: Yes, it's the statement on 13 page 10 that says "since the coding does not have a 14 specified life, aging effects are evaluated as if the 1s quality of steel was not coated."
16 JUDGE ABRAMSON: And since we had some 17 uncertainty as to what that meant we should --
18 CHAIR YOUNG: Let's get to that after we 19 get the documents in.
20 So this would be Exhibit 70.
21 (Whereupon, the above-referred 22 to document was marked as 23 Exhibit 70 for identification 24 and was received in evidence.)
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746 1 copies of the photos, do you want to. do that and make 2 sure that -- I think we need three copies. Is that 3 right, Ms. Tebo.
4 THE CLERK: I need two.'
5 CHAIR YOUNG: Two. It would be helpful to 6 give us also -- if you're going to print out copies.
7 MR. LEWIS: Maybe on the next break I can 8 try and get the color copies of those if --
9 JUDGE ABRAMSON: What next break.
10 MR. LEWIS: Okay.
11 (Laughter.)
12 CHAIR YOUNG: Those can be submitted 13 either today or after the fact. I mean what -
14 obviously, it would be better today. People could 15 look at it, but I presume Pilgrim Watch you sought 16 when you looked at it on the computer, you saw what 17 the original photo looked like on the computer before 18 it was printed out, so there wouldn't be any harm in 19 substituting a better printout of the photo.
20 MS. LAM4PERT: No, that would be a great 21 idea.
22 CHAIR YOUNG: Okay, so either today or 23 later --
24 MR. LEWIS: We can just try to see if we 25 can do it right now.
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-74.7 1 CHAIR YOUNG: Okay. So two for the 2 official record and one for each *of us and for the 3 rest of the parties, if it's not that difficult. All 4 right, great.. So that will be Exhibit -
5 MR. -LEWIS: Excuse me?
6 CHAIR YOUNG: That will be Exhibit 70 and 7 I think that takes care of that, so you wanted to 8 explain some of the language in the last one? You 9 wanted to have your expert explain that.
10 MR. COX: The statement, if I could read 11 -it here says "since the coding" -
12 CHAIR YOUNG: On page ten?
13 MR. COX: Right, it's on page 10 of 26.
14 It says "since the coating does not have a specified 15 life, aging effects were evaluated as if the carbon 16 steel was not coated."
17 CHAIR YOUNG: And this was how far down, 18 excuse me?
19 MR. COX: It's the first paragraph, starts 20 about the middle of the first, end of the second line 21 of the first paragraph.
22 It's the second sentence on that page.
23 CHAIR YOUNG: "Aging effects that may 24 result in" --
25 MR. COX: No, I'm sorry. It's page 10 of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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748 1 26, the second sentence on that paragraph,. starts with 2 "since the coating does not have a specified life" 3 CHAIR YOUNG: I was looking at the wrong 4 page, thank you.
5 MR. COX: And what that simply means is if 6 we had a specified life of the coating, a guaranteed 7 life, we would have no aging effects. We would have 8 no entries in the aging -- in the license renewal 9 application for that component. We would have none 10 listed as the aging effect. We would have no aging 11 management program listed or required to manage aging 12 effects.
13 What we've done here is since there is no 14 qualified life of the coating we have said that loss 15 of material of that underlying metal is possible, so 16 we have to have an aging management program. The 17 aging management program in this case is actually 18 relying on the coating and the inspections that we do 19 periodically of the coating to prevent the loss of 20 material from that surface.
21 CHAIR YOUNG: Is there any follow up to 22 that?
23 *MR. GUNDERSEN: That same quote appeared 24 in several other Entergy documents, so this is not a 25 stand-alone quote. It has woven its way through NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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749 1 several -- does it change anything of that quote if 2 repeated? I agree with them that we're acknowledging 3 that there's no qualified life and I think that the 4 emphasis is on qualified which I get back to that 5 environmental qualification from before.
6 Your Honor, I did find the citation. It's 7 10 CFR 50, Appendix B, paragraph 2 talks about the 8 inspection frequency being related to the qualified 9 life of the component.
10 I don't believe the liner is safety. The 11 pipe is safety related, but the liner is not, so I 12 keep coming back to it's nice that the liner is there, 13 but the real goal is to make sure that that carbon 14 steel pipe retains its integrity and doesn't collapse 15 and so -between looking at it from the inside and a 16 monitoring program from the outside, it's the pipe 17 that's the issue, not the liner.
18 CHAIR YOUNG: Is the second paragraph 19 talking about quality assurance?
20 MR. GUNDERSEN: 10 CFR 50(b) (II), I think.
21 CHAIR YOUNG: Roman numeral two?
22 MR. GUNDERSEN: Yes.
23 CHAIR YOUNG: Okay, so section two, not 24 paragraph two.
25 MR. GUNDERSEN: Yes. Yes.
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750 1 CHAIR YOUNG: Also relating to quality 2 assurance program.
3, MR. GUNDERSEN: I don't have it in front 4 of me. I'm sorry, I don't have what you're reading in 5 front of me.
6 CHAIR YOUNG: The citation that you were 7 giving.
8 MR. GUNDERSEN: Yes.
9 CHAIR YOUNG: Appendix B, Section 2 --
10 MR.'GUNDERSEN: Yes.
11 CHAIR YOUNG: And the title of that is 12 quality assurance program?
13 MR. GUNDERSEN: And I believe that that's 14 where the life cycle -- the testing comes in. In my 15 mind that's the first citation I could think of that 16 addressed the issue you brought up earlier which was 17 the frequency of testing being related to the 18 component degradation.
19 CHAIR YOUNG: Any other follow up?
20 MS. LAMPERT: Do you want those exhibits 21 he referred to or are you satisfied with one, his 22 statement?
23 CHAIR YOUNG: What exhibit?
24 MS. LAMPERT: He said that we had other 25 documents like the one produced that said the same NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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751 1 thing about the liner not being -- what do you call it 2 -- as specified.
3 JUDGE COLE: Guaranteed service life.
4 MS. LAMPERT: Yes, guaranteed service life 5 and we do like to submit those at this time as opposed 6 to just relying on the fact that he said that there 7 are other statements.
8 CHAIR YOUNG: I'm not going to ask for 9 anything. If you want to propose something --
10 MS. LAMPERT: I would like to propose --
11 CHAIR YOUNG: Do so and then we'll get 12 responses to that.
13 MS. LAMPERT: I would like to propose, if 14 I may, three other documents that were produced by 15 Entergy that, in essence, say the coatings have not 16 been specified.
17 JUDGE ABRAMSON: Do they all relate to the 18 same piping?
19 MS. LAMPERT: Yes, I believe so.
20 JUDGE ABRAMSON: And other than repetition 21 of the point, do they add any information to us, Mr.
22 Gundersen?
23 MR. GUNDERSEN: No, as I said, it's a 24 repetition of the point. It's repeated that same 25 exact same concept, can we just --
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752 1 MR. LEWIS: I don't know if they are, but 2 I would suggest they're redundant. We've admitted 3 this statement into evidence and it's there. And so
-4 I suspect 5 JUDGE COLE: The point was taken.
6 MR. LEWIS: Probably drafts of the same 7 document.
8 CHAIR YOUNG: Is there any reason to 9 submit them other than to just indicate that there are 10 three more that say the same thing?
11 MS. LAMPERT: No, I don't believe there 12 are.
13 CHAIR YOUNG: So the record --
14 MS. LAMPERT: Just to have the record show 15 that Entergy had provided any disclosures, three other 16 documents that say the same thing.
17 JUDGE ABRAMSON: With respect to the same 18 pipe.
19 MS. LAMPERT: With respect to the same 20 pipe.
21 CHAIR YOUNG: All right. Is there 22 anything else on this salt service water system that 23 any party would like to follow up on, anything that 24 we've overlooked?
25 MS. UTTAL: Did you want to say --
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753 1 DR. DAVIS: We just looked at that section 2 of Appendix B and we couldn't -
3 CHAIR YOUNG: We can't hear him.
4 JUDGE.ABRAMSON: Get close, Mr. Davis, Dr.
5 Davis.
6 CHAIR YOUNG: Project, pretend you're an 7 actor.
8 JUDGE ABRAMSON: Sing, get that thing 9 under your nose.
10 DR. DAVIS: We couldn't find anything in 11 that paragraph *that mentioned- qualification of 12 equipment.
13 JUDGE ABRAMSON: So perhaps you can get us 14 another more precise reference.
15 DR. DAVIS: Yes.
16 CHAIR YOUNG: It's only a one-paragraph 17 section. If it's Appendix B, Section II quality 18 assurance program, so it says-what it says.
19' MR. GUNDERSEN: I'm sorry, at a break or 20 something I'll just skim through it. I apologize.
21 CHAIR YOUNG: Okay. Then anything else on 22 the saltwater, salt service water? Judge Cole?
23 JUDGE COLE: Yes. Just a couple of 24 questions and comments. You didn't say anything about 25 the intake system. All this was about the discharge NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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754 1 system and in the intake system the pipes were 2 replaced in 1993, is that correct?
3 MR. SULLIVAN: That's correct.
4 JUDGE, COLE: Why were they replaced?
5 MR. SULLIVAN: They we-re replaced because 6 of -- to address service life of the pipes. They had 7 reached the end of their service life and they were 8 replaced with titanium piping as stated previously.
9 JUDGE ABRAMSON: What was the prior pipe?
10 MR. SULLIVAN: The prior pipe was carbon 11 steel rubber-lined.
12 CHAIR YOUNG: What's the last word?
13 MR. SULLIVAN: Carbon steel rubber-lined.
14 CHAIR YOUNG: Rubber-lined.
15 JUDGE COLE: So the same as in the other 16 system, same as in the discharge pipes?
17 MR. SULLIVAN: That's correct.
18 JUDGE COLE: And there were two pipes.
19 They were about the same size as the discharge pipes?
20 MR. SULLIVAN: About the same size. They 21 have to -- the flow going in has to equal the flow 22 going out, so they might have been a little bigger.
23 JUDGE COLE: So their service life was 24 some time just pre-1972 to 1993, is that correct?
25 MR. SULLIVAN: That's correct.
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755 1 JUDGE COLE: So about what, 22 years-, 21 2 years?
3 MR. SULLIVAN: That's correct.
4 JUDGE COLE: And the expect life is, as 5 you said before, 20 years?
6 MR. SULLIVAN: Approximately 20 years.
7 JUDGE COLE: What problem did you observe 8 in those pipes at the time that they were replaced, do 9 you recall?
10 MR. SULLIVAN: I don't recall.
11 JUDGE COLE: You were responsible for 12 let's see -- Mr. Woods, right?
13 MR. WOOD: Yes.
14 JUDGE COLE: You were responsible for the 15 work on the titanium pipe that replaced that, correct?
16 MR. WOOD: Yes, I was one of the field 17 engineers on site when the titanium pipe replacement 18 was going on.
19 JUDGE COLE: And why did they select 20 titanium?
21 MR. WOOD: I would say because of its 22 inherent corrosion-resistant properties. I wasn't on 23 the design team. I was on the installation team.
24 JUDGE COLE.: All right, sir. Did you 25 observe how they installed and prepared that pipe?
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756 1 MR. WOOD: Yes.
2 JUDGE COLE: And what did they do?
3 MR. WOOD: The pipe was brought in, 4 flanged, sections, it was coated in the field 5 externally with a coating per specification M306 which 6 you do an inspection to make sure you have a good base 7 metal, clean it up, degrease it and prime it with a 8 primer and then a field application would be field 9 wrapped with coal tar tape, spiral tape the entire 10 length. When that was complete, you would do a 11 holiday test, looking for any voids in the wrap with 12 a high voltage tester which would provide an arc that 13 you could see, a bright arc, also hear the arc snap.
14 When that was done, it would be placed in 15 the trench, bolted together and then the same primer, 16 cleaning and primer and tape would be applied over 17 each joint between pipe sections. And again, after 18 that was done, it would be tested in the trench to 19 make sure there were no holidays or voids.
20 JUDGE COLE: What sort of preparations did 21 they make in the trench prior to putting the pipe in 22 it?
23 MR. WOOD: The trench would be prepped 24 with engineered fill material at the base and 25 compacted. The pipe would be set down in place and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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757.
1 then engineered fill would be placed, clean sand or 2 fill would be placed around the pipe, compacted, and 3 then at six-inch lifts the engineered fill would also 4 be compared and every other lift was tested for 5 compaction.
6 JUDGE COLE: Did they use that procedure 7 for all the pipes that were installed in the salt 8 service water system?
9 MR. WOOD: To my knowledge, yes.
10 JUDGE COLE: And I noticed that all of the 11 pipes in the systems that we're concerned with, the 12 salt service system and the condenser service water 13 are located seven to ten feet below the service 14 system. Is that correct?
15 MR. WOOD: That is correct.
16 JUDGE COLE: And where is the ground water 17 level with respect to that?
18 MR. WOOD: The ground water level is 19 approximately 17 feet below the surface.
20 JUDGE COLE: Is that significant with 21 respect to assisting in minimizing corrosion?
22 MR. WOOD: Yes.
23 JUDGE COLE: How is that?
24 MR. SPATARO: As you realize, the action 25 of corrosion is electrochemical in nature and so I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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758 1 have to have an electrolyte. The piping is buried at 2 a depth of approximately seven to ten feet and the 3 water table is 17 feet, appreciably lower than the 4 piping itself.
5 There is no way that the piping could be 6 immersed in the ground water, thereby creating a 7 situation where you would have a corrosion cell 8 generated for any length of time.
9 JUDGE COLE: Is the ground water table 10 artificially lower or was that just where it stayed 11 with the drainage system you had?
12 In other words, do you have a pumping 13 system to keep the ground water level?
14 MR. WOOD: No, we do not have a pumping 15 system.
16 JUDGE COLE: So it's gravity drained.
17 MR. WOOD: That would be natural, that's 18 correct.
19 JUDGE COLE: I have no further questions 20 on the salt service water system.
21 Well, just one. The intake, you have a 22 traveling screen at the intake. Is that correct?
23 MR. WOOD: Yes, that's correct.
24 JUDGE COLE: What is the size of the 25 opening in that screen?
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759 1 MR. WOOD:, Three-eighths mesh.
2 JUDGE COLE: And how is it cleaned?
3 MR. WOOD: It's a traveling screen that 4 rotates and then there's water nozzle sprays that 5 spray on the screen to clean the debris off.
6 JUDGE COLE: Have you had any problems 7 with that clogging, because it would be a safety 8 issue, if you're not letting any water in.
9 MR. WOOD: We have had incidents where the 10 screens have become clogged with debris. We have 11 alarm response procedures and off-normal procedures 12 that provide specific guidance to the operators on the 13 actions to take, if we do have intake structure 14 clogging.
15 JUDGE COLE: How often do you have those 16 kinds of problems?
17 MR. WOOD: In my experience, going back to 18 when I was licensed as an SRO, until present day, 19 twice.
20 JUDGE COLE: How many years ago were you 21 licensed as an SRO?
22 CHAIR YOUNG: Senior Reactor Operators?
23 MR. WOOD: Yes. That goes back to 1996.
24 JUDGE COLE: All right, sir. Thank you.
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.760 1 get over to you. Traveling screen simply means that 2 it rotates?
3 MR. WOOD: -Yes.
4 CHAIR YOUNG: -Okay, andholiday test, that 5 is a test that looks for voids in the coating? Is 6 that all that means or is there some other --
7 MR. WOOD: Yes, it looks for voids in the 8 coating. Areas that wouldn't be covered are. pinholes 9 or things of that nature.
10 CHAIR YOUNG: Does it refer to any tests
- 11. that does that or is it a specific method?
12 MR. WOOD: It's a specific method using 13 high-voltage.
14 CHAIR YOUNG: You had -- go ahead.
15 JUDGE COLE: You were talking about the 16 packing around the pipe and you used a cold tar tape, 17 35 millimeters, the testimony indicated? A 7 18 millimeter film backing and 28 millimeters of 19 adhesive, do you mean mill or did you mean 20 millimeters?
21 MR. WOOD: I believe that's mills.
22 JUDGE COLE: Okay.
23 CHAIR YOUNG: So that's 7/28 thousandths 24 of an inch.
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761 1 28 millimeters of adhesive. All right, thank you..
2 CHAIR YOUNG: All right, actually I saw --
3 go ahead.
4 MR. GUNDERSEN: Thank you. It's been 5 suggested in rebuttal to my testimony that I recommend 6 ripping up the yard and doing an external visual exam 7 of all of the service water pipe. I reread my 8 testimony and I haven't suggested that. I think it's 9 probably not even safe because you always run the risk 10 of hitting the pipe and causing damage.
11 You can in places- along the pipe apply 12 cathodic protection. You don't have to do the whole 13 pipe, go down and put appropriate anodes and cathodes 14 with a rectifier in the building that sends a DC 15 current out and it doesn't require ripping up the 16 whole pipe which would cathodically protect that pipe.
