ML100700489

Topical Report 116, Rev. 3 Oyster Creek Underground Piping Program Description and Status.

ML100700489
Person / Time
Site:	Oyster Creek
Issue date:	01/05/2009
From:	Tamburro P AmerGen Energy Co
To:	Office of Information Services
References
FOIA/PA-2009-0214 116, Rev 3
Download: ML100700489 (82)

Text

Topical Report 116 Revision 3 Oyster Creek Underground Piping Program Description and Status Prepared By: Peter Tamburro I a- t-T -1?'

115-/0 Approved By: Thomas Roddey C0 0 0.7 January 2009 1 11,

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Oyster Creek UnduergroundPiping Program Description dnd Status Topical Report 116 Rev. 3 Page 2 of 82 Executive Summary This Topical Report provides a program description and the current status (as of November 2009) of the Oyster Creek Underground Piping Program.

The objective of the program is to ensure that the material condition of Oyster Creek underground piping will remain satisfactory until the end of 2029, considering Nuclear Safety, Environmental Regulations, Plant Availability, and System Reliability. (CM-1)

This objective is achieved with the following program elements:

1) Investigate operating history related to underground piping leaks

2) Perform Risk Evaluations of underground piping on the Oyster Creek Site (CM-1).

3) Prioritize underground lines based on evaluation and operating history

4) Perform inspections and tests on high and medium priority systems and at target of opportunity in low priority systems

5) Analyze to determine generic failure mechanisms and corrective actions

6) Evaluate, justify and sponsor modifications and tests

7) Designate low priority piping in which no preventive actions will be taken and leaks will be repaired as they occur.

Oyster Creek UndergroundPiping ProgramDescriptionanl Status Topical Report 116 Rev. 3 Page 3 of 82 The following are significant program accomplishment::

1), In 2008, Oyster Creek replaced the remaining 50% of all underground Safety Related ESW piping; approximately 300 linear feet. In 2004, Oyster Creek had replaced the other 50%. Therefore, as of 2008, 100% of Safety Related Underground ESW piping has been replaced and the Risk Ranking for these lines has been revised and is no longer considered "High Risk".

2) In 2004 and 2008, Oyster Creek replaced approximately 20% of all underground Service Water System piping; approximately 150 linear feet.

The remaining 80% is planned to be rehabilitated in 2010.

3) In 2008, Oyster Creek Engineering developed a series of technical evaluations that demonstrated that ESW System I could be used as an alternate source of RBCCW Heat Exchanger cooling with the plant online. The technical evaluations became the basis for operating procedure changes. The revised operating procedures gave Oyster Creek the capability for taking the Service Water System out of service for maintenance for short durations with the plant online. This mode of operation takes advantage on the ESW to Service Water System crosstie line, which was sponsored by this program and installed in 2002. In early of 2008 the revised procedures were used to mitigate an underground Service Water Line leak. The Service Water System was taken out of service for repairs while the plant remained on line. This was a first time evolution in the history of Oyster Creek.

4) In 2068, Oyster Creek replaced all three chlorination lines to the ESW and Service Water System. The new lines are double wall pipe. The Risk Ranking for these lines has been revised and is no longer considered "High Risk".

5) In 2008, the program performed coating inspections on 6 lines in the southeast vault. This inspection is now required as a new Repetitive Task (PM57304M).

This PM opens and drains water out of the vault. The inspection found that the coating on five lines had broken down and require repair. An IR (00813967) was issued to document this condition. The IR was accompanied by an evaluation, which concluded that the coating conditions did not pose an immediate operability concern. Repairs are planned per work order R2130898.

6) In 2008, the program excavated and inspected a 6" Condensate Transfer line located west of the Turbine Building. The inspection showed that the coating was in good condition.

7) In 2006, approximately 1000 feet of Fuel Oil Transfer Piping was replaced with double walled pipe and leak detection instrumentation. The approximate cost of the project was $600,000. This project reduced risk from Oyster Creek's highest risk underground systems.

Oyster Creek UndergroundPiping Program Description and Status Topical Report 1 6 Rev. 3 Page 4 of 82 The following significant corrective actions have been sponsored and are planned in the near future.

1) Inspection of three AOG Offgas lines before by December 2010 (IR 00686711).

2) Inspection of two 36" and 48" Offgas Holdup Lines by 2010 (IR 00698332).

3) The Program will sponsor a modification to replace underground small-bore lines which pose operational or environmental risks (IRs 00861654, 00861649, and 00861645).

4) Upon entering the period of extended operation, focused inspection of buried piping and components will be performed within ten years, unless an opportunistic inspection occurs within this ten-year period. The inspections will include at least one carbon steel, one aluminum and one cast iron pipe or component. In addition, for each of these materials, the locations selected for inspection will include at least one location where the pipe or component has not been previously replaced or recoated, if any such locations remain. The stainless steel piping in the vault will continue to be periodically inspected, and the bronze material is addressed by the buried carbon steel pipe coating inspections. (CM-1)

Oyster Creek UnulergroundPiping Program Descriptionand Status Topical Report 116 Rev. 3 Page 5 of 82 2.0 Table of Contents Section Title Page 1.0 Executive Summary 1 2.0 Table of Contents 3.0 Purpose 4.0 Program Background 5.0 Program Elements 6.0 Generic Problems 7.0 Program Priority # 1 Systems 8.0 High Susceptibility and Consequence Line -

2005 Review 9.0 Corrective Actions 10.0 References Appendix I Significant Underground Piping Leaks Appendix 2 1991 Review Matrix and Priorities 38 Appendix 3 Underground Piping Inspections 44 I I

Appendix 4 Inventory of Susceptibility and Consequence 42 Significant lines Appendix 5 Susceptibility and Consequence Significant 57 Specific Assessments.

