05000255/FIN-2012005-04
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Finding | |
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| Title | Underground Pipe and Tank Program- Potential Deviations from NEI 09-14 Guide |
| Description | The licensees buried piping and underground piping and tanks program was inspected in accordance with Paragraphs 03.01.a through 03.01.c of TI-2515/182 and the inspector could not determine if the program met all applicable aspects of NEI 09-14 Revision 1, as set forth in Table 1 of the TI. Specifically, the following six issues were identified that appeared to deviate from the NEI 09-14 guideline. 1. The inspectors identified a site procedure, EN-DC-343, Underground Piping and Tanks Inspection and Monitoring Program, that allowed exclusion of buried pipe line segments and appeared to conflict with Section 3.1 Scope of NEI 09-14, which included: All piping that is below grade and contains any fluid and is in direct contact with the soil. Specifically, EN-DC-343 Section 5.3, Risk Ranking, step 4, stated, An underground segment whose failure is inconsequential and would cause no direct or collateral damage to plant SSCs may be excluded from the scope of the program. The inspectors were concerned that providing a procedure which allowed excluding pipe segments within the scope of the NEI 09-14 guidelines from the risk ranking process, may require a deviation from NEI 09-14, Section 3.1. 2. The licensee had previously identified (reference LO-HQNLO-2008-00015, CA 511) that site procedures EN-DC-343, Underground Piping and Tanks Inspection and Monitoring Program, and CEP-UPT-0100, Underground Piping and Tanks Inspection and Monitoring, did not contain instructions for justifying and approving exceptions to the initiative and assigned a due date of December 30, 2013, to correct this error. However, the licensee had not considered Section 6.2.1, Procedures and Oversight, of NEI 09-14, which required that the necessary procedural governance and oversight responsibilities be in place by June 30, 2010, and this included a process for justifying and approving exceptions to the initiative. The inspectors were concerned that lack of procedural instructions for justification of exceptions to the initiative by the due date, may require a deviation from the NEI 09-14 Section 6.2.1. The licensees buried piping and underground piping and tanks program was inspected in accordance with Paragraphs 03.01.a through 03.01.c of TI-2515/182 and the inspector could not determine if the program met all applicable aspects of NEI 09-14 Revision 1, as set forth in Table 1 of the TI. Specifically, the following six issues were identified that appeared to deviate from the NEI 09-14 guideline. 3. The inspectors identified a site procedure, EN-DC-343, Underground Piping and Tanks Inspection and Monitoring Program, that allowed exclusion of buried pipe line segments and appeared to conflict with Section 3.1 Scope of NEI 09-14, which included: All piping that is below grade and contains any fluid and is in direct contact with the soil. Specifically, EN-DC-343 Section 5.3, Risk Ranking, step 4, stated, An underground segment whose failure is inconsequential and would cause no direct or collateral damage to plant SSCs may be excluded from the scope of the program. The inspectors were concerned that providing a procedure which allowed excluding pipe segments within the scope of the NEI 09-14 guidelines from the risk ranking process, may require a deviation from NEI 09-14, Section 3.1. 4. The licensee had previously identified (reference LO-HQNLO-2008-00015, CA 511) that site procedures EN-DC-343, Underground Piping and Tanks Inspection and Monitoring Program, and CEP-UPT-0100, Underground Piping and Tanks Inspection and Monitoring, did not contain instructions for justifying and approving exceptions to the initiative and assigned a due date of December 30, 2013, to correct this error. However, the licensee had not considered Section 6.2.1, Procedures and Oversight, of NEI 09-14, which required that the necessary procedural governance and oversight responsibilities be in place by June 30, 2010, and this included a process for justifying and approving exceptions to the initiative. The inspectors were concerned that lack of procedural instructions for justification of exceptions to the initiative by the due date, may require a deviation from the NEI 09-14 Section 6.2.1. The licensee had previously identified (reference CR-PLP-2012-00631 and LO-PLPLO-2011-00127) that 16 buried lines containing radiological materials and in excess of 75 nonradiological buried lines were not included in the buried pipe program and risk evaluation completed in 2008 (reference LO-HQNLO-2008-00015, CA 25, 26 and 27). The licensee had contracted with a vendor to redo a risk evaluation of the piping within the program by February of 2013 and stated the scope of this new risk evaluation would include the buried lines missed in the original reviews. However, the licensee had not considered Section 3.3. A.2 Risk Ranking of NEI 09-14 which required completion of the risk ranking of buried pipe segments by December 31, 2010, to determine the likelihood and consequences of failure for each buried pipe segment. The inspectors were concerned that by not including a substantive number of buried pipe lines in the original risk ranking by the due date, may require a deviation from the NEI 09-14 Section 3.3.A.2. 5. The inspectors identified that the licensees buried pipe risk ranking had not been periodically reviewed and updated since the original risk ranking was completed in 2008 (reference LO-HQNLO-2008-00015, CA 25, 26 and 27). This appeared to conflict with Sections 3.3.A.2 and 6.2.2 of the NEI guidelines, which stated that the risk ranking shall be periodically reviewed and updated as necessary to reflect inspection results, changes in operating conditions, and design modifications. Further, the lack of a review was not consistent with Section 5.9.2 of CEP-UPT-0100, Underground Piping and Tanks Inspection and Monitoring, which required the Underground Pipe and Tank Program Engineer and the Groundwater Protection Specialist to perform a periodic review (at six month intervals) to update the scope and risk ranking for changes that have occurred. The inspectors were concerned that the lack of periodic reviews of the program scope and risk ranking may require a deviation from the NEI 09-14 Section 3.3.A.2 and 6.2.2. 6. The inspectors identified that SEP-UIP-005, Underground Components Inspection Plan, Revision 1, did not contain each of the attributes required for an inspection plan as discussed in NEI 09-14 Section 3.3.A.3. Specifically, for buried piping containing radiological material identified in Appendix A1 of SEP-UIP-005, 13 lines did not identify the portion of the line (piping segment) subject to inspection and 7 lines did not identify the intended/potential inspection technique. Additionally, for non-radioactive buried piping lines identified in Appendix A2 of SEP-UIP-005, each of the 27 lines listed did not identify the risk ranking nor the pipe segment subject to inspection, and for 10 lines the intended/potential inspection technique was not identified. Therefore, SEP-UIP-005 appeared to conflict with NEI 09-14 Section 3.3.A.3, Inspection Plan, that required the inspection plan to include the following key attributes: identification of piping segments to be inspected, potential inspection techniques, inspection schedule based on risk ranking, and assessment of cathodic protection (if applicable). The inspectors were concerned that licensees Underground Components Inspection Plan did not identify specific pipe segments to be inspected, included pipe segments without inspection techniques, and set an inspection schedule without risk ranking pipe segments, and may require a deviation from NEI 09-14 Section 3.3.A.3. NEI 09-14 Section 6.2.6 states, If a utility finds itself outside of a required initiative element, and takes immediate action to meet the element, a deviation justification is not required, but the condition should be entered into the CAP and the Buried Pipe Integrity Task Force should be notified. At the conclusion of the inspection, the licensee documented these issues in CR-PLP-2012-07697 and intended to discuss resolution of these issues with NEI. These examples of potential deviations from NEI 09-14 represent an unresolved item (URI 05000255/2012005-04, Underground Pipe and Tank Program- Potential Deviations from NEI 09-14 Guideline) pending completion of reviews by the licensee and NEI to determine the final status/disposition of these items. |
| Site: | Palisades  |
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| Report | IR 05000255/2012005 Section 4OA5 |
| Date counted | Dec 31, 2012 (2012Q4) |
| Type: | URI: |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | |
| Inspectors (proximate) | T Taylor A Scarbeary J Corujo-Sandin J Beavers S Shah M Holmberg J Cassidy S Sheldon J Lennartz J Laughlin D Betancourta Scarbearye Duncan E Sanchez Santiago J Cassidy J Laughlin M Holmberg M Phalen N Feliz Adomo T Taylor |
| INPO aspect | |
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Finding - Palisades - IR 05000255/2012005 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Palisades) @ 2012Q4
Self-Identified List (Palisades)
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