17 CHAIR YOUNG: When you say cathodic, could 18 you explain that a little bit more? Are you talking 19 about a test or --
20 MR. GUNDERSEN: Well, boats have it.
21 Frequently, you'll put a little hunk of zinc on the 22 back of your motor on a boat and --
23 JUDGE COLE: A sacrificial anode?
24 MR. GUNDERSEN: Yes, it's a sacrificial 25 component that attracts the electrical ions as opposed NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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762 1 to having them attract the carbon steel pipe. And 2 you've set up a potential between a plus and a minus 3 and it just -- it's kind of like inviting them to one 4 location as opposed to having them attach themselves 5 to the --
6 CHAIR YOUNG: Like a lightning rod?
7 MR. GUNDERSEN: The opposite of a lighting 8 rod, yes. Yes. It's like an anti-lighting rod, 9 right. But the British Navy invented it in the 1700s 10 to protect the copper lining on their boats, and 11 although it's an old technique. But the modern 12 technique would be to apply and GALL suggests that 13 cathodic protection is a good idea for this type of 14 pipe, especially carbon steel, that at intervals, 15 depending on the layout and my guess would be every 30 16 or 40 feet, you go down and apply and there's only 200 17 feet, so maybe 10 small holes where you would apply 18 the cathodic protection and you -- that would go a 19 long way to assuring that you don't get rust from the 20 inside -- from the outside in.
21 I mean this morning we talked about coming 22 from the inside out, but should abrasion affect that 23 outside liner, GALL suggests that cathodic protection 24 is a good idea and I would agree. If it were a new 25 plant, you would cathodically protect the whole pipe NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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763*
1 and I'm not suggesting that, but you can backfit --
2 it's called an impressed current cathodic protection 3 system by putting anodes and cathodes along the pipe 4 at intervals of about 40 feet so maybe five on each 5 pipe would go a long way to protecting the pipe from 6 outside in.
7 I was speaking to Dr. Ahfield at break and 8 he also felt that we could put monitoring wells on the 9 outside and should saltwater, because the water table 10 is so low, if the pipe -- and the pipe has saltwater 11 in it, if the pipe were to leak the conductivity would 12 change dramatically because it is salt water and Dr.
13 Ahfield felt you could pick that up in a simple test 14 in a pretty simple monitoring well.
15 Can I pass it down?
16 CHAIR YOUNG: But before you pass it down, 17 let me just ask one question. I had written in my 18 notes a reference to GALL report, Section 11M-28. Is 19 that related to this or to the condenser? Is that 20 what you were just referring to?
21 MR. GUNDERSEN: Yes. We have it here, but 22 yes. May I put it forward? It's that -- it is --
23 that's the reference, yes.
24 CHAIR YOUNG: To the cathodic protection?
25 MR. GUNDERSEN: Yes.
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764 1 CHAIR YOUNG: Any objection?
2 JUDGE ABRAMSON: Isn't the whole GALL 3 report in evidence?
4 MS. LAMPERT:. No. May I have the 5 opportunity to present it as an exhibit?
6 CHAIR YOUNG: Any objection to that?
7 MR. LEWIS: No.
8 CHAIR YOUNG: No objection, okay.
9 And that will be official exhibit 71, I 10 think.
11 (Pause.)
12 (Whereupon, the above-referred 13 to document was marked as 14 Exhibit 71 for identification 15 and was received in evidence.)
16 All right, are you Dr. or Mr.? I got that 17 wrong this morning. You're Mr. --
18 DR. AHFIELD: I'm Dr. David Ahfield.
19 MR. LEWIS: May I ask for clarification?
20 I'm not sure Dr. Ahfield is responding to any of the 21 questions -- is this just new testimony or is this in 22 response to something somebody has raised as an issue?
23 CHAIR YOUNG: We asked a question if there 24 was any follow up or anything that we might have 25 overlooked with regard to the saltwater service system NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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765 1 and I believe this was in response to that, following 2 up on--
3 MR. LEWIS: What I heard earlier -- I 4 believe before the break was questions directed to Mr.
5 Gundersen regarding suggestions he might have perhaps, 6 if that's not too strong a way to put it, for 7 additional inspections or different techniques and so 8 on. So following up in that spirit, I'd like to just 9 interject that monitoring wells are another way to 10 determine if leaking is occurring and then, of course, 11 if you determine that, then you have an incentive to 12 fix the leak. And we heard that there's a water table 13 beneath this particular piping system. I think Dr.
14 Cole's questions were directed to the intake pipe.
15 I'm not sure about the out-take pipe.
16 JUDGE COLE: I think they said they're all 17 buried seven to ten feet underground.
18 DR. AHFIELD: Okay.
19 JUDGE COLE: And the groundwater table is 20 at 17 feet below the surface.
21 DR. AHFIELD: Correct, okay, and that 22 probably varies over the site, although we have very 23 little data on the groundwater table available to us 24 anyway and probably varies seasonally. of course.
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766 1 likelihood. And in fact, we have a limited amount of 2 sampling data that indicates that it 'is fresh water.
3 so if you had a leak of salt wa-ter that mixed with 4 that ground water, you would be. able to detect that 5 quite readily and inexpensively with a set of 6 strategically placed monitoring wells.
7 And that sampling could be done at a 8 typical installation, do samplings of this sort 9 quarterly, that is four times a year, so -- and if 10 we're looking at a situation of a leaking pipe with 11 'water traveling through, unsaturated soils to the 12 water table and then migrating laterally,. being picked 13 up by a monitoring well, you could get detections 14 again if they're well placed within weeks or months 15 after initiation of the leak, depending on rates of 16 groundwater flow and other factors. And again, we 17 don't have that much information about the site to be 18 more specific than that.
19 That was my comment at this point.
20 CHAIR YOUNG: I don't know if either of my 21 colleagues want to ask this, but can you speak to how 22 that would be related to the timing of inspections and 23 the rate at which you could have a leak that would 24 ultimately compromise the pipes so that if you had an 25 earthquake it would cause the pipe to crumple or is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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767 1 that outside your area?
2 DR. AHFIELD: Yes, that's edging outside 3 my area. That. is the behavior of the rate at which 4 the corrosion occurs in the pipe is outside my area.
5 But if a small hole were to be initiated 6 by some mechanism and then grow at some rate, the 7 notion is that the groundwater monitoring wells would 8 -- if properly placed again and monitored with some --
9 monitored with reasonable frequency, would pick up a 10 signal from that leak fairly soon after it was 11 initiated.
12 CHAIR YOUNG: So that then there could be 13 an inspection prior --
14 DR. AHFIELD: -- within say months or a 15 year on that time scale.
16 CHAIR YOUNG: Okay. Any follow up to 17 that?
18 MR. LEWIS: I have two follow-up 19 questions, generally; one on the new exhibit and one 20 just to make sure that some testimony before relates 21 what Judge Cole asked is complete, if I could ask 22 those questions.
23 JUDGE COLE: Please.
24 MR. LEWIS: Gentlemen, Judge Cole asked 25 you to describe the process for backfilling the hole NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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768 1 where the saltwater, sal t service water piping was 2 installed and you discussed putting in the soil and 3 compacting. Isn't it also true that that entire area
- 4. above thle intake and discharge piping is blacktopped?
5 MR. SULLIVAN: That's correct.
6 MR. LEWIS: And that black top was 7 restored after the piping was installed?
8 MR. SULLIVAN: That's also correct.
9 MR. LEWIS: And then Mr. Cox, Pilgrim 10 Watch has introduced this section of the GALL report.
11 Could you explain how this -
12 CHAIR YOUNG: Can everyone hear?
13 MR. LEWIS: Mr. Cox, Pilgrim Watch has 14 introduced a section of the GALL Report, Section 11-15 M28, buried pipes and tank surveillance. Could you 16 explain how this program relates with the other GALL 17 guidance on the buried pipe and tanking program?
18 MR. COX: The M-28 program is one of the 19 aging management programs listed in Chapter 11, along 20 with the M-34 program which is the one that we have 21 credited for the Pilgrim license renewal application.
22 If you go to the tables in the GALL Report in the 23 earlier chapters, for buried piping they will refer to 24 one of -- either one of these two programs as an 25 acceptable method to manage the aging effects on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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769 1 buried pipe.
2 CHAIR YOUNG: They're alternatives.
3 MR. COX: They are alternatives. It. is 4 not a requirement that you have both. It says either 5 one is acceptable.
6 CHAIR YOUNG: Is there any discussion on 7 recommending both would be better than either one or 8 is it just simply an alternative?
9 MR. COX: I believe it's just an item in 10 the table that says you can use M-28 or M-34.
11 DR. DAVIS: I- wrote both of those 12 programs, so I have some familiarity with them.
13 JUDGE ABRAMASON: You want to tell us what 14 they mean?
15 CHAIR YOUNG: Speak up, please.
16 JUDGE ABRAMSON: And get closer again.
17 DR. DAVIS: okay. M-28 I wrote before we 18 started Calvert Cliffs, the first plant. And they 19 objected very strongly to using that program. And 20 they said the reason that they objected was in their 21 rectifiers would be safety-related --
22 CHAIR YOUNG: Explain rectifiers before 23 you go on.
24 DR. DAVIS: It's a battery -- like a 25 battery. It supplies a DC charge to the pipe through NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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770 1 an anode. There's. no cathodes involved. It' s just 2 anodes. And you probably only need one.
3 JUDGE COLE: But they would still call 4 that cathodic protection?
5 DR. DAVIS: Yes,- and what you're doing 6 basically is you're setting up so you're like plating 7 the pipe so that iron cannot . go into solution 8 thermodynamically. It can only plate, if there's any 9 iron -- it's possible, but it would stop corrosion.
10 They were concerned that if they used a 11 rectifier or put the rectifier in a safety-related and 12 it went down for some reason they would go into a 13 limited condition of operation and they would have to 14 shut down the plant because the rectifier failed.
15 JUDGE COLE: And the leads, too, right?
16 DR. DAVIS: Right, right. So we 17 negotiated with the NEI on what different program to 18 come up with and I interviewed the people in the 19 industry and I said how often do you normally look at 20 your buried piping? How often do you do maintenance?
21 And they said about every five years on average. I 22 talked to quite a few people so I wrote the alternate 23 program, M-34 and allowed them to do the visual 24 inspection, rather than using cathodic protection.
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771 1 very extensively, particularly on cross-country 2 pipelines, oil and gas, slurry, a-ll different kinds.
3 It's. fairly easy to apply cathodic protection in that 4 situation.
5 -To backfit cathodic protection on a 6 nuclear power plant is a very dangerous practice 7 because of something that we call stray current 8 corrosion. What happens is you have a complete 9 circuit from the rectifier sends the current to the 10 anode, the anode sends it to the pipe, and then it's
-11 got to somehow return back to the rectifier. And it 12 likes to take the path of least resistance, so if it 13 sees another pipe in the area it will go to that pipe 14 and it will put a hole right through that pipe in a 15 matter of weeks.
16 And so what you have to do when you 17 originally design the cathodic protection system, you 18 have to take all that into consideration. You have to 19 know where every single pipe is on your facility and 20 then you have to bond those together and that's 21 extremely difficult to do --
22 CHAIR YOUNG: Bond what together?
23 DR. DAVIS: You have to have an electrical 24 bond between the pipes so that the current won't go 25 through. the soil and cause corrosion. It will go NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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772 1 through the lead. So to backfit and use cathodic 2 protection is -- can be extremely dangerous. You have 3 to be extremely careful when you do that.
4 So to dat e, nobody has used M-28.
`5 Everybody has used some alternative program and most 6 of them have used M-34.
7 JUDGE COLE: Sot hat's -why they're not 8 using cathodic protection at this plant?
9 DR. DAVIS: They're not taking credit for 10 it, if they are using it, and I don't believe they're 11 using it.
12 CHAIR YOUNG: Okay. Anything further?
13 All right, then let's -- what's your 14 question?
15 MS. LAMPERT: I noticed that Judge 16 Abramson said in regard to the one time inspection 17 program that it would occur in the next four years.
18 My understanding of reading the aging management 19 program requirements is that a one-time inspection can 20 occur, will occur once in the ten-year period. That 21 would be between 2002 and 2012. And so I wanted to 22 have assurance, and then I'll follow up on that that 23 they're not crediting inspections that they did in 24 2002, 2003, 2004, and also to bring up the point if 25 they are doing their one-time inspection in the next NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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773 1 four years, that would be after you made the decision 2 on whether the aging management program should be 3 supplemented, so you would not have had the benefit of 4 looking at how thorough the inspection was, what the 5 results of that inspection were to see whether it 6 would serve as a more current baseline to judge 7 whether there should be more frequent inspections or 8 what have you.
9 And also, it disallows any public input 10 really on the process because the deal would have been 11 done, so to speak, before we had the opportunity to 12 look at what they inspected and what the results were, 13 if you understand what I'm saying.
14 So I'd like to know (a) when they're going 15 to do these or have they, what's been credited and how 16 your role really fits into this?
17 CHAIR YOUNG: First, can you address the 18 timing issues and then to the extent you can answer 19 the remainder of it, go ahead. that may be also 20 something for argument in your ultimate proposed 21 findings of fact and conclusions of law. But go 22 ahead.
23 MR. SULLIVAN: There were a lot of 24 questions there, so I'd like to go back and just 25 clarify some of the programs because I think we're NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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774 1 crossing boundaries here and confusing different 2 programs.
3 The inspections on the interior of the 4 pipe were put in place -- that requirement was put in 5 place well in advance of any aging management program.
6 Those requirements were put in place when we put the 7 cured-in-place pipe liner inside those piping systems.
8 So that question of when did we decide to do it, is it 9 adequate? We always have the responsibility to ensure 10 the safety and safe operation of the plant.
11 So in ten years from when those systems 12 went in, they'll be inspected and for one piping 13 system it's in 2011 and one it is after the extended 14 license period or after the initial license period in 15 2013, assuming that the license renewal gets approved.
16 Now I'm not sure I understood any of the 17 other questions that were in there, so if you could 18 ask those again.
19 CHAIR YOUNG: Did that respond to the 20 questions on timing?
21 MS. LAMPERT: Okay, so could you repeat 22 exactly what date you're inspecting what and if it's 23 appropriate and you feel it's relevant and what are 24 you inspecting? Are you looking at welds? Are you 25 looking at a part of a spool or what percent? What is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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775 1 your plant?ý What are you going to look at on what 2 date? That's -- my linear mind is trying to get this 3 focused.
4 CHAIR YOUNG: To the extent you can 5 clarify, go ahead.
6 MR. SULLIVAN: When you say one-time 7 inspection, we do a one-time inspection to verify the 8 thickness of the chemistry program. That would be on 9 the end side of the condensate piping. It really is 10 not applicable to the salt service water piping. We 11 do the -
12 CHAIR YOUNG: So anything that would be 13 called the one-time inspection is not related to the 14 salt service water, is that right?
15 MR. SULLIVAN: That's correct.
16 MS. LAMPERT: So you won't inspect --
17 CHAIR YOUNG: So the inspection for the 18 salt service water --
19 MR. COX: The external surfaces of the 20 salt service water system are subject to the buried 21 piping and tanks inspection program and that's the 22 inspection that will be done prior to entering the 23 period of extended operations, between now and 2012.
24 And that inspection is intended to verify the general 25 condition that the piping is coated the same on all NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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776 1 portions of it, exposed to the same environments so 2 that is intended to be a sample inspection that is 3 representative of all of the coatings on the buried 4 piping.
5 JUDGE COLE: That's for the external?
6 MR. COX: That's for the external.
7 JUDGE COLE: Of the SSW system.
8 MR. COX: That's correct.
9 JUDGE'COLE: Now what about the internal?
10 I think what we heard is that you've put this epoxy 11 coating in. And you agreed at that point under your 12 on-going operation maintenance programs. that at the 13 ten-year point you would inspect those from the 14 inside, with a visual inspection. Those two dates are 15 2011 and 2013 for the two respective loops. Is that 16 correct?
17 MR. COX: That's correct.
18 CHAIR YOUNG: And then your question .that 19 I think probably goes more to argument to us in your--
20 MS. LAMPERT: Yes, I think it does. I was 2.1 just bringing that point forward because it wasn't 22 clear for the external, the required external 23 inspection in the ten years prior whether it could 24 occur in 2002, 2003, 2004, and then the concern that 25 the required external inspection in the first ten NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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777 1 years could be in 2019, so you could conceivably have 2 a long period of time or you could have a short period 3 of time.
4 JUD~GE ABRAMSON: Let's try to ti~e it down.
5 CHAIR YOUNG: Plese.
6 JUDGE ABRAMSON: You're doing external 7 inspection on the salt water pipes in what years?
8 MR. COX: We are doing an inspection one 9 time between now and 2012 and we're doing a second 10 inspection during the first ten years, the period of 11 extended operation, those are between the years 2012 12 and 2022.
13 JUDGE ABRAMSON: So could it be you could 14 do the one-time inspection now and do the other one in 15 2622? It could be that long?
16 MR. COX: That's correct and we have no 17 plans to take credit for any inspections that were 18 done in 2003 to say that was the first inspection 19 within the first ten-year period..
20 JUDGE ABRAMSON: Right.
21 CHAIR YOUNG: All right, are we now 22 finished with the salt water service system?
23 Okay, then we'll sort of switch over to 24 another topic and Judge Abramson, do you want to 25 start?
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778 1 JUDGE ABRAMSON: Let's now take the same 2 process through the condensate storage system buried 3 pipes.
4 I'm going to start by looking at the 5 responses of the Applicant in their February 11th 6 filing responding to our particular questions.