Appendix 6 Susceptibility and Consequence Significant 60 lines I

Oyster Creek Undergrourul Piping Program Descriptionanti Status Topical Report 1 16 P Rev. 3 Page 6 of 82 3.0 Purpose This Topical Report describes the Oyster Creek Underground Piping Program and provides a status as of November 2007. It is intended that this report will be updated periodically (approximately every two years).

4.0 Program Background In the early 1990's after several events in which underground piping developed leaks, station management recognized that the material condition of underground pipe at Oyster Creek should be ascertained. In addition, generic and common failure mechanism for underground piping should be identified and corrected. As a result, the station initiated the Oyster Creek Underground Piping Program.

4.1 Program Objective The objective of the program is to ensure that the material condition of Oyster Creek underground piping remains satisfactory until the end of plant life, considering Nuclear Safety, Environmental Regulations, Plant Availability, and System Reliability.

In 2007, Exelon developed a Corporate program for raw water systems and underground piping (procedure ER-AA-5400). Oyster Creek became one of four Exelon plants to pilot the program. Revision 2 of this report provides a description of the program's transition to new Exelon Program.

4.2 Responsibilities Program administration is the responsibility of the Oyster Creek Programs Branch within the Engineering Department.

5.0 Program Elements This section describes the basic elements of the program 5.1 Operating Experience Significant input to the program is operating experience. As events occur at Oyster Creek related to underground piping leaks, the station ensures that the Programs Branch monitors related activities. The plant Corrective Action Process is used to track root cause and corrective actions. The Programs Branch reviews and evaluates events for generic and common mode failures. Appendix #1 provides a listing of significant underground leaks and the possible root cause of each.

5.2 Evaluations 5.2.1 Initial Review - 19911 In 1992, the program created an inventory of systems that had direct buried underground piping. A matrix was then developed which established the priority of each system plant based on Nuclear Safety, Environmental Impact, affect on

Oyster Creek Underground Piping Program Description and Status Topical Report 116 Rev. 3 Page 7 of 82 Plant Availability, and System Reliability (see appendix 2). The matrix then prioritized each underground system as follows:

Priority #1 - Systems that would have an immediate safety significance to the plant or create a significant environmental hazard if a leak were to develop.

Priority #2 - Systems that would require an eventually plant shutdown or an environmental impact.

Priority #3 - Systems that would not cause an immediate safety concern or a-plant shutdown, and would not result in an environmental hazard if a leak were to develop.'

In general, inspections and testing were performed in the early 1990's for priority

1. 1 systems. Section 7.0 provides a summary of the status of these systems.

5.2.2 1997 Review In 1997, a more refined review was performed of the program inventory. The review focused on system with underground pipe that contain contaminated fluids. The review, in general, did not look at the priority #1 systems from the 1991 review since activities were already underway to address identified problems. This review focusedon the priority #2 and some priority #3 systems.

The review focused on the susceptibility of each line for developing a leak and the radiological and environmental consequences of leaks should they occur. A revised matrix was developed in Which the susceptibility and consequence of a leak were evaluated (ref. 10.11).

5.2.3 2005 Review In 2004, Exelon announced the decision to pursue Licensing Life Extension of Oyster Creek to 2029. Therefore, since the 1991 and 1997 reviews did not consider operating Oyster Creek past 2009, the underground piping inventory was again evaluated. The evaluation focused on the susceptibility of each line developing a leak prior to 2029 and the radiological and environmental consequences of leaks should they occur. The revised matrix is documented in appendix 4 and 6 and new evaluations are documented in section 8. Resulting action items are tracked in section 9. TDR 1218 will no longer be updated.

5.2.3 2007 Risk Review Prior to 2007, each system in the program was evaluated for risk as single lines, which could be hundreds of feet long. In 2007 a new Risk Rank Evaluation was performed at a more refined level. All underground lines in the program were segmented in approximate 20-foot lengths. Then each segment was risk ranked.

The evaluation developed a segment data based that captures specific information for each segment and computes a risk ranks for every segment in accordance with ER-AA-5400. The results of this evaluation can be found in reference 10.23 and are consistent with the previous 1997 and 2005 evaluation. However, some

Oyster Creek UndergroundPiping Program Descriptionand Status Topical Report 116 Rev. 3 Page 8 of 82 inconsistencies do exist between the 2005 system risk rank evaluations and 2007 segmented risk rank evaluation. These differences will be resolved as the program continues to transition to the guidance of procedure ER-AA-5400. Section 7 and 8 document the reconciliation between high risked systems based on the 2005 system evaluation and the 2007 segmented evaluation.

5.3 Piping Inspections As a result of the 1991 review, a series of underground piping inspection were performed between 1991 and 1995. This was done by either excavating to the underground line to inspect external conditions or by internal video inspections.

Underground piping inspections have also been performed during targets of opportunities in which excavations were already being performed for other reasons. This is considered cost effective since the cost of excavating piping is expensive. Whenever an underground line leaks and is excavated for repair the root cause of the leak is investigated and the line is inspected to the greatest extent possible. In addition, any other lines that are in the excavation footprint are also inspected. Inspection results are incorporated into the program.

In 2007, new inspection technology (Guided Wave) was implemented to ascertain the condition of high priority lines. Results of the inspections are documented is sections 7 and 8 and in reference 10.24.

Appendix 3 provides a listing of all program related inspections.

5.4 Analysis Based on the results of operating history, program evaluations, inspections, and the priority of the affected systems corrective actions are developed.

5.5 Modifications For those generic mechanisms on systems with high priority, modifications have been evaluated and if cost justified recommended to plant management.

Completed and ongoing modifications are documented in section 6. Proposed modifications to the ESW and Service Water System are tracked in section 9.

5.6 Periodic Testing Oyster Creek utilizes the pump IST flow surveillances of various systems to demonstrate that the underground lines are not leaking, and as method of detecting a potential underground leak. Therefore, in 2008 applicable surveillance procedures were revised to alert operators that one of the possible reason for a pump IST failure could be an underground leak.

Oyster Creek UndergroundPiping ProgramDescription and Status Topical Report 116 Rev. 3 Page 9 of 82 t The table below provides a list of systems and surveillances.

Line /System ST /Procedure Frequency ESW System 1 607.4.017 Quarterly ESW System 2 607.4.017 Quarterly Service Water 641.4.001 Quarterly 641.4.006 Condensate 644.4.002 Quarterly Transfer System RBCCW System 642.4.001 Quarterly Fire Protection 645.6.023 Yearly Turbine Dirty Pressure test prior to use Every time the Lube Oil during a Refueling lines are used Transfer Lines Outage. See Section 7.5 5.7 Operate Until Failure For underground piping with #3 priority, there is no cost justification for wholesale changes. Therefore, the program has determined that these systems will be repaired as leaks occur.

5.8 Implementation Program inspections, tests, and corrective action are typically implemented per IRs and PIMS ARs with approval by PHC (Plant Health Committee) and PRC (Plant Review Committee). Complicated inspections and modifications that require excavation are typically performed per engineering approved specifications. Piping and coating degradation are typically identified, tracked and corrected per the CAP process. Operating procedure changes and periodic surveillances are implemented through the plant procedure change process.

Modifications to piping are developed, approved, and implemented through the Oyster Creek Project Approval Process I

Oyster Creek UndergroundPiping ProgramDescriptionand Status Topical Report 116 Rev. 3 Page 10 of 82 6.0 Generic Problems (CM-Il)

The program has identified several generic problems with underground piping. Below is a summary of each generic problem.

6.1 Aluminum Underground Piping Operating experience and numerous inspections has shown that there is a generic degradation mechanism with underground aluminum piping. The root cause of the mechanism is localized external coating failure and galvanic corrosion. As a result, the program has designated underground aluminum piping as having a high risk of developing leaks.

Plant experience shows that direct buried aluminum lines have leaked many times at Oyster Creek. In the past 15 years, Oyster Creek has replaced all but four of its consequence significant direct buried aluminum lines with above ground pipe. Past experience indicates that the service life of direct buried aluminum lines at Oyster Creek is 15 to 20 years. For example, the Condensate and Demineralized Water Transfer Pump Recirculation lines (WD-I and WD-2) developed leaks and were completely replaced (with direct buried pipe) in 1980. These same lines again developed leaks in 1992 and 1996 and were again replaced, this time with above ground piping.

The primary contributor the high corrosion rate of buried aluminum pipe at Oyster Creek is galvanic corrosion. The galvanic mechanism is primarily due to the interaction between the aluminum pipe wall and the large copper grounding grind located on the west side of the plant. The grounding grid protects the main transformers and other electrical equipment and lies in the same footprint as the majority of the direct buried aluminum pipe; before it was replaced by above ground pipe. The dissimilar metals and moisture in the soil result in a high electrical/chemical potential that drive the galvanic corrosion. Corrosion occurs in local areas where the coating was not properly applied or has broken down.

6.1.1 Condensate Transfer System The program has designated the Condensate Transfer System as a high consequence system. This is due to potential environmental consequences should system develop underground piping leaks and the possibility that a leak would force a plant shutdown.

A decision was made to relocate a significant portion of the underground system piping to either above ground, in engineered trenches, or in vaults. A modification was performed in 1996, which relocated the bulk of the system (ref.10.15). To date, only a few aluminum Condensate Transfer System lines (4) remain underground in contact with soil (see appendix 4). Inspection and modification of these lines are tracked in section 9. In 2007, the four remaining lines were inspected by Guided Wave Technology.

In 2008, a section one of these (line A-4) was excavated and inspected in accordance with procedure ER-AA-5400-1002. The coating system on this line

Oyster Creek UrunergroundPipinig Program Descriptionand Status Topical Report 16 Rev. 3 Page II of 82 J was installed in 1992. The results of the inspection showed that the external condition was acceptable (see section 8.2.2.2)

Reconciliation Between 2007 Segmented Risk Rank and 2005 Risk Rank The 2007 and the 2005 evaluation both consistently rank the remaining four direct buried Aluminum Condensate Transfer Lines with High Risk.

6.1.2 Demineralized Water Systems The remaining bulk of all other underground aluminum piping at Oyster Creek is mostly the Demineralized Water System. In 1998, a modification was performed to relocate all direct buried aluminum pipe with above ground pipe with the exception of one line (A-9) that provides Demineralized Water to the Reactor Building. The one exception was replaced in 1993 with direct buried pipe. The risk and consequence of a leak on this line has been assessed as low.

Reconciliation Between 2007 Segmented Risk Rank and 2005 Risk Rank The 2005 and the 2007 evaluation both consistently rank the remaining direct buried Aluminum Demineralized Water Lines with Low Risk.

6.2 Salt Water Systems with Carbon Steel Piping with Internal and External Coal Tar Coatings Operating experience and inspections has shown that there is a generic degradation mechanism with salt-water underground carbon steel piping with internal Coal Tar Coating. The root cause of the mechanism is that the coating system has reached its end service of life. The mechanism results in localized coating failures.

For internal coating, the localized failure allows salt water to come in contact with the carbon steel-piping wall, which results in pitting corrosion. Based on inspection of above ground piping the ESW and Service Water Systems have and will continue to experience internal localized coating failure (TDR 829). Based on inspections actual corrosion rates have been observed in both systems after the internal coating has degraded. It has been concluded that ESW System piping components that have experienced internal coating failure are corroding at a rate of approximately 12 mpy +/- 4 mpy and Service Water System piping components that have experienced internal coating -failure are corroding at a rate of approximately 10 mpy +/- 6 mpy (TDR 829).