7 I'd like you to elaborate a little bit on 8 your response to question C. We asked what's the 9 smallest leakage rate that could reasonably expect to 10 challenge the ability of the CSS system piping to fail 11 its intended safety function as relevant for license 12 renewal?
13 And the response was and I think this, to 14 me, is key --
15 CHAIR YOUNG: What page are you one?
16 JUDGE ABRAMSON: I'm on page three.
17 CHAIR YOUN\G: Three, okay.
18 JUDGE ABRAMVSON: Page three.
19 CHAIR YOUNG: We're talking about the 20 February 11th --
21 JUDGE ABRAMSON: February 11th responses.
22 CHAIR YOUNG: Page three, response C.
23 JUDGE ABRAMSON: Okay. And your first 24 comment was that at the outset no amount or rate of 25 leakage from the CSS buried piping could challenge the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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779 1 ability of the high pressure coolant injection in the 2 RCIC system to perform their intended functions.
3 Would you elaborate on that for us? What 4 I'm trying to understand is are you telling us that 5 those buried pipes are not, in fact, within the scope 6 because they're not ones that are required to be 7 operable under 54.4?
8 MR. SULLIVAN: Yes, sir.
9 MR. COX: Let me clarify that a little 10 bit. The scoping that we did for the license renewal 11 is done on a system basis. The reason we included the 12 CSS system is because of the connection not in the 13 buried piping, but in the reactor building where it 14 connects to the HPCI and the RCIC systems. That 15 section of the CSS piping could be relied upon to 16 provide seismic support to the safety-related systems.
17 So that's the reason it was included, not because of 18 anything that the buried section of piping - -not 19 because of any function performed by the buried 20 piping.
21 It was done at a system level so the 22 system is in scope. That doesn't necessarily mean 23 that each segment of piping performs an intended 24 function and that is the case for the buried piping.
25 It does not perform an intended function.
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780 I JUDGE ABRAMSON: So the bottom line here 2 is neither one of those pipes, buried piping systems 3 is within the scope of this proceeding, is that right?
4 MR. COX: Again, we said the systems run 5 the scope of license renewal and they contain 6 radioactive liquid, so from that standpoint, one could 7 say, that they are within the scope of this proceeding.
0 JUDGE ABRAMSON: Well, help me through 9 54.4 then. So you're saying the system itself is 10 relied upon to remain functional because a piece of 11 the piping is relied upon to provide structural 12 support during seismic event?
13 MR. COX: That's correct.
14 JUDGE COLE: Is either of the buried pipes 15 relied upon in any way for this series of events that 16 are described in 54.4?
17 MR. COX: No, it is not.
18 CHAIR YOUNG: Isn't there some kind of 19 backup or redundancy issue here? Is this related to 20 the TORUS being the source of the water for the -
21 just for the record and everyone that's here, RCIC is 22 reactor core isolation cooling and the HPIC is high 23 pressure coolant injection system.
24 MR. SULLIVAN: Each one of those systems 25 has a water supply from the condensate storage tank.
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781 1 The condensate storage tank is a nonsaf ety- related 2 structure. The piping that runs from there to the 3 reactor building in our auxiliary bay is not relied 4 upon, for those systems to operate. Those systems have 5 isolation valves that separate that water supply from 6 the TORUS and automatic valves, motor operated valves 7 that will be opened in order to have sufficient water 8 -supply to meet the intended functions of those 9 systems.
10 CHAIR YOUNG: Okay, I guess I'm a little 11 confused now.
12 I thought that the TORUS served a backup 13 function to the condensate storage system water. Did 14 I get that backwards or --
15 MR. COX: I think the terminology that 16 we've used is that the preferred source is the 17 condensate storage system. That's typically a higher 18 quality of water so just for long-term cleanliness of 19 the system, we prefer to use that source.
20 CHAIR YOUNG: Right, I remember your 21 testimony in that.
22 MR. COX: The primary source or the 23 assured source, the source that you rely on in the 24 accident is the TORUS. It's safety related. It's 25 seismically qualified. The condensate storage tank NEAL R. GROSS
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782 1 itself, I'm not even talking about the piping, but the 2 condensate storage tank itself is non-seismic, so it's 3- not available to you in the seismic event.
-4 CHAIR YOUNG: So the reason you don't 5 count on it is not because - -it's a primary source 6 and the TORUS is secondary. And I may not be using 7 the right terminology here, but just from my 8 perspective. You don't count on it because it doesn't 9 have the structural characteristics that would allow 10 that to be used?
11 JUDGE ABRAMSON: It's. not safety 12 qualified.
13 MR. COX: Right, right. We go by 14 preferred source and assured source.
15 JUDGE ABRAMSON: So if we understand this 16 correctly, the assured source is the one that's safety 17 qualified and you're entitled to rely on it for your 18 safety analysis in these events and that is the TORUS 19 in this case.
20 MR. COX: That's correct.
21 JUDGE ABRAMSON: So neither of these pipes 22 is relevant for that analysis?
23 MR. COX: That's correct.
24 CHAIR YOUNG: So you use them -- and the 25 reason you use them is because the water in them is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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783 1 higher quality water, but in the event of a safety --
2 a severe accident, the safety source that you rely on 3 is the TORUS.
4 MR. COX: That's correct.
5 CHAIR YOUJNG: And in that event if 6 something happened is there -- is the condensate 7 storage system a back up to it or --
8 MR. SULLIVAN: No, the condensate storage 9 tank is assumed to go away in a seismic event.
10 CHAIR YOUNG: So the TORUS is the -
11 MR. SULLIVAN: Is the source of water.
12 CHAIR YOUNG: Okay.
- 13. MR. SULLIVAN: That's correct.
14 JUDGE COLE: So the condenser storage 15 system has no safety function?
16 MR. SULLIVAN: That's correct.
17 JUDGE COLE: And there's only one pipe, 18 isn't there?
19 MR. SULLIVAN: There was one pipe that 20 runs down and then it branches off.
21 JUDGE COLE: Sixty-four feet of 18-inch 22 pipe?
23 MR. SULLIVAN: That sounds right.
24 JUDGE ABRAMSON: Plus or minus.
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784 1 of radioactive water in the TORUS?
2 JUDGE ABRAMSON: It's not a buried pipe.
3 CHAIR YOUNG: It's not buried, okay.
-4 JUDGE ABRA.MSON: Those are my questions on 5 this.
6 JUDGE COLE: There is radioactivity in the 7 condenser storage system. What is the source of that 8 radioactivity?
9 MR. SULLIVAN: The source of that 10 radioactivity is that serves as a makeup supply of 11 water to -- for our steam cycle and the water in our 12 steam cycle runs through the reactor, becomes 13 contaminated and then the CST serves, condensate 14 storage tank, and it serves as a make up in storage 15 volume.
16 JUDGE COLE: And what are the principal 17 isotopes involved, radioisotopes?
18 MR. SULLIVAN: I can't answer that. it 19 might be in there.
20 JUDGE COLE: But if it's. pretty high 21 quality water, would it be tritium and maybe nitrogen-22 16?
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785 1 primary system and from that standpoint it's -- the 2 corrosive items, it could cause cracking and corrosion 3 are minimized by the water treatment systems that 4 apply to that.
5 JUDGE COLE: How hot is it?
6 MR. COX: How hot temperature wise?
7 JUDGE COLE: Radioactivity wise.
8 JUDGE ABRAMSON: You would not want to 9 drink it or shower in it..
10 MR. SULLIVAN: We will have to consult 11 with some people in the audience and answer that 12 question after a break.
13 JUDGE COLE: Okay, I just wonder, I mean -
14 - most of it is buried below, but you've got this 15 275,000 gallon tanks, two of them there.
16 By the way, aren't they partially 17 submerged?
18 MR. SULLIVAN: No, they're not.
19 JUDGE COLE: Well, if the pipe is coming 20 out of them are seven to ten feet below the ground, 21 then at least or seven to ten feet of those tanks are 22 below ground.
23 MR. COX: The tanks are setting there are 24 on the surface and the pipes run down seven feet from 25 the bottom of the tank.
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786 1 JUDGE COLE: Oh, they come out of the 2 bottom of the tank.
3 MR. COX: That is correct. Yes. The 4 tanks are accessible. I can't give you a good feel 5 for the radioactivity, but from a -- you can walk up 6 next to it without violating any limits.
7 JUDGE COLE: So the concrete walls are 8 thick enough.
9 MR. COX: There are no concrete walls.
10 JUDGE COLE: In the CST tanks there are.
11 Aren't they concrete?
12 MR. COX: No, it's a steel lined tank.
13 JUDGE COLE: Oh. I guess I was looking at 14 the CST and I keep think that being a civil engineer, 15 1 think C is concrete.
16 (Laughter.)
17 JUDGE ABRAMSON: And S is sludge.
18 (Laughter.)
19 MR. COX: I think it might be worth noting 20 that there's not a lot of -- you're not filling this 21 tank with water from the reactor coolant system.
22 You're using it to reject small amounts of water 23 periodically if the condenser level ever gets too 24 high. And that's probably a fairly rare occurrence 25 because normally you're making up to the primary NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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787 1 system, the feedwater system from the tank to make up 2 for any leakage in the secondary plant.
3 JUDGE COLE: I understand the condenser 4 storage tanks, the level fluctuates between -- you try 5 to keep it at 30, is that correct?
6 MR. SULLIVAN: Try to keep it greater than 7 30.
8 JUDGE COLE: And how high can it go?
9 MR. SULLIVAN: Thirty-eight feet is our --
10 JUDGE COLE: What would cause it to 11 fluctuate between 30 and 38 and does the operator know 12 -- do that? Or is it an automatic operation?
13 MR. SULLIVAN: Well, the fluctuation is 14 caused just automatically as the condenser maintains 15 a certain volume of water within the condenser. If 16 the level drops and we have to take on some make up 17 water, then that would cause the level to raise and at 18 the same time you're drawing water down as Alan 19 discussed for normal make up for the steam cycle.
20 JUDGE COLE: And you say that happens 21 automatically?
22 MR. SULLIVAN: Yes, it does.
23 JUDGE COLE: Or does the operator do that?
24 MR. SULLIVAN: That -- the surge volume 25 from the condensate system happens automatically.
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788 1 It's monitored every -- once very four hours by the 2 operator.
3 JUDGE COLE: And what would the normal 4 fluctuation be over a four-hour period?
5 MR. SULLIVAN: About .2 feet possibly.
6 JUDGE COLE: So if it were to go 7 considerably more than that, somebody would know?
8 MR. SULLIVAN: Yes, they would.
9 JUDGE COLE: All right, *thank you.
10 MR. COX: If I could clarify just a little 11 bit, the normal mode of operation would be to use that 12 tank from a period of probably several days where you 13 would have a gradually decreasing level and then you 14 would -- the operator would manually initiate make up 15 to bring the level back up to the 38 feet.
16 JUDGE COLE: Thank you.
17 CHAIR YOUNG: Let's go to the Intervenor 18 next and then the staff, unless the staff wants to go 19 ahead first.
20 Normally, we would go in the order.
21 Okay.
22 JUDGE ABRAM4SON: Before we do that, since 23 the key to my question was whether or not these buried 24 pipes are necessary, and therefore within the scope 25 necessary for safety and therefore within the scope NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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789 1 and the Applicant has said no, they're not. I'd like 2 the staff to advise us whether to concur or disagree 3 with the Applicant's position.
4 MR. COX: I concur with the Applicant's 5 position.
6 CHAIR YOUNG: Do you have any follow up to 7 that? Do you --
8 MR. GUNDERSEN: I agree with the Applicant 9 that the condensation storage tank is not seismic and 10 in the event -- but the condensate storage tank still 11 is the preferred way if there were a nonseismic 12 initiated event and you were drawing water through it, 13 you would prefer to use the condensate storage tank.
14 So a seismic failure of that tank is protected by 15 other backup sources.
16 I think though when the issue gets down to 17 -- the piping is already in the order and are you 18 suggesting it go out of the order, is that the 19 question?
20 JUDGE ABRAMSON: The response that we had 21 from the Applicant in several instances and the 22 response that we had ab initio I think from the staff 23 was that these pipes are outside the scope of this 24 hearing and so I'm trying to clarify if they are or 25 are not. And we've been discussing them. We've been NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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790 1 examining them. We've been considering them, but it's 2 fundamental. If they're outside they scope, they're 3 -outside the scope. So the question is what brings 4 them inside the scope? And for them to be brought 5 inside the scope, they have to be required under 10 6 CFR 54.4 and what I hear the staff telling us is 7 they're not and I hear the Applicant telling us 8 they're not. So if you have evidence that they are, 9 we'd love to hear it.
10 MR. GUNDERSEN: I have one thing I think 11 you should consider as part of that. A hole in the 12 bottom of the tank or a hole in the pipe, it's a 13 stainless steel pipe this-time, not a carbon steel 14 pipe, but a hole in that pipe would introduce 15 contamination into the pipe which then could get 16 injected forward through those pumps, so that the 17 safety related system -- so in a normal, if there's 18 such a thing, in a normal accident where the preferred 19 source was that tank, should there be a hole in that
- 20. you're going to be injecting contaminants from the 21 ground water into the system. The pumps on the first 22 system were before this tank, so if there was a 23 collapse it could cause a back pressure.
24 This system is the opposite. The pumps 25 are beyond this, so that it is a negative pressure if NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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791 1 you will, pulling that water out and into the reactor 2 which if there's a hole in that pipe, then pulls 3 contamination from the soil --
4 JUDGE ABRAMSON: Right, and it could 5 contaminate the reactor and that would be obviously a 6 concern for on-going operations.
7 MR. GUNDERSEN: Back in the '70s I worked 8 at Northeast Utilities. The contamination of the 9 reactor was not just an operating concern. We had a 10 chloride intrusion incident which was one of the 11 famous early accidents in the history of nuclear 12 power. We contaminated the condensate storage tank 13 with chlorox which we then pumped forward into the 14 reactor and failed all the nutrient sources and there 15 was cracking in the stainless and caused the isolation 16 condenser to'develop cracks, serious cracks. Because 17 we were pulling chlorides that had been put into the 18 condensate storage tank back into the system, so it's 19 not -- it's safety-related concern in that the 20 contamination from those systems being drawn back into 21 the reactor, stainless steel at 500 degrees does not 22 like contamination so that my concern is that in a 23 non-seismic event when you're going to want to use 24 that as a normal source, if there's a hole in that 25 underground pipe that then pulls contamination into NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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792 1 it, you inject that contamination into the reactor.
2 CHAIR YOUNG: Let me see if I can get some 3 clarification here and I guess I was a little 4 surprised by your testimony before. Because you do 5 say in your testimony and I think it's always been 6 said at the beginning that the condensate storage 7 system was one of the systems that's included within 8 the scope of license renewal and you. addressed that in 9 your application.
10 Mr. Gundersen has suggested that other 11 issues besides seismic issues might come into play 12 with regard to safety issues that would be related to 13 license renewal.
14 Was what you were -- what I understood you 15 to say earlier was that the reason that you don't rely 16 on the condensate storage system pipes for a safety 17 function is because structurally they don't qualify if 18 that's the right word, whereas the TORUS is.
19 Did that apply to all safety issues that 20 might arise non-seismic ones that could arise? And if 21 so, what? And if not, on what basis was this system 22 included in the application as one of the six systems 23 under 54.4?
24 MR. COX: Yes, I think that it is true 25 that you could have other events than a seismic. The NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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793 1 TORUS still remains the assured source. In fact, one 2 of the two systems that rely on this suction piping 3 has an automatic transfer to the TORUS when the level 4 gets low enough in the tank that the suction pressure 5 is threatened.
6 So the TORUS is always there, whether it's 7 a seismic event or not, the TORUS is always there and 8 it will always take over if you lose water from the
.9 condensate storage tank for any reason.
10 Again, for the scoping question, we -- I 11 feel like we were fairly conservative the way we did 12 scoping. We did it on a system basis which brought in 13 the whole system. We evaluated the system. We didn't 14 try to rule out specific parts of the system and say 15 this is not required. When we started getting into 16 this contention and we started examining the specific 17 functions of that individual section of buried piping, 18 that's the basis for this statement in our testimony.
19 It's not required for a design-basis event.
20 CHAIR YOUNG: So when you originally 21 included the system, you're saying there are other 22 parts of the system besides the buried parts that 23 would be relevant under the license renewal analysis 24 under 54.4?
25 MR. COX: That's correct. That was the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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794 1 conclusion that we reached, is that the parts of the
- 2. system that are directly connected to the valves that 3 interface with the reactor core isolation cooling 4 system -
5 CHAIR YOUNG: I*'m sorry. Back up and use 6 whole words. Maybe you just said it too fast.
7 MR. COX: The reactor core isolation 8 cooling system -
.9 CHAIR YOUNG: Reactor core. Okay.
10 MR. COX: And the high pressure coolin g 11 injection system. The interface valves that are 12 actually part of those systems are connected directly 13 to the condensate storage system piping, and that's 14 the reason it was included.
15 JUDGE ABRAMSON: And if there were an 16 event that threatened the buried piping, or threatened 17 the CST, would that threaten the integrity of these 18 parts that are connected to these valves in a way that 19 it could -- that it becomes necessary to rely on the 20 buried pipes and tanks from the CST for any of the 21 functions of 54.4?