For the external coating, the localized coating failure allows groundwater to come in contact with the carbon steel pipe wall, which may result in pitting corrosion or galvanic corrosion.

Oyster Creek Underground Piping ProgramDescriptionand!Status Topical Report I 16 v Rev. 3 Page 12 of 82 6.2.1 Service Water and ESW Systems The Service Water and ESW Systems have been designated as high consequence systems. This is due to the possibility that a significant underground leak in these systems could force plant shutdowns.

In 1992, a 20" underground Service Water line developed a leak. Since the leak located on piping approximately 23 feet below grade, extensive excavation was required to repair the line. Between 1992 and 2000, the Service Water System developed two additional underground pipe leaks that required extensive excavations. Also since 1992, numerous leaks have occurred on above ground Service Water and Circulating Water system lines that have the same coal tar coating. During the repair of these lines, the piping internal coating of was closely inspected. In some cases the inspections showed severe pitting corrosion.

Numerous activities have been performed to investigate potential solutions. The bulk of the 600 feet of Service Water and approximately 100 to 150 feet of ESW system underground piping has been internally inspected by a robotic video camera. Results of the video inspection show no significant gross degradation.

However, since the piping internal is covered with silt and biological growth, the remote videos cannot show the actual condition of the pipe coating below the silt and biologic growth. The videos do show evidence of what appears to be "rust blooms" in the silt and biological growth.

In August 2001, ESW System 2 developed an underground leak near the Startup Transformer and the Condensate Transfer Building (CAP 2001-1233). The leak put Oyster Creek in a seven day LCO (Limiting Condition of Operation). The leak had to be repaired in seven days or the plant would have to shutdown. The actual leak occurred at an underground branch connection located 23 feet below grade.

A similar leak occurred in 1996 on the Service Water System. The leaking area was too deeply buried and located under important plant equipment and could not be safely excavated in time to meet the 7 day deadline. Therefore, the decision was made to run approximately 250 feet of 14" pipe to bypass the leak. Since the plant only had seven days to install the new pipe, the decision was made to install uncoated carbon steel pipe, which has a limited service life in salt water.

In 2004, Oyster Creek again replaced this line, the same redundant line on the ESW System 1, and a similar Service Water System line. All three of these lines had a similar underground branch connection configuration. The original lines were direct buried 23' feet below grade while the new lines are within 5 feet of grade. The project replaced approximately 50% of all safety related ESW underground piping and 10% of all Service Water System Underground Piping.

A second phase was completed in 2008. With this second phase the remaining 50% of underground safety related ESW piping and an additional 10% of all Service Water System Underground Piping was replaced. The replacement of the ESW line became a commitment to the NRC for License Renewal (Passport assignment 00330592.26). Therefore, risk of an underground safety related ESW

Oyster Creek Underground Piping ProgramDescription andi Status Topical Report 116 Rev. 3 Page 13 of 82 System leak has been significantly reduced and the Risk Evaluation for the ESW System has been revised (Appendix 2, 4 and 5) and no longer considered "High Risk".

A third phase is planned for completion in 2010. This phase should install Cured In Place Pipe (CIPP) in the remaining underground portions of the Service Water System not modified in the previous two phases.

In early 2008, an underground leak developed on a portion of the Service Water System near the Intake. This portion of the system was to be replaced later in the year. In response, Oyster Creek Engineering developed a series of technical evaluations that demonstrated that ESW System 1 could be used as an alternate source of RBCCW Heat Exchanger cooling with the plant online. The technical evaluations became the basis for operating procedure changes. The revised operating procedures gave Oyster Creek the capability for taking the Service Water System out of service for a short duration to repair the leak while the plant remained on line. This new mode of operation took advantage on the ESW to Service Water System crosstie line, which was sponsored by this program and installed in 2002. The Service Water System was taken out of service for repairs while the plant remained on line. This was a first time evolution in the history of Oyster Creek. The new operational mode is available in the future in case the Service Water System again develops a leak.

Reconciliation Between 2007 Segmented Risk Rank and 2005 Risk Rank The 2007 and the 2005 evaluation both consistently rank underground portions of the ESW and Service Water System with high risk.

6.2.2 Thirty Inch Over-board line In 1991, the 30" Overboard Discharge line was designated as a medium consequence line system since a leak in this line would complicate plant operation.

In 1993, this line developed a significant leak in an area just down stream of an elbow located approximately 10 feet from the line discharge point at the discharge canal. The root cause was attributed to flow impingement on this downstream side of the elbow. The impingement is due to excessive velocities at this point, which worn away the internal coating and then allowed corrosion. A repair was performed 1994 by replacing an approximate 15-foot length of the line up to the discharge point. The repair included he application of an epoxy-based coating specifically intended for high velocities and abrasive environments In 1994, an internal robotic video inspection was performed on the bulk of this line during the repair. The inspection showed no gross degradation. Although the video showed evidence of the localized pitting, the structural integrity of the pipe remains un-compromised. This line is a gravity drain line and therefore is under a small amount of pressure.

Oyster Creek UndergroundPiping ProgramDescription and Status Topical Report i 16 Rev. 3 Page 14 of 82 In 1999 this line developed a large leak near the Service Water Seal Well close to and almost under the foundation to the Drywell Airlock. As result in 2000 Oyster Creek installed Cured In Place Pipe (CIPP) in the entire length of the 30" Overboard Discharge Line (reference OC-MD-H496-001). The completion of this project ensured that this line would be capable of performing its design function past 2029. The line is now considered a low risk.

Reconciliation Between 2007 Segmented Risk Rank and 2005 Risk Rank The 2007 and the 2005 evaluation both consistently rank the 30 Inch Overboard Discharge Line with Low Risk.

6.2.3 New Radwaste Service Water System This system is not applicable to the generic mechanism since the piping -coating system consists of internal cement lining and the external is an epoxy-based coating. /

Reconciliation Between 2007 Segmented Risk Rank and 2005 Risk Rank The 2007 and the 2005 evaluation both consistently rank this system with Low Risk.

6.3 Separation of Internal Coal Tar Coating Operating experience and inspections has shown that there is a generic degradation mechanism in which carbon steel piping with internal Coal Tar Coating experiences internal coating delaminating and separates from the piping in large pieces. In 1985, an event occurred in which a large amount of delaminated coating broke away from ESW internal piping and blocked the Containment Spray Heat Exchangers. Investigation into the root cause showed that the coating had degraded in ESW piping, which was located submersed in the plant intake. The root cause of the event was determined to be repeated temperature cycling of the coating material. This failure mechanism was evaluated to be limited only to ESW piping submersed in the intake.

This mechanism results in two potential adverse affects on the system. First, the large pieces of coating travel down the system and block system heat exchanger tube sheets.

Since the system operates intermittently and not continuously, the heat exchangers in a 1985 event were significantly blocked. The second adverse affect is that the piping internal walls are no longer protected from the salt-water environment. Therefore the ESW system has been designated as a high-risk system.

Corrective action at the time was to remove all internal coating in ESW piping submersed under the intake. This corrective action eliminated the build-up of coating material on the system heat exchangers but increased the corrosion of the piping that was stripped of internal coating.

Ovster Creek UndergroundPiping ProgramDescriptionand Status Topical Report 11 6 Rev. 3 I Page 15 of 82 In 1992 and 1993, the submerged piping was inspected and with some pipe replaced and coating repaired.

In 1R20 (2004), UT inspections were performed on the Service Water and ESW System headers submerged in the north intake bay using a diver to control the UT probe. Results of the inspection on the Service Water Pipe in the north intake bay showed that the external coating is in good condition. With the exception of one local area with internal corrosion, no external or internal coating breakdown was' observed. The remaining piping wall was measured at nominal thickness. The one degraded area will not corrode to below Tmin until at least 2010. This inspection provides confirmation that the coating system applied in 1992 and 1993 is not significantly degrading. AR A2047021 will track inspections of the south intake bay in 1R2 1.

The mechanism seems to have been limited to piping submersed under the intake.

Activities to monitor inspect, and correct the problem have been managed in separate activities and not directly through the Underground Piping Program, however the program has monitored activities related to this event for applicability to underground piping.

6.4 High Risk Small bore lines In 2008, it became apparent that there were a number of small-bore direct buried lines that pose high risk. These are lines that carry contaminated fluid which, if they leaked, couldresult in unmonitored radiological releases and/or plant transients. Because of their size these lines cannot be inspected using Guided Wave or "C Scan" Technology. Given that these lines will be expected to be in service for up to 60 years, it was decided that projects will be pursued to replace these lines with aboveground lines.

These lines are:

1) A 1" carbon steel Reactor Cleanup Sludge Transfer line (CS-1) to Radwaste and 1 1/2" RBEDT line to Radwaste (CS-5). These lines are located approximately 5 to 6 feet below grade south of the Reactor Building. Although these lines were inspected in 1997 and repaired, the inspection was only an external visual inspection. Since these lines transfer highly contaminated water, the consequences of a leak would be severe due to the high contamination levels of the sludge. IR 00861649 has been submitted to replace these lines.

2) An approximate 600' long 1 1/22" and 2" brass Instrument Air line (CS-37) that runs from the southwest corner of the Turbine Building to the Condensate Transfer Building and to the Intake. Except for a small portion near the intake road, this line has never been inspected. The small portion (less then 7 feet) near the intake road was inspected during a 2004 excavation (with no degradation observed). A leak of this line could result in a plant transient. IR (00861654)has been submitted to replace this line.

3) Two carbon steel 1-inch lines which run from the Turbine Building to either the Condensate Building or to the CST. One line is direct buried between the

Oysrer Creek UnderroundPiping Program Descriptionand Status Topical Report 116 Rev. 3 Page 16 of 82 condensate Building and the Turbine Building (CS-26) and supplies flow from the Hotwell Level Control System to the Condensate Pump Seals, only during plant startup and shutdown. The other line runs from the Northeast Corner of the Turbine Building to the CST (CS-38) and provides minimum recirculation flow from the CRD Pumps.

These lines were assessed as a medium risk factor since they are direct buried and could result in an unmonitored radiological leak and possibly lead to a plant shutdown. IR 00861645 has been submitted to replace these lines.

7.0 Priority # 1 Systems resulting from 1991 Review 7.1 ESW System Discussed in detail in sections 6.2 and 6.3. The ESW System, as of the 2008 replacement; is no longer considered a priority 1 System.

7.2 Service Water System Discussed in detail in sections 6.2.

7.3 Condensate Transfer Discussed in detail in sections 6.1 and 8.2.

7.4 Diesel Fuel Oil Transfer Line In 1986 this 2" line developed an underground leak that resulted in an unmonitored underground fuel oil release. This has become very expensive, since Oyster Creek is now required to clean up this spill. The line was repaired at the failed location.

In 2004 Oyster Creek made the decision to replace this line and two similar lines. In 2006 these lines were replaced with double wall pipe (ECR 04-00584 and PD 102026). The new lines included the Fuel Oil Transfer Line from the main tank to the EDG Storage Tank, the Fuel Oil Supply Line to the Boiler House, and the Minimum Recirculation line back the to main tank. 'All three lines are double wall pipe. The inner pipe carries the fuel oil, and the outer pipe contains instrumentation, which will alarm to a panel in the Boiler House in case the inner pipe leaks oil.