22 CHAIR YOUNG: In other words, could they 23 impair the valves? Is that what you're --
24 JUDGE ABRAM4SON: Yes, is there something 25 that can happen here that we -- is there some scenario NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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795 1 whereby you're going to have to need these for safety?
2 MR. COX: No.
3 MR. GUNDERSEN: May I say one thing?
4 CHAIR YOUNG: Go ahead.
5 - MR. GUNDERSEN: I absolutely agree that 6 there's no scenario that would cause the -- if the 7 pipe were to fail, then they go to the -- but earlier 8 there was a statement that while it's not required, it 9 is preferred. And my concern is not degradation of 10 the type that would cause the pipe to fail. Unlike --
11 the cast iron pipe, I'm much more worried about from 12 that standpoint, but this pipe is stainless, and I 13 doubt would show that same pattern, but would show --
14 could develop a leak, and the source would then be 15 shown as Tritium in the groundwater, because probably 16 the single biggest isotope is Tritium. There might be 17 others, but certainly Tritium in the groundwater, so 18 this is a source that a monitoring well would pick up 19 well. But my concern is that given it's the preferred 20 way of cooling the plant when you turn on your HCIC 21 pumps or RCIC pumps, or whatever. You can introduce 22 contamination into the reactor that can make the 23 problem worse if there's a whole in the pump suction 24 pipe, which this is.
25 CHAIR YOUNG: Would that affect --
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796 1 MR. GUNDERSEN: So it's safety-related, 2 but it's not flow safety-related. It's a source --
3 the hole becomes a source of contamination --
4 JUDGE ABRAMSON: Well, let's turn to 54.4 5 to answer Judge Young's question, Mr. Gundersen. 54.4 6 says it's within the scope if it's relied upon to 7 remain functional during and following design-basis 8 events, or to maintain -- to insure certain functions, 9 integrity of the reactor coolant pressure boundary, 10 capability to shut the reactor down and maintain safe 11 shutdown, capability to prevent or mitigate 12 consequences of accidents that can result in certain 13 off-site exposures from serious accidents.
14 Does the kind of failure you're concerned 15 about implicate one of those events?
16 CHAIR YOUNG: In my --
17 MR. GUNDERSEN: First of all --
18 CHAIR YOUNG: Actually, let me just ask 19 mine in conjunction with that, another clarification.
20 Is what you're talking about an event that would lead 21 to shutdown in any case? So, if so, how is that 22 related to the --
23 MR. GUNDERSEN: Okay. My experience on 24 the sister unit to Pilgrim back in the 70s was 25 Millstone I, and chloride ions had got into the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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797 1 condensate storage tank, and were then pumped into the
-21 reactor. It made a minor problem severe. We lost 3 track of all our neutron monitors. Every single 4 neutron monitor in the plant failed in about 10 5 seconds.
6 JUDGE ABRAMSON: And what did you do?
7 MR. GUNDERSEN: The plant scrammed and 8 shut down for a year.
9 CHAIR YOUNG: So it would go into --
10 JUDGE ABRAMSON: It was costly, but what -
11 12 MR. GUNDERSEN: Yes. In that event, we 13 were lucky because the through wall cracks in the 14 stainless -- in the isolation condenser, we didn't 15 develop through wall cracks in the -- we had 16 significant cracks in the isolation condenser but not 17 through wall. We stopped the event soon enough that 18 it was only costly, but that didn't necessarily have 19 to happen, because -- so this is -- so to answer your 20 question, Your Honor, you said relied upon. I think 21 the --
22 JUDGE ABRAMSON: Yes, the language is --
23 MR. GUNDERSEN: Relied upon. I think if 24 you look at their operator's manuals, the preferred 25 source in the operator's manual, preferred source, so NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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798 1 what they're relying on as a preferred source is the 2 condensate storage tank. But the required source then 3 becomes the TORUS, so -
4 JUDGE ABRAMSON: Well, that -
5 MR. GUNDERSEN: Are they relying on it?
6 I think the operator's manuals have said hey, try the 7 condensate storage tank first, but remember it's not 8 seismic, and if you don't have suction or whatever, 9 you don't use the TORUS.
10 JUDGE ABRAMSON: Well, I think it's a 11 little -- it's not just relied upon. You've got to be 12 careful how you read this, and here's where a lawyer 13 might give you some advice. It says "relied upon to 14 remain functional during design-basis events." And 15 during design-basis events, is it not accurate that 16 you must rely on your assured sources? *That's what 17 you really rely on, that's what they're assured for.
18 In other words, yes, you might prefer to go somewhere 19 else, but when you're trying to make sure you can 20 handle a design-basis event, you have to make -- you 21 count on your assured source.
22 MR. GUNDERSEN: Yes, you count on the 23 assured source, but you may not use the assured 24 source, so I guess my -- the Applicant has already 25 said that they're going to try to use the condensate NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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799 1 storage tank. The operators would have no indication 2 of contamination through a leak, because whatever 3 monitors were in the CST would not pick it up, because 4 we're talking about the underground pipe, which is 5 then introducing contamination into the reactor, which 6 could cause, my experience, loss of neutron monitoring 7 and things like that.
8 JUDGE COLE: But the water level in the 9 tank is normally 30, 35 feet, and there would be 10 enough head pressure there where you wouldn't wind up 11 with negative pressure when you're pulling water out 12 of that tank system.
13 MR. GUNDERSEN: That was a question -- I 14 understand that. And I come back to the Green Lawn 15 stuff you put into your -- how does that get in? It 16 gets in through a Venturi-kind of effect, where you're 17 spraying your lawn.
18 JUDGE COLE: Right.
19 MR. GUNDERSEN: So I believe, my 20 experience shows that a hole would be drawn through on 21 a Venturi basis, even though the head is appreciable, 22 30 feet or so.
23 JUDGE COLE: With that much head, I doubt 24 that, but the operator would know if the water level 25 was down low enough where they would wind up with NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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800 1 negative pressure there, and create an effective 2 Venturi problem. Wouldn't the operator know by virtue 3 of the elevation readings which he has in his room?
4 MR. GUNDERSEN: Probably by the time it 5 got down to --
6 JUDGE COLE: So then he would know not to 7 use that as a source, and go to the --
8 MR. GUNDERSEN: I understand what you 9 mean. I don't know at what head a Venturi effect 10 would not occur in that pipe, and that's really --
11 JUDGE COLE: Depends on how --
12 (Simultaneous speech.)
13 MR. GUNDERSEN: I understand where you're 14 coming -- but I don't -- it depends on the size of the 15 hole, and the shape of the hole. But I think you 16 could introduce contamination into the system, which 17 could make a minor accident, if there's such a thing, 18 worse.
19 CHAIR YOUNG: So, and I'm maybe catching 20 up a little bit here, but the question about whether 21 any of the functions specified in 54.4, insuring the 22 integrity of the reactor coolant pressure boundary, 23 the capability to shutdown the reactor and maintain it 24 in a safe shutdown condition, or the capability to 25 prevent or mitigate the consequences of accidents NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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801 1 which could result in potential off-site exposures 2 comparable to those referred to in 50.34(a) (1),
3 50.67(b) (2), or 100.11, as applicable.-
4 Your answer is that any holes in the 5 condensate storage system would affect which of those, 6 and -- well, then we'll move on to the next question.
7 MR. GUNDERSEN: I guess my experience at 8 Millstone was that we had no idea if we were safely 9 shutdown, because every single neutron monitor had 10 failed. So to the degree that the neutron monitors 11 monitor -- because they- had developed through wall 12 leaks, and literally every one of them failed. So to 13 the degree that knowing you're in a safe shutdown mode 14 is part of being safely shutdown.
15 JUDGE ABRAMSON: What year was that event 16 in Millstone?
17 MR. GUNDERSEN: '72, sir.
18 JUDGE ABRAMSON: Has the technology 19 changed at all since then, do you think, on how these 20 things are monitored? Is there any --
21 MR. GUNDERSEN: There is more -- I wrote 22 the Reg Guides on this, and there's certainly more 23 monitoring in the condenser. The source of the leak 24 at Millstone was a failed tube in the condenser, which 25 then fed contamination into the condensate storage NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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802.
1 tank through these level changes. So you would pick 2 up the salt, or you'd pick up the increased 3 conductivity in the condenser. So for that event, I 4 think the single biggest thing the industry learned 5 was putting a lot of -- a lot of more conductivity 6 measurements in the condenser, and upstream and 7 downstream of the condensate demineralizers.
8 This event that I'm proposing with the 9 hole in the condensate pipe feeding into the HPCI 10 pumps is not monitored for contamination, because it's 11 not a normal source of water, so I don't believe 12 industry experience affects this event, but there 13 certainly was a lot of industry experience learned 14 from the chloride intrusion at Millstone. Yes.
15 JUDGE ABRAMSON: And if I understand your 16 dialogue with Judge Cole, whether or not this effect 17 that you're postulating, this Venturi effect, would 18 take place as a function of the dynamic head, the 19 static head, the size of the hole, the shape of the 20 hole, what's outside the hole in the ground. All 21 those things, right?
22 MR. GUNDERSEN: Certainly, the static head 23 on the vessel. That would be, I think, the single 24 biggest parameter that it's going to be a function of.
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803 1 can understand this a little bit better. What you're 2 talking about is, if there were a hole in the I condensate storage system underground pipe, I guess.
4 MR. GUNDERSEN: Yes.
5 CHAIR YOUNG: That that could introduce 6 some kind of contamination that could then be sucked 7 into the reactor, and that that -- if it led to a 8 shutdown, you're saying you wouldn't be able to 9 determine the state after that, so as to determine how 10 safe the shutdown condition was. Did I -- is that a 11 fair paraphrasing of it?
12 MR. GUNDERSEN: It was great at the 13 beginning, great at the end. There was a clause in 14 the middle that wasn't quite right. If it led to a 15 shutdown, you would be in -- you would be shutting 16 down. The reactor would have probably scrammed, or 17 maybe an orderly transition, but in any event, a 18 shutdown would be occurring, at which point you'd be 19 using the high pressure cooling injection system, and 20 then later other systems.
21 CHAIR YOUNG: The what?
22 MR. GUNDERSEN: So you would be shutting 23 down.
24 CHAIR YOUNG: Using the what?
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804 1 injection, HPCI.
2 CHAIR YOUNG: Okay.
3 MR. GUNDERSEN: So you would be shutting 4 down, and could, through a leak in that line, as it's 5 the preferred source, you could introduce 6 contamination into the reactor, which could blind you.
7 Essentially, we were running blind at Northeast --
8 CHAIR YOUNG: So the question you're 9 raising is --
10 JUDGE COLE: The velocity had exceeded the 11 elevation.
12 MR. GUNDERSEN: The problem -- yes.
13 Right. That's correct, Judge Cole.
14 CHAIR YOUNG: So what we're focusing in on 15 is the capability to maintain the reactor in a safe 16 shutdown condition. You're questioning whether that 17 might happen by virtue of any introduction of any of 18 the contaminants that came in through the hole and got 19 suck into the reactor. Is that -- that's what you're 20 questioning. Right? Am I understanding?
21 MR. GUNDERSEN: Yes, I think that's what 22 I'm questioning. Yes.
23 CHAIR YOUNG: Okay. Any follow-up to 24 that? Could you provide, either Entergy, or the 25 Staff, or both, your response to that?
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805 1 JUDGE ABRAMSON: Before we do that, Mr.
2 Gundersen, when reactors shut down and you've lost 3 your neutron monitoring, but you've scrammed it, do 4 you have reason to believe a reaction is still going 5 on? You'll know whether the control rods are in or 6 not, won't you?
7 MR. GUNDERSEN: You'll know that the 8 indications are that they fell down. But since 9 they're largely stainless, as well, you don't know 10 that -- well, actually fell in, fell up.
11 JUDGE ABRAMSON: Will you lose your 12 thermocouples? Did you lose your thermocouples? Did 13 you know what the temperature going in and out of the 14 reactor vessel was?
15 MR. GUNDERSEN: We were able to monitor 16 reactor -- we were still steaming, because the reactor 17 was --
18 JUDGE ABRAMSON: Sure. You had decay 19 heat.
20 MR. GUNDERSEN: So we had decay heat, and
- 21. we were running the isolation condenser, et cetera.
22 JUDGE ABRAMSON: And you were able to see 23 the steam generation rate going down as decay heat got 24 consumed.
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806 1 black. We had -- there was a lot of annunciators 2 going on, and I don't know about how much steam we --
3 I don't think that's where our focus was. The 4 concern is that because the control rod mechanisms are 5 also stainless, even though the board will show the 6 control rods are inserted up, that you could have had 7 a flaw in the stainless from this kind of attack.
8 Stainless at 500 degrees is pretty reactive. But at 9 Millstone, the three problems that we encountered were 10 loss of all the neutron monitors, because of inner 11 granules stress corrosion cracking.
12 JUDGE ABRAMSON: How long did that process 13 take to cause the failure?
14 MR. GUNDERSEN: About 10 or 20 seconds.
15 JUDGE ABRAMSON: From the onset of the 16 leak?
17 MR. GUNDERSEN: From the time the 18 chlorides broke through, to the time we lost --
19 JUDGE ABRAMSON: And when in the process 20 did SCRAM occur, at the beginning of the 10 seconds, 21 at the end? When? When did the SCRAM initiate, as 22 far as you know?
23 MR. GUNDERSEN: When the neutron monitors 24 started to fail, and I think the first one started to 25 fail at seven, or eight, or nine seconds, so it was --
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807 1 -- the slug had begun into the vessel and by the time 2 the vessel shutdown and cooled down, we had cracking 3 in the isolation condenser, lost all the neutron 4 monitors, and had cracking in the stainless steel clad 5 of the vessel.
6 JUDGE ABRAMSON: And you said you wrote 7 some Reg Guides after that to prevent against this 8 sort of a failure. Now, did the Reg Guide address 9 loss of instrumentation, or did it just address the 10 particular failure you had?
11 MR. GUNDERSEN: It addressed the 12 particular failure, which was to add additional 13 condensate -- additional monitors on the condenser.
14 And then before and after the demineralizers. The 15 other source out to the condensate storage tank and 16 back remained unmonitored.
17 MS. UTTAL: JUDGE, both you and Mr.
18 Gundersen are referring to Reg Guides. Reg Guides are 19 something that are written --
20 JUDGE ABRAMSON: That's why --
21 MS. UTTAL: -- by the NRC.
22 JUDGE ABRAMSON: And so what was the 23 connection between your statement that you wrote the 24 Reg Guide, and --
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808 1 engineer in Northeast Utilities. I was chosen because 2 I knew calculus better than the other engineers, 3 having been most recently out of college, compared to 4 some of the older engineers. The initial contacts 5 were a meeting with the entire -- it was at least 150 6 NRC staffers in Bethesda, and I presented the dynamics 7 of the accident, which I had modeled. Turned out to 8 be three coupled partial differential equations where 9 condensate storage tank was feeding in, and the 10 condensers and the demineralizers were breaking 11 through, and there were other loops involved, as well.
12 That description, then, resulted in 13 regulation, which the industry rolled through to 14 assure that the condenser was better monitored, to 15 assure that the condensate demineralizers were better 16 monitored, both on the inlet and the outlet side.
17 That same description then got rolled over to 18 pressurized water reactors, and was also implemented 19 on pressurized water reactors. The point person for 20 the NRC was a guy named Dan Pomeroy, and I worked 21 extensively with him for several years on this issue 22 to make sure that --
23 JUDGE ABRAMSON: So you had input into the 24 writing of the Reg Guide.
25 MR. GUNDERSEN: Correct.
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809 1 JUDGE ABRAMSON: You didn't author it 2 yourself.
3 MR. GUNDERSEN: That's correct, sir.
4 JUDGE COLE: This was in 1972?
5 MR. GUNDERSEN: Yes.
6 JUDGE COLE: That was AEC then.
7 MR. GUNDERSEN: Yes.
8 JUDGE ABRAMSON: All right. Judge Cole 9 has been with this agency since it was the beginning, 10 the AEC. He's one of the few relics of that era.
11 -(Laughter.)
12 CHAIR YOUNG: Institutional memory.
13 JUDGE ABRAMSON: But let me ask you one 14 more question, Mr. Gundersen. Have you done any 15 computations to give us an idea what size hole, and 16 what kinds of heads, what the trade-off would be, 17 where you think this Venturi effect might occur, or 18 might not?
19 MR. GUNDERSEN: No, I have not.
20 JUDGE ABRAMSON: So this is intuition at 21 this point, not based on any analysis.
22 MR. GUNDERSEN: It's professional opinion.
23 I hate to say just intuition, but it is not based on 24 a mathematical analysis. No, it's not.
25 PARTICIPANT: May I apologize for him?
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810 1 We're a public interest group, and my husband gave me 2 a birthday and Christmas present, to pay for his 3 expertise.
4 CHAIR YOUNG: Do you know what number Reg 5 Guide that resulted-in?
6 JUDGE COLE: NUREG something.
7 MR. GUNDERSEN: It would have had to be a 8 NUREG. It was early, I mean --
9 JUDGE COLE: It was probably -- well, not 10 a NUREG. It was something else. What did they call 11 them?
12 MR. GUNDERSEN: There were actually two, 13 I remember, because the boiling water reactor one came 14 out first, and then very rapidly the pressurized water 15 reactor realized that they had maybe not a safety 16 problem, but they were injecting chloride ions on to 17 the steam generator, which was a no-no, also. And so, 18 it wound up being written twice, once for boiling 19 water reactors, and once for pressurized. But no, I 20 can't -- I was surprised I remember Dan Pomeroy's 21 name.