The Diesel Fuel Oil Transfer Line, as of the 2007 replacement, is no longer considered a priority I system.

Reconciliation Between 2007 Segmented Risk Rank and 2005 Risk Rank The 2007 and the 2005 evaluations both consistently rank underground portions of the Diesel Fuel Oil Transfer Line as High Risk. However, this evaluation did not considered the most recent modification, which replaced these lines with double walled pipe.

Therefore the database will require revision in the next update.

7.5 Turbine Lube Oil Transfer Lines

Oyster Creek UndergroundPiping Program Description and Status Topical Report 116 Rev. 3 Page 17 of 82 These lines transfer turbine lube oil from the Main Turbine Lube oil Tank to the Storage tank located west of the Turbine Building. The lines are only used during refueling outages when the turbine is overhauled. As a result of the 1991 program evaluation these lines were pressure tested successfully in 1993. This demonstrated that this line had not degraded. Follow-up review of the consequence should this line leak in the future shows that this line should be tested on a periodic basis.

In 2007, about 110 feet of each line were inspected per Guided Wave Technology and were found to be acceptable (reference 10.24)

Reconciliation Between 2007 Segmented Risk Rank and 2005 Risk Rank The 2007 and the 2005 evaluations consistently rank underground portions of the Turbine Lube Oil Transfer Line as High Risk.

7.6 Fire Protection System Fire protection system underground piping is made of carbon steel pipe with external coal tar coating and no internal coating. The process water in the system'is fresh water supplied by an onsite pond. Operating experience has indicated no generic problems with the system. Inspections during targets of opportunity have shown that the exterior coating is generally in good shape. No further action is planned at this time for this system.

In 2007, about 90 feet of these two lines was inspected per Guided Wave technology and were found to be acceptable (reference 10.24)

In 2008, a small portion of a 14" line was excavated and replaced including Fire Hydrant FH-19. This provided an opportunity to inspect a small section of the underground piping that supplied this hydrant. The inspection showed that the external coating of the carbon steel pipe was in acceptable conditions. In addition, inspection of the cast iron fire hydrant body showed that cast iron materials perform well in direct buried application.

(Reference Passport Assignment 00330592.26.27).

Reconciliation Between 2007 Segmented Risk Rank and 2005 Risk Rank The 2007 and the 2005 evaluations consistently rank underground portions of the Fire Protection System Lines with Low Risk.

7.7 Chlorine Injection Lines These lines inject chlorinated water in relatively high concentrations into the Service Water, ESW and Circulating water. A leak in one of these lines could cause an unmonitored underground release of chlorine. In addition, the released of chlorine would attack the external coal tar coating on other underground piping. In 1993 during modification to one of these lines a hydrostatic test was performed on the portion of the line that is underground. The test showed no degradation of this line. However, the material condition of the Service Water and Circulating Water System injection lines is unknown at this time.

Oyster Creek UndergroundPijiig Program Descriplion and Status Topical Report 116 Rev. 3 Page 18 of 82 In 2005, actions had been issued to inspect these lines during the planned excavation to tie in the ESW and Service Bypass modification in 2006.

However the ESW and Service Water modification was deferred form 2006 to 2008 and therefore the chlorine line the inspections were also deferred until 2008. Unfortunately the 3" chlorine line to the Service Water System developed a leak in the summer of 2006 near the Startup Transforms. The line was abandoned and a temporary hose was installed in it place. The ESW and Service Water modification was then revised to include the replacement of all three chlorine lines (ECR 07-00458).

In 2008, all three chlorination lines to the ESW and Service Water System were replaced with double-wall pipe. The Risk Evaluation for these lines has been revised (Appendix 2, 4 and 5) and they are no longer considered Priority I "High Risk".

Reconciliation Between 2007 Segmented Risk Rank and 2005 Risk Rank The 2007 and the 2005 evaluations consistently rank underground portions of the Chlorination System with High Risk. However, this evaluation did not -considered the planned modification, which replaces these lines with double-walled pipe. Therefore, the database will require revision after the modification is complete in the next update.

Oyster Creek Underground Pipihg ProgramDescription and Status Topical Report 116 Rev. 3 Page 19of82 8.0 Risk Ranking 8.1 Methodology 8.1.1f Data Collection The list of systems developed in 1991 and the underground lines developed in 1997 (TDR 1218) was revaluated. Also lines identified with the potential to affect plant capacity or accident mitigation were added to the inventory. Each line was assigned a program identification number.

A review was then performed of each remaining underground line to determine the following information:

1) Description and function

2) Size

3) Pipe material

4) Length of piping underground

5) Fluid and Level of contamination

6) Coating/ Protection

7) Depth Underground

8) Reference Drawings

9) Recent inspections and Repairs

10) Additional Comments Based on the above data each line was then assessed risk and consequence values per the criteria in section 8.1.2 through 8.1.4.

8.1.2 Susceptibility In 1997 and 2005, each line was assigned a Low, Medium or High "Probability" value based on the known conditions of existing pipe material, coating systems, and plant experience. ER-AA-5400-1003, which was implemented at Oyster Creek in 2007, requires a "Susceptibility Ranking" for underground piping segments. Review of section 4.1.3 and attachments 4 and 6 of procedure ER-AA-5400-1003 indicates that the following methodology (which was been renamed Susceptibility Ranking) meets the requirements of the new procedure.

The following criteria were used as a guide.

Low Susceptibility

• Line carries salt water, is carbon steel with internal coat tar coating and has been inspected within the last 20 years.