22 CHAIR YOUNG: If you can clarify that, and 23 maybe in consultation with the staff, and provide that 24 later. I'm just curious about that.
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811 1 you recommended, and that were implemented into the --
2 -- whatever document it was, that those are now 3 required on the part of all current plants?
4 MR. GUNDERSEN: It was -- yes, all -- the 5 protections, again, were not in this line, but the 6 protections that were recommended by Northeast 7 Utilities Group in conjunction with the NRC are 8 industry standards now, yes. But the protections are 9 mainly on the condenser in both the inlet and 10 discharge of the condensate demineralizer. To the 11 best of my knowledge, contamination coming -- sort of 12 like doing the end run through the condensate storage 13 tank was not addressed in those modifications to the 14 plants.
15 JUDGE ABRAMSON: Was the type of 16 contamination that was introduced through the leak 17 that you had the same contamination one would expect 18 from groundwater on the site?
19 MR. GUNDERSEN: The -- I would expect it 20 would be different. You would -- the Millstone 21 experience was largely chloride ion. I've seen some 22 documents about sulfates, but I guess I would expect 23 that it would be different is about all I can say.
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812 1 that Mr. Gundersen has presented, and could you -- do 2 you have any response to that?
3 JUDGE ABRAMSON: What's your view of this 4 scenario that Mr. Gundersen has postulated?
5 MR. SULLIVAN: Well, there's really two 6 things that Mr. Gundersen discussed. One is the 7 possibility of having leakage into the buried line 8 that supplies -- could supply water to HPCI and RCIC 9 system, and the other is the Millstone event.
10 CHAIR YOUNG: Excuse me for just a second.
11 MR. SULLIVAN: Yes.
12 CHAIR YOUNG: The court reporter, whenever 13 they say HPCI and RCIC, you've got the acronyms over 14 there for that. Okay. Thank you.
15 MR. SULLIVAN: I'm sorry. I'll try to 16 spell them out.
17 CHAIR YOUNG: Well, you weren't the first 18 one. I just wanted to make sure that we got it 19 correct --
20 JUDGE ABRAMSON: I did it first.
21 CHAIRYOUNG: -- ultimately, sowhenwe're 22 reading the transcript we'll know what we're referring 23 to.
24 MR. SULLIVAN: But I can correct what I 25 say. The scenario related to the high pressure NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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813 1 coolant injection system, HPCI, or reactor core 2 isolation cooling system, RCIC, where water would be 3 drawn in, we just don't find that it's credible for a
- 4. couple of reasons. One is, the piping is stainless 5 steel piping, and the choice -- the material was 6 chosen because it's a material that's not susceptible 7 to corrosion, and it's very durable.
8 The possibility of groundwater or 9 chloride, or water heavily contaminated with chlorides 10 being drawn in, we just don't see it as being 11 credible. There's approximately a 30 foot head, 30-38 12 foot of head on that piping at all times.
13 JUDGE ABRAMSON: Do you understand that?
14 MR. SULLIVAN: Oh, I'm sorry.
15 CHAIR YOUNG: Actually, basically, let me 16 see if I can back up a little bit. What I understand 17 you to be saying is that you don't think that a leak 18 could occur that would lead to that. But earlier what 19 we were saying was, what people here were saying, as 20 I understood it, was, essentially, that because it's 21 not being relied on for a safety function in the 22 context of the TORUS, being the source that you rely 23 on, you don't really need to even get to the question 24 of how leaks would occur, et cetera.
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814 1 you can address the leaks. But assuming that a leak
.2 did occur, what's your view of how whatever 3 contamination might come in, might lead to the 4 question about the ability to maintain the plant in a 5 safe shutdown condition, because that's the specific 6 part of 54.4. That's the issue that's being raised by 7 Mr. Gundersen, as I understand it. And that's sort of 8 a separate question than -- well, that's not only a 9 separate question, but it's sort of determinative of 10 whether you need to look at the mechanisms and 11 likelihood of leaks and so forth. And you were going 12 directly to the likelihood of leaks in the first 13 place, so maybe if you could first address for me the 14 possibility of once a contaminant got in, it then --
15 raising some question about the ability to insure 16 that the --
17 MR. COX: Reactor is shut down.
18 CHAIR YOUNG: To maintain the reactor in 19 a safe shutdown condition. I forget where that 20 sentence started, but anyway, you get the drift.
21 MR. COX: I've got the idea, a couple of 22 counts. Again, I think it's -- Brian mentioned that 23 it's unlikely that you would have the leak. I think 24 the other thing that's very unlikely is that if you 25 did have a leak, that you would draw contaminants into NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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815 1 the pipe. Again, it's because of the head of the 2 water above it, you don't have much pressure drop in 3 a line that size with the flow. rates that we're 4 talking about in these systems, so it would be very 5 unlikely that you would get to the point where you'd 6 have a negative pressure in there, and be drawing 7 water in from outside.
8 The Venturi effect that he mentioned on a 9 garden hose sprayer, that's a specially designed 10 nozzle that's designed to give you a low pressure area 11 to draw the contents out of a cannister to get your 12 fertilizer into the spray. The analogy that I would 13 make to the situation that we have with the condensate 14 storage tank is if you took a water hose and poked a 15 hole in it, and stuck that hose down in a bucket of 16 water, would it fill up the bucket, or would it empty 17 the bucket? I think it's going to fill up the bucket 18 in most cases. It would be a very rare case, you'd 19 have to have a long run of pipe going down to a very 20 low level creating a vacuum on that to have it 21 otherwise.
22 And the last part of that, that I wanted 23 to address briefly is the -- I believe I understood 24 Mr. Gundersen correctly. His concern was pressure 25 boundary failures in the systems that were caused by NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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816 1 this contamination that happened in a~ matter of, I 2 believe he said in a matter of seconds after the 3 introduction of the contamination.
4 In my experience, that's not likely. I'm 5 not aware of any operating experience with any kind of 6 contamination that I've ever heard of being from 7 condenser tube leak, or whatever, where you would get 8 contaminants in a system, and have that immediate a 9 response in terms of pressure boundary failures.
10 CHAIR YOUNG: So the issue of -- well, the 11 first issue is whether there would be a leak. The 12 second issue would be whether there could be the 13 effect that would bring in the contaminant. And then 14 the third issue would be -- well, first, I guess two 15 parts to it. Is the only way -- let me direct this 16 back to you, first. Is the only way that there could 17 be a question about the ability to maintain the 18 reactor in a safe shutdown condition the potential 19 introduction of the contaminant? Do we need to take 20 a break?
21 JUDGE ABRAM4SON: I'll be right back.
22 MR. GUNDERSEN: I'm sorry. I have ADD.
23 I got distracted.
24 CHAIR YOUNG: Okay. Is the only way that 25 this issue that you're raising about the question of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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817 1 the ability to maintain the reactor in safe shutdown 2 condition. That would be dependent on the 3 introduction of the contaminant into the reactor.
4 Right?
5 MR. GUNDERSEN: Yes. I don't believe that 6 a stainless steel pipe'.s overall integrity is going to 7 cause the pipe to collapse, or reduce the flow.
8 CHAIR YOUNG: Okay. But all I'm asking 9 is, the only issue about ability to maintain the plant 10 in safe shutdown condition is the introduction of a 11 contaminant. Forget where it comes from. That's the 12 mechanism that would raise the problem that you're 13 talking about. Right?
14 MR. GUNDERSEN: Yes. That's correct.
15 CHAIR YOUNG: Okay. So then going back to 16 you, -you don't disagree with him, that if a 17 contaminant got in, a question could be raised?
18 MR. COX: If the contaminant got in, and 19 I guess in my professional opinion, the effects would 20 be long-term effects caused by corrosion mechanisms 21 that they're not going to happen within seconds, or 22 minutes, or even hours, but more like months.
23 CHAIR YOUNG: What I'm talking about is, 24 forget how it got there. If it gets in, is there any 25 question about the contaminant in the reactor vessel NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W, (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com
818 1 raising a question about the ability to insure the 2 capacity to maintain the reactor in safe shutdown 3 condition?
4 MR. COX: Yes, there is a question. It's 5 not credible. You'-re going to -- we have samples that 6 are taken from those systems on a routine basis.
7 CHAIR YOUNG: The whole -- let me back up.
8 MR. COX: If you contamination, you would 9 know.
10 CHAIR YOUNG: Hold on. Hold on. I'm not 11 asking about the likelihood of contamination. The 12 sole question I'm asking right this minute is, if you 13 got contamination, is there any question that it would 14 bring into question the ability to maintain the 15 reactor in safe shutdown condition, if you got it.
16 MR. SULLIVAN: No.
17 CHAIR YOUNG: All right. Now, let's move 18 back. Then the issue --
19 MR. SULLIVAN: I would like to qualify 20 that.
21 CHAIR YOUNG: Oh, go ahead.
22 MR. SULLIVAN: Because when the reactors 23 shut down, the first thing the operators do, and they 24 are trained to do, and they are trained like this 25 across the country, is to verify that the reactor is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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819 1 in a safe shutdown condition. And the first thing 2 they look at is to make sure that all control rods are 3 fully *inserted. That is the very first thing that 4 they check. And if. all rods are in, you're shutdown.
5 CHAIR YOUNG: And is there any question 6 about the monitoring system for that, that would bring 7 into question whether that's happened, or whether any 8 contaminant was in the system? Is -- and maybe I need 9 to go back to Mr. Gundersen, but is that -- was that 10 the only way you were saying that the contaminant 11 could raise a question, is the effect that it would 12 have on the steel, if the rods weren't up?
13 MR. GUNDERSEN: No, I don't think I said 14 that. And, by the way, I didn't suggest that the 15 pressure boundary was failed. We had significant 16 attack on the stainless steel clad of the vessel, and 17 stainless steel components, but the pressure boundary 18 did not fail.
19 What did fail was the neutron probes, 20 which run throughout the reactor, and there the 21 through wall cracks grew incredibly fast, on the order 22 of 10 seconds. And yes, the first thing a reactor 23 operators look at is at the board to make sure all the 24 rods are in. The second thing they look at is the 25 neutron monitors, and the two didn't agree. We had NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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820 1 every neutron monitor failed, and there was no idea 2 what the neutron fluence was. And, yet, the rods were 3 in, so the reactor operators were in conflict.
4 CHAIR YOUNG: So taking that into account, 5 go ahead with what you were explaining about.
6 MR. GUNDERSEN: That the reactor operators 7 would verify that all rods have fully inserted, and 8 they would be able to do that.
9 CHAIR YOUNG: They would be able to do 10 that because --
11 MR. GUNDERSEN: That's correct.
12 CHAIR YOUNG: -- of improvements in the 13 technology since then?
14 MR. GUNDERSEN: No, the technology is 15 essentially the same, but the indication that they're 16 looking at are read switches, which are just magnetic 17 switches similar to what you see on top of doors for 18 alarm systems sometimes. A magnet travels up with the 19 control rod drive as it inserts, and it picks up the 20 read switches as it's moving and fully inserting. And 21 then when they get all the way in, they indicate zero 22 zero, which is the full in position,. and they also 23 have a backup sensor that provides a green light that 24 rods have been fully inserted.
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821 1 little bit. I think Mr. Gundersen was referring to 2 the nuclear instrumentation that would be used to 3 verify the reactor is shut down. What Brian is saying.
.4 is you don't need to look at your nuclear 5 instrumentation, you can look at the position of the 6 rods and know that the reactor is shut down.
7 MR. SULLIVAN: And the shutdown 8 instrumentation that would be used after the rods were 9 in, the IRM, Intermediate Range Monitors, and Shutdown 10 Range Monitors, I'm sorry, Source Range Monitors would 11 be inserted into the core so that you can then monitor 12 what's going on inside the core.
13 CHAIR YOUNG: That's the neutron monitors 14 that he was talking about?
15 MR. SULLIVAN: He was talking about the 16 Power Range Monitoring System, which is different.
17 CHAIR YOUNG: Okay. So --
18 MR. SULLIVAN: Quite honestly, I don't 19 know what he was talking about, but I'm trying to 20 answer the question with regard to how Pilgrim Station 21 is operated, and how boiling water reactors are 22 operated.
23 JUDGE ABRAMSON: So, in your mind, there's 24 no question that you would know that the reactor is 25 shut down.
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822
- 1. MR. SULLIVAN: That's correct.
2 JUDGE ABRAMSON: And that you could safely 3 maintain shutdown after that, whether or not
.4 contaminant had been drawn in by this, postulated 5 scenario.
6 MR. SULLIVAN: That's also correct.
7 CHAIR YOUNG: And the way you would know 8 that is -- well, how?
9 MR. SULLIVAN: You would check that all 10 rods fully inserted.
11 CHAIR YOUNG: No, I mean after that, after 12 that, that the rods were inserted, and that if a 13 contaminant was there, that it wouldn't have any 14 effect.
15 MR. SULLIVAN: Well, the level of 16 contamination that's being discussed here from a 17 condenser tube leak, Pilgrim Station has two 18 condensers. Each condenser is broken down into two 19 different water boxes. Each water box has 10 20 conductivity elements in it, which monitor for tube 21 leaks. And the reason why there's 10, is so you get 22 some idea of where the tube leak is.
23 CHAIR YOUNG: The reason why this?
24 MR. SULLIVAN: Why there's 10 conductivity 25 elements, is so that you have some idea where the leak NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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823 1 is coming from.
2 JUDGE ABRAMS0ON: But he's speculating 3 the scenario that's being speculated about here is
-4 one where the source of the contaminant is not from 5 the tube leak, it's from this drawing in of 6 groundwater which contains contaminants into this tube 7, by a Venturi effect, despite the 30 feet of head.
8 And, so, it's a very different -- and as I understood 9 Mr. Gundersen, you would expect this to be quite 10 different type of contamination.
11 MR. SULLIVAN: That's correct.
12 JUDGE ABRAM'SON: So setting aside for a 13 moment what this contamination would do, because this 14 is, in my view, quite speculative. We have no idea 15 what's being drawn in, or whether it can be drawn in, 16 so let's talk about maintaining the reactor in a safe 17 shutdown condition.
18 As I understood you to say, if you lost 19 your Power Range Neutron Detectors, once you shut it 20 down, you insert the Intermediate Range --
21 MR. SULLIVAN: Source Range.
22 JUDGE ABRAMSON: Source Range Detectors, 23 and those were not in the reactor at the time that 24 this contaminant was introduced, so you don't have any 25 reason to believe at the outset, at least, that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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824 1 they're not going to function.
2 MR. SULLIVAN: That's correct.
3 JUDGE ABRAMSON: What other mechanisms do 4 you have to observe whether or not this is shut down?
5 For example, can you watch the steam generation rate?
6 Can you watch the temperatures, et cetera?
7 MR. SULLIVAN: All of those. You can 8 watch all of.those. All of those would be secondary 9 indications. You would know by whether or not your 10 pressure control systems were working adequately. If 11 you could not maintain pressure control within the 12 prescribed band following the shutdown, you would know 13 if you had excess steam generation. Those would be 14 secondary indications.
15 CHAIR YOUNG: Excess?
16 MR. SULLIVAN: Steam generation.
17 CHAIR YOUNG: Steam generation. I'm 18 missing some of your words, sometimes.
19 MR. SULLIVAN: Okay. I'll slow down.
20 CHAIR YOUNG: Okay.
21 MR. SULLIVAN: But those would be 22 secondary indications. If your rods are in, your 23 reactor is shut down.
24 CHAIR YOUNG: Now, Mr. Gundersen, after 25 having heard what they've said about assuming a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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825 i contaminant got in, whether you'd be able to maintain 2 it in safe shutdown condition. What's your response 3 to that? Do you have questions about what they're 4 saying about the ability to know what's going on, and 5 to maintain a safe shutdown condition?
6 MR. GUNDERSEN: Just one split second. I 7 need to -- there was a period when we were running 8 blind until we could use the other monitors, which had 9 been previously withdrawn. And after that, we could 10 then confirm that the board was correct, and that the 11 rods had been inserted.
12 CHAIR YOUNG: So with --
13 MR. GUNDERSEN: So there was -- yes, after 14 Northeast Utilities got the probes that -- the sources 15 that -- the neutron detectors that had been withdrawn 16 were reinserted, at that point we could confirm that 17 the board was correct. But there was a period of time 18 when we could not.
19 CHAIR YOUNG: So, in other words, you're 20 not questioning -- let me ask. Are you questioning 21 what the Applicant just said about their ability to 22 know what was going on, and maintain a safe shutdown 23 condition?
24 MR. GUNDERSEN: No.
25 CHAIR YOUNG: You're not questioning that.
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826 1 Okay. So, basically, what I understand is that, at 2 this point, there's not really any question remaining 3 about the ability to fulfill the functions in Section 4 54.4, the ones that Judge Abramson read off.