• Line is direct buried aluminum has been inspected within the last 10 years.

• Line is directed buried carbon steel with external coal tar coating and has been inspected within the last 30 years.

Oyster Creek UndergroundPipihg Program Descriptionand Status Topical Report 116 Rev. 3 Page 20 of 82

" Line is aluminum has been replaced within the last 15 years.

" Length of piping in vault or underground less than 20 feet, or

" Leak can be quickly detected, Medium Susceptibility

" Line carries salt water, is carbon steel with internal coal tar coating and has been inspected within the last 25 years.

• Line is direct buried aluminum has been inspected within the last 15 years.

" Line carries salt water, is carbon steel with internal coal tar coating and has been replaced within the last 35 years.

• Line is direct buried aluminum has been replaced within the last 20 years.

• Length of piping underground is more than 20' but less than 50',

• Leak cannot be quickly detected,

• Pipe wall material; Carbon Steel with Coal Tar Coating,

" Line is within an existing vault.

High Susceptibility

• Line has never been inspected or replaced,

• Length of piping underground is more 50',

• It would be difficult to detect a minor leak, or

" Material is aluminum.

8.1.3 Consequence In 1997 and 2005 each line was assigned a High, Medium or Low Environmental Consequence value and a High, Medium or Low Operational value. ER-AA-5400-1003 requires a "Consequence Ranking" which combines Operational and Environmental Consequences into one factor.

This revision will no only apply one Consequence Ranking consistent with the new procedure.

The following criteria will be considered:

Low Consequence

• Contamination level in fluid is Low (i.e.- Domestic Water, Air, RBCCW water, Raw Service Water, etc.)

" Leak would be easy to identify, access and repair,

• Line can be placed out of service without major complication to Plant Operations,

" Access to repair is easy (excavation would less than 5' deep with no interference).

Oyster Creek Underground Pipihg ProgramDescription and Status Topical Report 116 Rev. 3 Page 21 of 82 Medium Consequence

• Contamination Levels in fluid are Medium (i.e.- Condensate Transfer, Heating Steam and Condensate, Laundry drains, and Sumps)

" Leak would be harder to identify, access and repair,

" Repair would be timely and expensive,

• Leak may result in inability to transfer Clean-up sludge or Resin's thereby affecting outage windows or plant chemistry, or

• Access is more difficult (excavation is 5' to 8' deep with some inferences).

High Consequence

" Contamination Levels in fluid are High (i.e. Cleanup Filter Sludge, Cleanup Resins)

" Leak would be difficult to identify, access and repair,

• Leak will result in a Plant Trip,

• Leak may not be isolated and may result in a plant shutdown, or e Access is difficult (excavation is greater than 8' deep with interference's).

8.1.4 Deleted 8.1.5 Systems Excluded Below is a listing of systems not included in the evaluation and basis for exclusion:

1. Radwaste Service Water - This system has been concluded to be not a problem system. Reference TDR 1162 ,

2. Fire Protection - This system has been concluded to be not a problem system.

Reference TDR 1162

3. Fuel Oil - These lines were replaced in 2007 per ECR 04-00584.

4. N2 Tank- Leakage is not a radiological or immediate operational concern.

5. Hydrogen Injection - Leakage is not a radiological or immediate operational concern. This piping is cathodically protected and is encased with an external casing.

Oyster Creek UndergroundPiping Program Descriptionand Status Topical Report 116 Rev. 3 Page 22 of 82 8.1.6 Risk Assessment Analysis Further action for each line was then evaluated based on the following criteria for Susceptibility versus Consequence.

Review of section 4.1.5 of ER-AA-5400-1003 indicates that the following Analysis Methodology, which was established in 1997, meets the requirements of the procedure.

Risk High Consequence Medium Low Consequence Assessment (3 points) Consequence (1 points)

(2 points)

High Evaluate minimum Evaluate minimum Re-evaluate within Susceptibility expected service life expected service life five years.

(3 points) and develop and develop corrective action or corrective action or (3 Points) inspect within inspect within operating cycle. operating cycle.

(9 Points) (6 Points)

Medium Evaluate minimum Evaluate minimum Re-evaluate within Susceptibility expected service life expected service life five years (2 points) and develop and develop (2 Points) corrective action or corrective action or inspect within inspect within operating cycle. operating cycle.

(6 Points) (4 Points)

Low Evaluate minimum Re-evaluate within Re-evaluate within Susceptibility expected service life five years five years (1 points) and develop (2 Points) (1 Point) corrective action or inspect within operating cycle.

(3 Points) 8.2 Risk Assessment Results 8.2.1 General Results A great deal of the underground piping at Oyster Creek that contains contaminate fluids is contained in piping tunnels that are below grade. These tunnels begin on east wall of the Turbine Building, run north to the Reactor Building, then east along the south wall of the Reactor Building, to the base of the Stack, then to Old Radwaste along the west wall of the Reactor Building. Any leakage in from these lines would flow to the 1-12 sump in

Oyster Creek UndergroundPiping ProgramDescriptionand Status Topical Report H16 Rev. 3 Page 23 of 82 the base of the stack. Therefore, piping leaks in the piping tunnel represent low risk and low radiological consequence.

The majority of the risk and consequence significant direct buried underground lines at Oyster Creek lie either to the south of the Reactor Building or to the west of the Turbine building. See Appendix 6 for markups of plant underground drawings.

In the 1990's, Oyster Creek performed inspections and replaced portions of risk and consequence significant direct buried underground lines. These inspections are documented in the matrix in appendix 4.

8.2.2 High Susceptibility with High to Medium Consequence Refer to appendix 4, 5, and 6.

8.2.2.1) Offgas Holdup Lines (CS-19 and CS-20)

Approximately 510 feet of 48" piping (CS-19) and 400 feet of 36" piping (CS-20) for the Offgas Holdup Lines located south of the Reactor Building between the Office Building and the Stack. These lines are carbon steel with coal tar internal and external coating.