5 MR. -'GUNDERSEN: There was a list. Could 6 you read it one more time? I think you could get to 7 a safe shutdown mode, and --
8 JUDGE ABRAMSON: And maintain it.
9 MR. GUNDERSEN: Would you read the list?
10 CHAIR YOUNG: And maintain it.
11 MR. GUNDERSEN: And maintain it. I guess 12 that's my -- could you read that one last time, before 13 I --
14 CHAIR YOUNG: Okay. The scope of license 15 renewal. "Plant systems, structures, and components 16 within the scope of this part are one, safety-related 17 systems, structures, and components which are those 18 relied upon to remain functional during and following 19 design-basis events, as defined in 50.49(b) (1), to 20 insure the following functions; one, the integrity of 21 the reactor coolant pressure boundary; two, the 22 capability to shut down the reactor and maintain it in 23 a safe shutdown condition; or, three, the capability 24 to prevent or mitigate the consequences of accidents 25 which could result in potential off-site exposures NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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827 1 comparable to those referred to in 50.34(a) (1),
2 50.67(b) (2), or 100.11, as applicable.' And then, 3 "Non-safety related systems, structures, and 4 components", I don't think we're talking about those, 5 but .whose failure - could prevent satisfactory 6 accomplishment of any of the functions identified in 7 1-3", that I just read.
8 MR. GUNDERSEN: Okay. I'm okay with the 9 initial no that I gave you about a minute ago.
10 CHAIR YOUNG: No to? There's no problem.
11 In other words, at this point --
12 MR. GUNDERSEN: I think the event which I 13 postulated -- after the event, which I postulated, 14 with some scrambling, they could get the reactor into 15 a safe shutdown mode, and maintain it therein.
16 CHAIR YOUNG: Okay. Okay.
17 MS. LAMPERT: Now, may I just ask, it 18 seems like there's been a change here. It is listed 19 to be in scope, and so isn't the question a more basic 20 one of shouldn't it be operating properly? There was 21 a reason that, in my imagination, the Gods at NRC who 22 wrote this thought that it was important to the safety 23 of the reactor.
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828 1 this- right. Okay? Just to try to 'pull it together.
2 As I understand it, the reason that the 3 condensate storage system was put into the application 4 as one of the systems that was within scope is because 5 there are parts of it that would play into the 6 functions that we're talking about. However, the 7 underground pipes and tanks are not those that you're 8 concerned about, because the TORUS would take over for 9 those. So it was in for reasons other than the 10 underground pipes and tanks. Does that make sense, 11 and does that accurately answer the question, which I 12 think is the same one I asked before, essentially?
13 MR. GUNDERSEN: That is correct. You said 14 that very well.
15 CHAIR YOUNG: Did that make sense to the 16 Intervener?
17 MS. LAMPERT: Can I just wait one second?
18 JUDGE ABRAMSON: While we're on this, and 19 waiting for Pilgrim to have their internal discussion, 20 does the Staff have any comments on this banter about 21 this scenario?
22 MR. CHAN: I just want to say that I don't 23 have experience in plant operations, to address what 24 Entergy did.
25 JUDGE ABRAMYSON: Okay. That's fine.
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829 1 We're not asking you to speculate. We have enough.
2 CHAIR YOUNG: It got into -- the 3 contention came in because the system was in scope.
4 Later, in preparation, Entergy, as I understood your 5 testimony, realized that the underground pipes and 6 tanks weren't really the reason why it's in scope, 7 because as far as those go, the TORUS would be the 8 source that you rely on. Correct?
9 MS. LAMPERT: So, in other words, over the 10 past couple of years, we have managed to shrink and 11 collapse the definition of function, where our 12 understanding was, is that in going forward another 20 13 years, that we want systems that are considered 14 important to be functional, and that would be, as they 15 defined it, getting the necessary liquid from Point A 16 to B, as opposed to into the ground. I mean, that's 17 sort of the definition of it being functional, but it 18 seems like we have been on a very severe diet.
19 JUDGE ABRAMSON: I think that -- I 20 understand your frustration, but I think that you're 21 mischaracterizing what this is about.
22 We have an application, the Agency has an 23 application for a license extension. The regulations 24 that prescribe what they have to do for a license 25 extension are very narrow, and very specific, and they NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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830 1 say the following systems, structures, and components 2 are appropriate for examination, and must be examined 3 during a license, extension application, and nothing 4 else. And the systems, the pipes that we're -- that 5 you raised a question about, which were all buried 6 pipes and tanks that might contain radioactive fluids, 7 and we understand you raised them because you were 8 worried about leaking radioactive fluids into the 9 groundwater, the Board admitted that contention in an 10 abundance of caution, to make sure that we examined 11 absolutely every possibility to make sure that what 12 was required to be examined in this process was 13 properly examined.
14 CHAIR YOUNG: I think the frustration -
15 and maybe your confusion was the same as mine earlier, 16 when I asked why was it listed as being in scope, if 17 now you're saying it's not in scope? And as I 18 understand the answer, the system is still within 19 scope, and so Entergy has to demonstrate to the Staff 20 that the entire condensate storage system, or the 21 system as a whole fulfills the functions that are 22 listed in 54.4.
23 What they're telling us now is that while 24 the system as a whole is still being looked at by the 25 Staff, and it's still being looked at in terms of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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8.31 1 license renewal, that the buried pipes and tanks, 2 which was the only part- of that system that we allowed 3 in with regard to this contention, because the 4 . contention was about buried pipes and tanks, that they 5 realized that the buried pipes and tanks in that 6 system were not the relevant parts for purposes of
'7 looking at whether the functions were fulfilled. So 8 I don't think that there's any cessation of looking at 9 whether the functions are fulfilled on the part of the 10 Staff in terms of the contention that's before us. The 11 contention did not include the other parts of that 12 system.
13 MS. LAMPERT: Okay.
14 CHAIR YOUNG: Does that make sense?
15 MS. LAMPERT: It makes sense if, again, 16 I'll defer to him, but in my mind, if it's the 17 preferred source, and if minerals, contaminants get 18 into a hole, let's say, can it cause -- Step Two, can 19 it cause degradation in the next system that would be 20 required for safe shutdown? In other words, going --
21 would this be a root of a problem that would fit in?
22 Does that sound crazy to you?
23 CHAIR YOUNG: And I think they can answer 24 that, but I think that -- what I understood was that 25 the two systems,-the condensate s~torage system, and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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832 1 the TORUS, were separate, and so you couldn't have a 2 contamination of the TORUS through the condensate 3 storage system. Right?
4 MR. SULLIVAN: That's correct.
5 CHAIR YOUNG: Judge, could we take a 6 break?
7 CHAIR YOUNG: Yes, we're going to take a 8 break. Let's let that settle, take a break, and then 9 if we have any more follow-up after the break. Let's 10 be back at 4:00, that's 15 minutes.
11 Before everyone leaves, if counsel could 12 come back.
13 JUDGE ABRAMSON: Counsel for Entergy, can 14 you come back for just a second, please?
15 CHAIR YOUNG: Is Ms. Uttal here?
16 CHAIR YOUNG: Yes, I'm here.
17 JUDGE ABRAMSON: Just one quick --
18 CHAIR YOUNG: Ms. Lampert just raised the 19 question of off-gas system, so when we come back from 20 the break, would you be prepared to address --
21 jUDGE YOUNG: The standby gas treatment 22 for the off-gas system.
23 JUDGE ABRAMSON: Right.
24 CHAIR YOUNG: Off-gas system.
25 MS. LAMPERT: It's the one that goes to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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833 1 the filter -
2 MS. UTTAL: That's the standby.
3 MS. LAMPERT: The standby.
4 MR. LEWIS: They both go up the stack, and 5 they're different systems. -
6 CHAIR YOUNG: At the break, would you talk 7 to each other, and figure out what you're talking 8 about, and then you can --
9 JUDGE ABRAMASON: We need to find out what 10 she's talking about.
11 MS. UTTAL: It's easy to figure out.
12 CHAIR YOUNG: Well, what I'm saying is, 13 can you talk with each other and clarify that you're 14 talking about the same thing, whatever it may be.
15 JUDGE ABRAMSON: Just ask her. Just 16 figure out what it is she's concerned about.
17 CHAIR YOUNG: And then we'll take that up 18 when we come back.
19 MS. UTTAL: Okay.
20 CHAIR YOUNG: All right. Now we can go 21 off the record. Thanks.
22 (Whereupon, the proceedings went off the 23 record at 3:47:25 p.m. , and went back on the record at 24 4:05:54 p.m.)
25 CHAIR YOUNG: On the record. All right.
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834 1 Let's see. We left things I think on the note was 2 there any follow-up to the last sort of clarification 3 that we had. Go ahead.
4 MR. GUNDERSEN: There is one Pilgrim 5 document that-does speak to contamination entering the 6 reactor through the condensate storage tank which we 7 would like to get on the record. It's a document 8 signed by Paul McNulty in 2004 and it has a Bates on 9 it of PilR00045.
10 JUDGE ABRAMSON: Why don't you have it 11 circulated quickly so we can look at it?
12 MR. GUNDERSEN: Okay.
13 JUDGE ABRAMSON: And let see what Entergy 14 says about it.
15 MR. GUNDERSEN: And while Ms. Lampert --
16 I'll just read the paragraph. It's on page 10 of the 17 document which page 10 is 45116 is the Bates.
18 "Intrusion from undetected organochlorides and 19 organosulfates can contaminate the condensate storage 20 tank resulting in increased chlorides and sulfates in 21 the condensate system and reactor." Then it goes on 22 to say, "Current conductivity, sulfate analysis and 23 TOC methods" which I think are total organic 24 compounds, I think that's what that is, "done at 25 Pilgrim Nuclear Power Station will not provide the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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835 1 information needed to prevent this." So I wanted to 2 get that on the record because it does address the 3 fact that contamination can enter the reactor through 4 the path that I suggested.
`5 MR. LEWIS: I'd like to see that document.
6 I don't hear that saying at all that contamination is 7 going to occur through the buried piping. I didn't 8 mention intrusion through the buried piping at all.
9 CHAIR YOUNG: Let everyone look at it and 10 -
11 JUDGE ABRAMSON: Let's see what it says 12 and we'll deal with it. In the meantime, have Pilgrim 13 Watch figured out which other system it was concerned 14 about?
15 (Off the record discussion.)
16 CHAIR YOUNG: Well, let's finish up this 17 one.
18 MS. LAMPERT: Yes. This is what we 19 decided. In recognition of the scope having become 20 very narrow, it really wouldn't make any difference to 21 talk about either because the conversation on the 22 condensate service system would wind up in the same 23 place. And so we'll drop that, but we would like the 24 opportunity to have a discussion about monitoring 25 wells and the important role that they could play NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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836 I particularly in what seems to be a 2 CHAIR YOUNG: I actually had a follow-up 3 question on that after we finish with these. So why 4 don't we go ahead with this. But I guess the only 5 question I would ask you is you do understand how we 6 got from sort of where we started to understanding why 7 the argument is being made that the underground pipes 8 and tanks of the condensate storage system are not 9 counted on to fulfill the safety functions under 54.4 10 because the TORUS is the actual source that they rely 11 on.
12 PARTICIPANT: Safety source.
13 CHAIR YOUNG: Was that clear before?
14 MS. LAMPERT: Your explanation was 15 certainly very clear. What hadn't been clear and I 16 think in the public's mind is not clear why in this 17 relicensing process that we are not what appears to be 18 focused on the disaster as opposed to having an aging 19 management required program on systems that were put 20 into place that would lead to preventing catching the 21 problem before the horse had left the barn.
22 That's, I guess, a conceptual problem and 23 I understand that you didn't write the rules which is 24 unfortunate. But that's the issue. I understand what 25 you're saying.
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837 1 CHAIR YOUNG: Just for those in the 2 audience who may not be following all this, basically 3 what happens in this adjudication is based on the
- 4. issues that, are allowable under, the rules and. *that 5 we've allowed in through contentions. That doesn't 6 mean that the staff doesn't address issues that are 7 not part of the contentions and it doesn't mean the 8 issues that are not looked at in license renewal are 9 not looked at in other ongoing operational oversight 10 that takes place.
11 MS. LAMPERT: We understand that and 12 that's why we spent a lot of time and paper explaining 13 why the day-to-day maintenance was not adequate and 14 this was the opportunity when we're entering a new 15 phase to put supplements on the aging management 16 program so that we would have public safety assurance.
17 Hence, that's that. But I certainly 18 understand what you've said.
19 CHAIR YOUNG: Okay. Now with --
20 PARTICIPANT: Let's talk about this 21 exhibit.
22 CHAIR YOUNG: -- with regard to the 23 exhibit. You're looking at page 10 and, Mr. Lewis, 24 you've had a chance to look at that as well and I 25 think you raised the question whether that related to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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838 1 any contamination coming from the underground pipes 2 and tanks.
3 MR. LEWIS: I won't object to this 4 document coming in. I~would just like to ask three 5 follow-up questions on this whole topic.
6 CHAIR YOUNG: Okay. Any objection from 7 the staff?
8 (No verbal response.)
9 CHAIR YOUNG: So then this will become 10 Exhibit 72.
11 (Whereupon, the above-referred 12 to document was marked for 13 identification as Exhibit No.
14 72, and received in evidence.)
15 (off the record discussion.)
16 CHAIR YOUNG: Is that right? Seventy-two, 17 I think that's right.-
18 MS. LAMPERT: Fifty-two A.
19 CHAIR YOUNG: Pardon me?
20 MS. LAMPERT: Excuse me.
21 CHAIR YOUNG: Okay. And what were your 22 questions?
23 MR. LEWIS: Should I just ask or should I 24 tell you?
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839 1 process. You have something you want to have your 2 experts reply to.
3 MR. LEWIS: Yes.
4 JUDGE ABRAMSON: Let's get on with it.
5 MR. LEWIS: With respect to the Venturi 6 effect seeing that was raised, there was some 7 references to groundwater being sucked into the 8 condensate storage system buried piping. What is the 9 relationship of that buried piping to the water table?
10 MR. COX: I can answer that. The buried 11 piping is at elevation, is buried seven to ten feet 12 deep. The water table is approximately 17 feet deep.
13 So the source of water if it was drawn into that pipe 14 would be from the groundwater.
15 MR. LEWIS: And is it also true that above 16 that buried piping, above the buried CST piping, the 17 area above that is covered with asphalt? Is that 18 correct?
19 MR. COX: That is correct.
20 MR. LEWIS: In addition, there was a 21 reference to the Venturi effect which happens, as I 22 understand is correct, when the velocity head exceeds 23 the pressure head. Is that correct?
24 MR. COX: That's correct.
25 MR. LEWIS: Am I correct that if the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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840 1 velocity head exceeded the pressure head there would 2 be a loss of net positive suction head?
3 MR. COX: That's correct.
4 MR. LEWIS: And what would happen with the 5 pumps at that point, the HPCI and RCIC pumps? -
6 MR. COX: The pumps would trip.
7 MR. LEWIS: And final question --
8 CHAIR YOUNG: They would short.
9 MR. COX: Shut off..
10 PARTICIPANT: They would trip.
11 CHAIR YOUNG:. Shut off.
12 MR. LEWIS: Final question with respect to 13 this new exhibit, does this indicate that chlorides 14 can be introduced through the buried piping?
15 MR. COX: This addresses chlorides getting 16 into the condensate storage tank and being introduced 17 through the normal method. It would have nothing to 18 do with chlorides being drawn into the buried piping 19 from outside the pipe.
20 CHAIR YOUNG: Where would they come from?
21 MR. COX: The item that this addresses 22 would be for chlorides coming from the condensate, the 23 mineralizers. This is actually addressing an analyzer 24 to monitor the water before it goes into the 25 condensate storage tank to make sure you didn't have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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841 1 chlorides in there. If it gets in there, the sampling 2 on the condensate storage tank will detect it.
3 CHAIR YOUNG: Was that all?
4 MR. LEWIS: Yes.
5 CHAIR YOUNG: Any follow-up to that?
6 DR. AHFIELD: Yes. Just a comment on the 7 relation of the elation of CST pipe to the water 8 table. There is a plausible scenario here, I think, 9 if this hypothesized hole is of sufficient size that 10 during the surge phase of the, that is the filling 11 phase of the, tank water could leave the pipe and 12 depending on the geologic conditions immediately 13 surrounding the pipe it could actually rather than 14 infiltrate downward take its time doing so and if the 15 water is coming out of the pipe fast enough, pond up 16 a bit and this, of course, happens from the time to 17 time that you could get a pressure head outside the 18 pipe and a source of water, now this condensate water 19 having left the pipe, sitting in the formerly 20 unsaturated soils, mixing with whatever is there and 21 then coming back in perhaps.
22 CHAIR YOUNG: Through the same hole?
23 MR. COX: Yeah.
24 DR. AHFIELD: Say it again.
25 MR. COX: Temporary perched water.
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842 1 DR. AHFIELD: Essentially yes.
2 JUDGE COLE: We understand the scenario.
3 Thank you.
4 CHAIR YOUNG: You asked -- I said from the 5 same hole, through the same hole and he said yes.
6 DR. AHFIELD: Yes. That's the scenario 7 we're describing, yes.
8 CHAIR YOUNG: Right.
9 CHAIR YOUNG: Does the staff have anything 10 to add on this?
11 MR. CHAN: The staff agrees first with the 12 Applicant's characterization of the Venturi effect and 13 its effects on the CST buried piping.
14 CHAIR YOUNG: Am I understanding right?
15 If anything did get in, you're saying once it got to 16 the HPCI or --
17 JUDGE ABRAMSON: RCIC.
18 CHAIR YOUNG: RCIC that it would shut off 19 automatically if the monitor --
20 JUDGE ABRAMSON: Let me see if I can 21 characterize this. I think it's quite simple. In 22 order for this Venturi effect to happen, the pressure 23 in the pipe itself has to drop very low. If the 24 pressure in the pipe dropped that low, the HPCI and 25 RCIC pumps would shut off automatically and therefore NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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843 1 it couldn't draw anything in.
2 JUDGE COLE: The pressure has to be 3 negative.
4 JUDGE ABRAMSON: Yes.
`5 CHAIR YOUNG: So is that correct?
6 MR. COX: That's correct.
7 JUDGE ABRAMSON: So they wouldn't draw 8 anything in.
9 CHAIR YOUNG: And did you want to follow 10 up to that?
11 DR. AHFIELD: Again, this is -- We're 12 spinning out a hypothetical here. But if there is 13 this temporary perched condition, there could be an 14 above atmosphere pressure in the water.
15 JUDGE ABRAMSON: Yes.
16 DR. AHFIELD: It doesn't necessarily have 17 to be negative.
18 JUDGE ABRAMSON: Yes. Okay. We 19 understand the ramifications of this thing. I think I 20 like --
21 CHAIR YOUNG: But the shutoff question, 22 the shutoff would be caused by the --
23 JUDGE ABRAMSON: By the pressure being 24 low.
25 CHAIR YOUNG: -- pressure being low.
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844 1 JUDGE ABRAMSON: Right, and it's a very 2 complicated computation to try to do it. It depends 3 on the permeability of the soil. It depends on how 4 much water got in there. It depends on how much you 5 could suck out before the pressure dropped which it 6 would eventually do. It's not something one can do.
7 One can speculate about scenarios, but I don't think 8 we can go past that. Is that -- Now I'm not supposed 9 to be testifying here.
10 (Laughter.)
11 JUDGE ABRAMSON: Maybe somebody wants to 12 tell whether I've summarized this right or not.
13 MR. SULLIVAN: We concur.
14 (Laughter.)
15 JUDGE ABRAMSON: Mr. Ahfield.
16 CHAIR YOUNG: He's doctor.
17 JUDGE ABRAMSON: Doctor.
18 DR. AHFIELD: It is -- It would be 19 conceivable to do that analysis. I'm not sure if you 20 were suggesting that it's impossible to do.
21 JUDGE ABRAMSON: No.
22 DR. AHFIELD: I think that analysis could 23 be done. No one at this table has done it.
24 JUDGE ABRAMSON: We understand.
25 CHAIR YOUNG: Do you have any idea on the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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845 1 likelihood of that scenario?
.2 JUDGE ABRAMSON: No, it depends on so many 3 things. Now I understand, Mr. Lampert, you wanted to 4 have a dialogue about monitoring wells and let me just 5 say we have a great deal of testimony in front of us 6 and I'm not particularly fond of the idea of having a 7 repetition of all that's in writing before us. If you 8 have something brief you'd like to say about the 9 benefits from monitoring wells in a few minutes, 10 that's fine. Bur I would not welcome a long dialogue, 11 monologue, about the benefits of monitoring wells when 12 it's repetitive of what we've already seen. That's 13 not the purpose of this hearing.
14 CHAIR YOUNG: Let me maybe set this off by 15 a question and that is -- And we did say that since 16 Entergy had opened the door to the comparison of the 17 effectiveness of the aging management systems and the 18 use of monitoring wells that that would not be 19 excluded.
20 So I'm looking at the last substantive 21 paragraph rather than the "I declare" from Dr. .Ahfield 22 saying that "groundwater monitoring networks can be 23 used as part of a leak detection system and are widely 24 used for this purpose. Well-established protocols 25 exist with proper design of monitoring networks NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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846 1 including well and screen placement, sampling 2 frequency and selection of sample to contaminants."
3 And then you say that "the four well system that 4 Entergy has does not meet what you would consider to 5 be reasonable standards for a monitoring network 6 design."
7 A couple questions. The way this is issue 8 of monitoring wells is in at this point is as to a 9 comparison between the effectiveness of the aging 10 management programs and monitoring wells and Entergy 11 said that their aging management programs are much 12 more direct and much more effective than monitoring 13 wells could be.
14 So I'd like to give you the opportunity to 15 give your opinion on that and also to give your 16 opinion on what level of added value there would be by 17 adding the monitoring well system you're talking about 18 in the context of the safety functions that we're 19 talking about in these contentions, in this contention 20 in these two areas.
21 DR. AHFIELD: Okay. Of course, this 22 testimony that you've quoted from me was written in 23 January when my understanding was that the three 24 components were relevant to the safety function, those 25 being the saltwater service and the CST and the off-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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847 1 gas and the name is escaping me.
2 In any case, the monitoring, wells can 3 supplement the- various monitoring techniques that 4 Entergy is proposing and add with relatively-little 5 cost an additional frequent measurement technique and 6 I think the example we talked about this morning with 7 the saltwater service line is a good one. There you 8 have a case where you have a pipe obviously traveling 9 through the unsaturated soil, a water table beneath 10 it, it's fresh water and that saltwater passing 11 through that pipe if it were to leak would generally 12 migrate downward, would then move laterally with the 13 groundwater and would leave a signature in monitoring 14 wells, I believe. That's a signature of sufficient 15 magnitude, in other words, a change in concentration 16 of chloride or some other substance that would allow 17 one to detect leakage from that particular pipe.
18 And so I think the value added here is the 19 frequency with which one could make this 20 determination, make this testing. We heard this 21 morning of inspection of the pipe, the interior of the 22 pipe, as I understand it, every ten years, inspection 23 of the exterior of the pipe on an occasional basis and 24 then only sort of spot inspection, as I understand it, 25 and that is at a few locations.
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848 1 In effect, the groundwater wells give us 2 an integrated measurement. So if they're properly 3 designed and placed,, then a leak anywhere along that 4 line,~ along that pipe,- would be detected by one or 5 more of those wells. So that's really the value 6 added. And as I note in my testimony, I appreciate 7 the interest in not repeating it all, but this is 8 routinely used for all sorts of applications in 9 industry. There are all sorts of protocols depending 10 on type of facility, size of facility, type of or risk 11 of potential leak. There are sort of protocols for 12 how the wells should be designed, how many there 13 should be, how often they should be sampled and so on.
14 CHAIR YOUNG: I think we heard mention 15 earlier today about ruling-making in process on the --
16 Was it on the tritium issue?
17 PARTICIPANT: It was the legacy site.
18 CHAIR YOUNG: Oh, it was it on the legacy 19 sites?
20 MS. UTTAL: We aren't aware of any rule-21 making.
22 CHAIR YOUNG: Maybe I misunderstood. I 23 thought I heard some reference to --
24 MR. LEWIS: In my opening statement, I 25 refer to a rule-making. The rule-making is entitled NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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849 1 "Decommissioning Planning" but, as part of that 2 regulation, it is also proposing to amend Part 20 to 3 require subsurface surveys and I can give you a 4 citation if you're interested, Judge Young.
5 CHAIR YOUNG: Okay. You can include that 6 in your proposed findings and conclusions if you'd 7 like. The reason I --
8 MR. LEWIS: That was my opening statement.
9 As I said, it's outside the scope of the proceeding.
10 I was just trying to explain that.
11 CHAIR YOUNG: Okay.
12 MR. LEWIS: Important stuff outside the 13 scope of the proceeding is not being ignored. It's 14 just being addressed in another arena.
15 CHAIR YOUNG: And that's sort of related 16 to the reason why I was remembering back to that and 17 that is I think one of the initial reasons that 18 Pilgrim Watch, if I can presume, brought the 19 *contention was that they were concerned about the 20 monitoring for radioactivity and that the aging and 21 safety aspects of it while they were there they 22 weren't the primary concern.
23 And so my question would be to what extent 24 is the type of monitoring or type of information, the 25 system that you're talking about, to what extent is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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850 1 that addressed or addressed to or. more useful with 2 regard to the monitoring for the radioactivity or the 3 monitoring with regard to the safety issues that we're 4 talking about and the reason I ask it is because I 5 think I -understand Entergy's testimony to be that the 6 level monitoring that they have and the flow rate 7 monitoring that they have along with the inspection 8 programs that those are more direct and that, and here 9 T'm paraphrasing but anyone can feel free to correct 10 me, any leak that would have a safety impact would 11 have to be so large that it would necessarily be 12 detected more directly through other means.
13 So that essentially, the amounts we're 14 talking about, while the type of monitoring wells 15 you're talking about pick up whether there were small 16 leaks, that the size leaks that they're talking about 17 are so big that it wouldn't serve that significant a 18 function with regard to the safety issues. Does that 19 make sense?
20 DR. ARFIELD: I think it does and I think 21 you'ye posed several questions and if I may address --
22 CHAIR YOUNG: And did I say that more or 23 less correctly?
24 (No verbal response.)
25 CHAIR YOUNG: Okay.
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851 1 DR. AHFIELD: I first want to clarify what 2 I think can be a confusing point about the purpose of 3 monitoring wells and certainly in many applications in
- 4. many industries they are used to detect contaminants 5 in the subsurface to- prevent pollution, to prevent 6 migration offsite.
7 CHAIR YOUNG: Right.
8 DR. AHFIELD: And that's not the issue 9 here.
10 CHAIR YOUNG: Right.
11 DR. AHFIELD: The notion is that they are 12 to be used here as they are elsewhere for monitoring 13 for leaks so that the leak can be corrected. So 14 that's really quite a different function.
15 CHAIR YOUNG: Right.
16 JUDGE ABRAMSON: Your point being that you 17 would detect them before they got to the level at 18 which they're this kind of safety problem. Is that 19 it?
20 DR. AHFIELD: That's correct. Yes.
21 Now with respect to the saltwater service 22 line, my understanding, and again I'm going to rely on 23 what Mr. Gundersen spoke to this morning and others 24 actually on the other panels, that small leaks can 25 lead, can indicate, corrosion in the steel pipe and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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852 1 for the saltwater now which may lead to its, may 2 indicated that it's losing structural integrity and 3 then maybe impaired or degraded in the design failure 4 event. I[m not sure I'm getting my terms right here, 5 the design --
6 PARTICIPANT: Design basis.
7 DR. AHFIELD: The design basis event. So 8 the notion of small leaks being indicative of a 9 corrosion, small scale corrosion, that may be getting 10 larger is important and may not be detected quickly 11 enough, you see in my opinion, with the relatively low 12 frequency testing proposed by Entergy, the ten-year 13 inspections, for example.
14 CHAIR YOUNG: Did you -- From you've heard 15 today, would you say that the type of monitoring that 16 you are proposing could make a difference in 17 preventing any of the -- serving any of the safety 18 functions that we listed earlier or is it more a case 19 of that it could save the company a lot of money 20 because if they didn't discover it until later they 21 might -- they would be able to shut down or to stop, 22 to address the safety issues, but it would be a lot 23 more expensive. Can you say that it would fall into 24 one or the other of those?
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853 1 we were doing some hypotheses with respect to the 2 Venturi effect and all of that, if we can speculate 3 now about a scenario with respect to SSW, the 4 saltwater service line. Suppose there's an 5 inspection, internal inspection. Everything looks 6 fine. But for whatever reason, there is now a leak 7 that develops. Some corrosion starts at some spot.
8 A leak develops. That corrosion spreads. Now this 9 gets into the rate of corrosion which is beyond my 10 expertise.
11 CHAIR YOUNG: Right.
12 DR. AHFIELD: But if that rate were 13 sufficiently rapid, then under this scenario I'm 14 laying out it may degrade the structural integrity of 15 the steel pipe to a point that it would be a safety 16 risk in the event of an earthquake before the next ten 17 year inspection. But I'm suggesting that under this 18 scenario those leaks would be detected by, say, 19 quarterly sampling from a strategically designed 20 network of groundwater monitoring wells.
21 CHAIR YOUNG: So in the end it does sound 22 like, at least, to me at this point, so correct, point 23 out anything I'm leaving out, it does sound a lot 24 depends on the integrity and functionality of the 25 epoxy liner with regard to the salt service water NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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854 1 system. Correct?
2 DR. AHFIELD: Well, the -- As I understand 3 it, it's the structural integrity of the steel pipe 4 that is critical in the design basis event.
5 CHAIR YOUNG: Right. But they're relying 6 on the epoxy liner to withstand or to protect against 7 any leaks that would get to the metal of the pipe.
8 JUDGE ABRAMSON: If I can help, Judge 9 Young.
10 CHAIR YOUNG: Articulate it.
11 JUDGE ABRAMSON: What I think Judge Young 12 means to say, I shouldn't be a mind reader, is that 13 Entergy relies upon the epoxy fiber liner to prevent 14 water from inside the pipe getting to the inside of 15 the carbon steel pipe where it could cause corrosion.
16 Is that right?
17 CHAIR YOUNG: Right, and I guess that was 18 the question that what you indicated was that you 19 didn't know about the rate of corrosion and so forth 20 and it sounds as though from what you're saying that 21 there's no question, but that the system that you're 22 proposing could detect leaks earlier and at least one 23 of the main missing ingredients in terms of whether it 24 could prevent a safety issue is the degree to which 25 the epoxy lining would prevent corrosion from starting NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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855 I in the first place and to a certain extent, I think, 2 there was also testimony about how fast it would 3 spread based on the adhesive or the adherence of the 4 liner.
5 DR. AHFIELD: Right. And again, I'm not 6 a corrosion expert, but what I'm hearing and 7 understand is that the corrosion can occur from both 8 inside and outside the pipe.
9 CHAIR YOUNG: Right. You're right.
10 DR. AHFIELD: And to Mr. Abramson's, Dr.
11 Abramson's, question, yes, the epoxy lining contains 12 the water so that we'd have to have a leak in that.
13 JUDGE ABRAMSON: I think we understand.
14 I think certainly I understand and I'm sure Judge Cole 15 understands quite well the benefits of a monitoring 16 well system. So if Judge Young has more to pursue on 17 this, let's carrying on.
18 CHAIR YOUNG: Did you have anything 19 further to say? I mean, I think you understand the 20 question that I'm trying to get at here. In other 21 words, is what you're saying something that would 22 involve maybe it would be wise to do this? But can 23 you say based on -- It sounds like you're saying that 24 you think it's something to consider that might 25 prevent safety functions from being compromised, but NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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856 1 that the missing piece that you can't provide is the 2 corrosion aspect of it.
3 DR. AHFIELD: That's correct. I can't 4 provide the corrosion aspect and I think a way to look 5 at this is simply as one of a set of tools. None of 6 them are perfect for monitoring or inspecting the 7 pipe.
8 CHAIR YOUNG: Right.
9 DR. AHFIELD: And, you know, in water 10 supply which I do some of we do a lot of redundancy in 11 water supply protection I should say and water 12 treatment and I presume the same would be true in this 13 case, when several systems that overlap to protect the 14 safety function.
15 CHAIR YOUNG: Right.
16 DR. AHFIELD: So that's the role I see it 17 playing and I don't think it's a -- I'm seeing it as 18 more than just a nice thing to add but instead a 19 crucial part of a full system.
20 Anything else to add, well, again I don't 21 want to elaborate, you know, repeat everything I said 22 here. But my testimony in regards to what is needed 23 is not very, you know, number of wells and so on, is 24 not specific because there's not enough data.
25 CHAIR YOUNG: Right.
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857 1 DR. AHFIELD: There hasn't been typical 2 due diligence on just characterizing. We've heard of 3 17 feet to the water table. It's not 17 feet 4 everywhere I'm sure. It varies from place to place 5 and I just think Entergy probably doesn't know. It's 6 probably an average of 17 feet. So that has to be 7 done and that has to be part of the package.
8 MR. GUNDERSEN: The issue of corrosion 9 rates in the carbon steel pipe on that service water 10 system, I think the record indicates that you can go 11 from nothing to significant hole on the order of two 12 years and we have a ten year inspection plan. So 13 we're hanging our hat on ..
14 CHAIR YOUNG: We understand. What's your 15 basis for that, sir?
16 MR. GUNDERSEN: That the photographs from 17 1995 and the evidence this morning, Entergy's, 18 Pilgrim's, discussion this morning said that in '95 19 they looked at it and in '97 they looked at it and 20 then '99, all at once, it was pretty full blown holes.
21 So the holes that we presented in the photographs were 22 nonexistent two years before. That was the basis for 23 that.
24 JUDGE COLE: They had been in the ground 25 25 years at that time.
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858 1 MR. GUNDERSEN: That's correct. But the 2 last time it was looked at was two years before those 3 photographs were taken and there was no problem. So 4 the carbon steel can deteriorate on the order of two 5 yeart from the time it gets saltwater up against it.
6 JUDGE COLE: But we don't really have an 7 accurate picture of when the last time the individual 8 systems have been looked at.
9 MR. GUNDERSEN: In that photo and I think 10 testimony this morning said they were looked at two 11 years before.
12 JUDGE COLE: We know when most of them 13 have been installed though.
14 CHAIR YOUNG: When did -it start?
15 MR. GUNDERSEN: I'm sorry. When I get 16 back to the photo with the quarter in it, two years 17 before that same pipe had been looked at at the same 18 spot and there was no evidence so that --
19 CHAIR YOUNG: Let me interrupt you for 20 just a second just to clarify something there. I 21 thought I remembered that in '95 that they did see 22 some degradation at least of the rubber lining and 23 possibly of the metal that they decided because of 24 that to check it two years later that there might have 25 been some progress, but it wasn't -- There wasn't a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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859 1 hole yet and then two years 2 when they checked it, that's when they discovered the 3 hole.
4 MR. GUNDERSEN: That's correct.
5 CHAIR YOUNG: So there was some 6 progression.
7 MR. GUNDERSEN: Yes. I think I said from 8 between two and four years and yet we're looking at 9 the pipe every ten. So we get back to we relying on 10 the integrity of the SOC, a great analogy.
11 CHAIR YOUNG: Right.
12 MR. GUNDERSEN: Yet the boundary that's --
13 But yet that's really not qualified. I mean, we have 14 industry --
15 JUDGE ABRAMSON: If you have something 16 new, let's hear it. Otherwise let's move on.
17 COMMISSIONER EDWARDS: No. I just wanted 18 to get back on the record the issue of we do know that 19 these pipes fail in less than ten years when exposed 20 to saltwater and that was something Dr. Ahfield 21 brought up.
22 MS. LAMPERT: Could I add one point? My 23 understanding is that it is the burden of Entergy to 24 offer proof.
25 CHAIR YOUNG: That's correct.
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860 1 MS. LAMPERT: Today I've heard opining 2 and, looking at the record, do you really see factual 3 data of we inspected A, B, C, D and E of each system 4 at' X date?. .Then so many, a period later, as you were 5 talking about, we went back to see the progression.
6 Now what is the age of the various segments in the 7 pipe and therefore we were going to ask these 8 questions. Therefore, what basis, what facts have 9 been presented?
10 JUDGE ABRAMSON: Ms. Lampert, if I may.
11 MS. LAMPERT: Certainly.
12 JUDGE ABRAMSON: We've had a lot of 13 written testimony. We've had some oral responses to 14 our questions today. The kind of information you are 15 now trying to present or are wishing to present is 16 perfectly appropriate for your proposed findings. But 17 it's not necessary for us to hear those questions now.
18 They're not going to answer now.
19 CHAIR YOUNG: It is something that's more 20 appropriate for argument.
21 MS. LAM4PERT: Okay. I didn't understand 22 that. Now I do.
23 CHAIR YOUNG: Okay. However, you did 24 mention questions and so what I'm going to do is ask 25 Entergy if you have any follow up to what you've just NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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861 1 heard about the monitoring well system, about the 2 corrosion progression.
3 MR. SPATARO: If I may, on the corrosion 4 question, at this point in time, the argument is moot.
5 It took 20 years for the rubber to degrade. It took 6 another six years for that degradation to get to the 7 substrate carbon steel and, yes, the carbon steel 8 failed very quickly. At this point in time, we have 9 a practically brand new epoxy liner over a non-10 degraded rubber liner which then is our double barrier 11 between the saltwater and the carbon steel.
12 Rough estimate, 40, 60 years before any of 13 those liners would start to show degradation and fail 14 and then you would have rapid deterioration of the 15 carbon steel. So that's our case.
16 CHAIR YOUNG: Anything further?
17 MR. SULLIVAN: Relative to the need for 18 monitoring wells, it's our position --
19 CHAIR YOUNG: Right. To follow up on the 20 testimony you've just heard.
21 MR. SULLIVAN: -- that we do not need 22 monitoring wells, that we have adequate surveillances 23 and procedures and specifications for how we do work 24 at the station that do not require monitoring wells in 25 order for us to assure the safe operation of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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862 1 station in the continued license period.
2 CHAIR YOUNG: Does the staff have anything 3 to offer?
4 MS. UTTAL: I believe all of our arguments 5 are in our testimony including Dr. Davis' testimony 6 that the monitoring wells are not required.
7 CHAIR YOUNG: Ms. Hollis, you have just 8 been sitting and listening all day which is sometimes 9 the hardest thing to do. Did you have anything to add 10 or the Town of Duxbury, either one?
11 MS. HOLLIS: A question and it may be an 12 inappropriate question in the context here, but I've 13 been puzzled with respect to the response on the 14 inspection, the timing of the inspections and the 15 necessity for more inspections in saltwater systems.
16 That's one issue.
17 And then the second is on the monitoring 18 wells and it may be that this is a completely outside 19 the context of this particular panel's interest and 20 jurisdiction to hear. I wonder from Entergy's 21 standpoint. Is the reason for not pursuing additional 22 inspections, for example, as was proposed by Judge 23 Abramson, let's say, during the refueling cycle of 24 segments of the pipe, is that because of cost? Is it 25 because of a precedential effect or what is the reason NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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863 1 for not pursuing that as an appropriate middle ground?
2 And then the second would also be related 3 to the question, for example, of the monitoring wells.
4 How much is a monitoring well and how much does it 5 cost to monitor the monitoring wells? I know in other 6 circumstances they have added monitoring wells, for 7 example, in other plant relicensing procedures where 8 Entergy has, in fact, added monitoring wells where 9 they felt it was appropriate in very large numbers, 10 let me say. So I don't know if this is an NRC 11 question or if this is outside the context of the 12 proceeding.
13 JUDGE ABRAMSON: Have you had any direct 14 discussions or has the Town had any direct discussions 15 with Entergy about it?
16 MS. HOLLIS: We have had discussions with 17 Entergy but not on this particular topic.
18 JUDGE ABRAMSON: Perhaps that would make 19 some sense for you to approach them directly and get 20 your answers. We're dealing with only the issues that 21 are in front of us. But those kinds of questions are 22 perfectly appropriate to take up with them and perhaps 23 you will understand what their rationale is and maybe 24 you'll get chances and maybe you won't. I don't know.
25 But that's the way to go with it, I would suggest.
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864 1 MS. HOLLIS: our cause taken into 2 consideration in the context of the panel's 3 deliberations or is it just the basic issue of the
.4 safety and the relationship between the contention.and 5 the safety issue?
6 JUDGE ABRAMSON: For us, it's a 7 regulation. Do they comply. with the regulation or 8 not?
9 CHAIR YOUNG: Right.
10 JUDGE ABRAM4SON: We just read the law and 11 deal with it.
12 CHAIR YOUNG: However, since the issue has 13 been raised, does Entergy have anything that you'd 14 like to say in response?
15 MR. COX: I would add that as Mr. Lewis 16 mentioned in the opening remarks we do believe that 17 monitoring wells are appropriate for dealing with the 18 NET groundwater protection initiative. But in the 19 context of license renewal as we've testified today, 20 they're not necessary to assure the license renewal 21 intended functions that are defined in 10 CER 54.4.
22 CHAIR YOUNG: And with regard to the more, 23 the dividing up the segments of the pipe and 24 inspecting them when you have shutdowns or refuelings?
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865 1 unnecessary and it creates a undue burden.
2 CHAIR YOUNG: An undue burden in terms of 3 cost or -
4 MR. SULLIVAN: Cost, safety, risk during 5 a shutdown. We believe that the safest thing for the 6 plant to do is to keep the safety systems in service 7 to the maximum extent possible.
8 CHAIR YOUNG: So doing them all at once, 9 you're saying minimizes the safety considerations and 10 that that's more of an issue to you than cost. Did I 11 understand that right or maybe I'm reading too much 12 into it.
13 MR. SULLIVAN: Yes, you understood it 14 right.
15 CHAIR YOUNG: Okay. Any other follow-up?
16 Have we left anything out?
17 JUDGE ABRAMSON: Does Town of Duxbury have 18 any? You were asked and we're not going to bypass 19 you.
20 CHAIR YOUNG: You're Ms. Chin. Right?
21 MS. CHIN: Yes. The only thing I would 22 add that the Town of Duxbury passed a unanimous vote 23 at their annual town meeting of 2007 that did support 24 monitoring wells and other components that have been 25 discussed today and that vote was forwarded to the NRC NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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866 1 and Entergy and there was no response.
2 CHAIR YOUNG: They're here today and so,.
3 as Judge Abramson said, any dialogue that you want to 4 initiate, or try to follow up on separate from the 5 -adjudication proceeding is certainly something that I 6 think is open to you. We can't speak for the rest of 7 the NRC. We're separate from them for obvious 8 reasons, well, maybe not for obvious reasons, for 9 reasons that our fulfilling our function of being 10 independent and neutral and weighing the evidence 11 without fear of favor to any party. So that's what 12 we've tried to do here today and when we deliberate 13 after we've received the proposed findings of fact and 14 conclusions of law we'll approach it from the same 15 standpoint.
16 But any communications between any of the 17 parties and with the NRC staff who are represented 18 here at the table next to you is certainly something 19 that you can follow up on.
20 MS. LAMPERT: Yes, I'd like to make a 21 comment on that. I think conversation is lovely and 22 voluntary programs is wonderful, too. However, I 23 think requirements, written requirements, it's the 24 only thing the public can actually count on.
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867 1 is that we're making probability guesses about risk.
2 What is. the risk of a hole occurring, growing to a 3 certain extent, and impacting safety? That requires, 4 J1 would think, more than opinions. it requires having 5 past experience, I'd like to finish it please, past 6 experience to look back on which they have very little 7 of and there is no experience for the aging management 8 program going forward nor any reactor in operation of 9 that age. Therefore it is prudent to take a. more 10 proactive approach and I think that's what we're 11 suggesting as opposed to, no, we will assume not based
.12 on much experience that we're going to wait until the 13 disaster occurs and then we'll worry about it. That 14 does not seem to be that it's officially the role. of 15 the NRC which is to protect public safety. That's 16 where I stand.
17 CHAIR YOUNG: I think I had -- we had said 18 in our last order that we wouldn't require closing 19 statements and that's sort of in the nature of a 20 closing statement and that's fine. You've said that.
21 Now as to the timing of any proposed 22 findings of fact and conclusions of law as I mentioned 23 earlier the closing of this hearing has been stayed by 24 the 1't Circuit. We have pending before us a motion 25 from Pilgrim Watch in response to which I presume NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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868 1 other parties will be filing responses.
2 Is there anything else that any party 3 thinks we could profitably do here today? I think 4 with regard to both of the other things we're sort of 5 not at a point of closure and the record will stay 6 open. But for today, is there anything else that any 7 party would like to propose we do? Is there anything 8 that's been left out? Is there any --
9 MS. UTTAL: Judge.
10 CHAIR YOUNG: Yes.
11 MS. UTTAL: One point I would like to make 12 is I don't think that the Board has to delay its 13 decision on this contention because of the order 14 issued by the l1s Circuit. The issue --
15 JUDGE ABRAMSON: We'll take the 1" 16 Circuit order under advisement. We're going to look 17 at it. At this point, it is our conclusion that this 18 proceeding needs to be delayed and we'll study it. If 19 you think that that's an erroneously interpretation, 20 we'd be happy to welcome a brief on it.
21 CHAIR YOUNG: Obviously, this is something 22 that literally came in the evening before we left the 23 next morning to come here, in other words, two 24 evenings ago and I happened to be there and get it 25 when it came in and emailed it to my colleagues and I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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869 1 think, one of- the things we're going to wait for is to 2 see what the State of Massachusetts does and we'll 3 -proceed from there.
4 obviously, any argument that the parties 5 want to make on anything that arises out of this we're 6 not foreclosing those in any way. But this is sort of 7 a new development and we sort of need to see where it 8 goes.
9 What the court said was that the hearings 10 that they would stay the closing of the hearings, in 11 this case and the Vermont Yankee case, until 14 days 12 after the mandate is issued by the court.
13 MR. LEWIS: Judge, if I could be heard on 14 this. I know I can follow up with a position on this 15 and the court's language was ambiguous. It's not 16 clear whether they mean termination of the 17 adjudicatory proceeding or closure of the record. I 18 think they mean the latter because what they wanted to 19 do was allow the Commonwealth of Massachusetts to come 20 as an interested state so that they could file a 21 motion pursuant to 10 CFR 2.802(d), give that some 22 time. It looks like the Commission is going to issue 23 the renewed licenses before a ruling on the petition 24 for rule-making that's pending.
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870 1 ope n, they can do that. My suggestion would be though 2 that none of this is an impediment to proceeding with 3 proposed findings and that would be useful time spent.
4 CHAIR YOUNG: Well, at this point, the 5 court said they're -- The 1St Circuit Court o f Appeals 6 said they're staying the closing of the hearings.
7 There is obviously -- Anyone could argue what they 8 want to about that meeting. But at this point, I'm 9 not willing to close the record in this hearing which 10 is part of this proceeding in the face of the court's 11 order.
12 So let's wait and see what happens next.
13 Presumably something will come from the State of 14 Massachusetts and the parties can argue about the 15 impact of that. But we're not going to close the 16 record now and I don't think it's appropriate to 17 schedule proposed findings of fact and conclusions of 18 law until the record is closed.
19 JUDGE ABRAMSON: Yes. Let me pick this 20 up, putting on my legal judge hat for a moment.
21 It's clear to me *that in the absence of 22 further testimony submitted by the Massachusetts 23 Attorney General on this particular contention. No 24 more testimony will be taken except if it's in 25 response to the motion we now have from Pilgrim Watch NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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87-1 1 which we assume you will reply to when you see in due 2 course.
3 So while the record isn't formally closed, 4 there should be no further testimony from any party on 5 this particular contention -
6 CHAIR YOUNG: It's unlikely I think.
7 JUDGE ABRAMSON: -- unless something 8 happens with the Massachusetts Attorney General which 9 I can't predict at this point. So you can certainly 10 start preparing your proposed findings of fact and 11 conclusions of law with the assumption that nothing 12 further will happen. But I don't think we can make 13 that assumption yet and frankly we'll be faced with a 14 very interesting situation should something develop 15 from Mass. AG on this contention.
16 MR. LEWIS: Maybe my suggestion then would 17 be for the parties to start preparing the proposed 18 findings recognizing that if at some point the mandate 19 issues and this record closes the Board may ask for 20 the proposed findings on very short order because to 21 me it doesn't make sense --
22 JUDGE ABRAMSON: I'm okay with that.
23 MR. LEWIS: -- turning a 30 day schedule 24 into a three month schedule.
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872 1 in the interim. I mean, there's nothing to stop you 2 from doing that.
3 JUDGE ABRAMSON: But there's a caveat 4 that's being --
5 CHAIR YOUNG: You're-wanting to say that 6 once that mandate is issued that we say we want the 7 proposed findings tomorrow. I think we just have to 8 wait and see what happens at this point. I don't 9 think we're ready to say what we're going to do 10 definitely with regard to closing the record under the 11 circumstances before us now. But we're not going to 12 go away. You know where to find us.
13 (Laughter.)
14 JUDGE ABRAMSON: You can certainly ask the 15 Commission to react to the order it got from the Is 16 Circuit. Remember that order was issued to the 17 Commission.
18 MS. UTTAL: One more thing regarding time 19 limits. Pilgrim Watch served their motion on us 20 yesterday, I believe, and I would ask the Court to 21 start the ten day period from tomorrow when we all get 22 back to our offices.
23 JUDGE ABRAMSON: That's okay.
24 JUDGE COLE: Sure.
25 CHAIR YOUNG: Starting tomorrow --
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873 11 JUDGE ABRAMSON: Is that a rijotion?
2 (Laughter.)
3 CHAIR YOUNG: -- that would be good.
4 (Off the record comments.)
5 CHAIR YOUNG: That would be the 21st. Am 6 I counting right?
7 (off the record discussion.)
8 CHAIR YOUNG: What date is 'the ten?
9 CLERK: The 21"t falls on Monday.
10 CHAIR YOUNG: Monday, okay. How about 11 Monday the 21" for responses?
12 JUDGE ABRAMSON.: No work for you because 13 they're the ones that have to do this. Right? You've 14 put your motion --
15 (Off the record comments.)
16 CHAIR YOUNG: All right. Anything else 17 before we adjourn for today?
18 MR. LEWIS: Judge Young, I looked at the 19 photographs. My memory failed me. They weren't in 20 color on our disc. We do have a slightly better copy 21 and I can hand those out if you'd like.
22 CHAIR YOUNG: Okay. That's fine.
23 JUDGE ABRAMSON: Why don't we adjourn?
24 CHAIR YOUNG: Yes, just a second. I just 25 want to say before we adjourn thank you, everyone, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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874 1 thank the parties for being here and being attentive 2 and providing assistance to us in doing our jobs and 3 for those of you in the audience thank you for coming 4 and we hope that you learned something from it as we 5-. did and I guess that's all to be said at this time.
6 We'll adjourn and expect to hear from the parties with 7 regard to the other pending matters in the near future 8 and see where that takes us.
9 Thank you all. We can go off the record.
10 (Whereupon, at 5:01 p.m., the above-11 entitled matter was concluded.)
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CERTIFICATE This is to certify that the attached proceedings before the United States Nuclear Regulatory Commission in the matter of:
Name of Proceeding: Pilgrim Nuclear Power Station Hearing Docket Number: 50-293-LR Location: Plymouth, Massachusetts were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and, thereafter reduced to typewriting by me or under the direction of the court reporting company, and that the transcript is a true and accurate record of the foregoing proceedings.
Eric Hendrixsoli Official Reporter Neal R. Gross & Co., Inc.
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