These lines have been determined to have a high risk of developing a leak due to the history at Oyster Creek in which underground carbon steel piping with coal tar coating has develop corrosion due to coating degradation. These lines were installed in 1968 and have never been inspected. Since the fluid in this piping is radioactive gas with some water vapor, leakage through the piping may contaminate the surrounding soil. On occasion during power operation these lines have filled with process water. A minor leak would probably not be observed. A major leak Would most likely shutdown the plant due to an uncontrolled release path.

Significant degradation of these lines will most likely be due to external attack on the coating and external corrosion of the carbon steel pipe wall. Based on plant operating experience the coating has the potential service life of 15-40 years and the pipe wall has the potential life of 25 to 60 years. Therefore, assuming the coating was properly applied these lines have a minimum service life of 40 years. Therefore since these lines were last inspected in 1969 they should be inspected prior to 2009. During 2007 these lines were considered for inspection by using Guided Wave and "C" Scan Technologies.

Unfortunately, the "C" Scan technology does not seem to by a good application for these lines. The technology requires isolation of the line from equipment such as pump, valves that are throttled and Steam Jet Air Ejectors. Also the configuration of these the two lines, which run in close together in the soil, will cause signal interferences and cross talk.

However, Guided Wave scanning is possible if the inspections are performed from within excavation in the yard south of the Reactor Building for the following reasons.

1) The lines are too long for the signals to travel their entire -length.

Oyster Creek UndergroundPiping Progrom Descriptionand Status Topical Report 1 16

. Rev. 3 Page 24 of 82

2) Both ends of the lines in the Turbine Building and in the Stack do no have accessible lengths of pipe in which a collar can be installed.

3) The radiation and contamination levels in the base of the stack would result in significant exposure to the inspectors.

4) The radiation and contamination levels in Steam Jet Air Ejector Room would result in significant exposure to the inspectors and to support personnel that would be required to build scaffolding..

5) Since both lines contain a gas mixture, which could create acoustical interferences while in service, a system outage is necessary to perform the inspections. Please Note the actual inspection, once the collar is installed, takes minutes.

Given the above limitations, it has been decided that performing an approximately 16 foot deep excavation and allowing access to the lines about mid length is 'the best alternative.

The following strategy has been developed.

1) Excavate and expose the lines prior to 1R23. The excavation will require shoring.

2) During 1R23 while the lines are out of service remove enough coating so that the collars can be installed.

3) Perform the inspection.

4) Install permanent cables to the lines and run them to grade so that "C" Scan Inspections can be performed in the future without the need for excavations.

(This is not an option for Guide Wave).

5) Recoat During I R23

6) Backfill after 1R23 This project has been entered in to the Plant Health Committee (PHC) process and was originally proposed for the 1R22 Refueling Outage in 2008. However, the Plant Review Committee (PRC) tabled this project for 2008 and recommended implementation in 2010 during the 1R23 Outage. This project is tracked in the funding and work management systems as IR 00698332 and Profolio Directory Number 134307.

Reconciliation Between 2007 Segmented Risk Rank and 2005 Risk Rank The 2007 segmented risk ranking evaluation did not rank these lines with high-risk ranking (none in the top 30 segments). However, actions are being pursued based on the 2005 evaluation. Future revisions of the data based should correct this discrepancy.

8.2.2.2 Condensate Transfer Line To Turbine Building (A-4)

An approximate 25' long portion of a 6" Condensate Transfer line (A-4) from the Condensate Transfer Pumps to the Turbine Building. This is the main Condensate

Oyster Creek Underground Piping ProgramDescription and Status Topical Report 116 Rev. 3 Page 25 of 82 Transfer System supply line to the plant. Risk of this line developing a through wall leak is high.

Plant experience shows that direct buried aluminum lines have leaked many times at Oyster Creek. In the past 15 years Oyster Creek has replaced all but four of its direct buried aluminum lines with above ground pipe.

A search of the configuration management system records indicates that this line (CH-5, A4) is still an original line.

This line has a medium radiological and operating risk. A leak of this line would result in an unmonitored leak of contaminated water. Also a significant leak would challenge the plant's ability to makeup water to the Condensate System, the Isolation Condensers and various other plant systems.

It is not certain if this line was inspected during a 1993 activity in which the area was excavated. The excavation was performed to repair a leak on an adjacent line. Review of the underground drawings and photos taken at the time of the excavation indicates that this line should have been exposed. Therefore the assumption is made that the coating of this line was inspected and repaired as necessary in 1993. Therefore assuming a service life of 15 to 20 this line should be inspected within 15 years of the previous 1993 inspection (2008). No credit was applied for the pipe wall in the service life assessment in Appendix 4.

This line was inspected in 2007 using Guided Wave Technology, with acceptable results.

Results are documented in reference 10.23.

In 2008, this line was then excavated and partially inspected (approximately 10 feet). The coating was found to be in very good condition. This inspection substantiated the Guided Wave Inspection performed in 2007. This inspection met a License Renewal commitment documented in Passport Assignment 00330592.27.26. This was the first inspection of the new coating installed on aluminum pipe. The Risk Evaluation for this line has been revised (Appendix 2, 4 and 5) and is no longer considered "High Risk".

Reconciliation Between 2007 Segmented Risk Rank and 2005 Risk Rank The 2007 and the 2005 evaluations consistently rank this underground line as High Risk.

8.2.2.3) Condensate Transfer line To CRD System (A-I)

A 4-foot long portion of a 12" Condensate Transfer line (Al) from the CST to the Core Spray System and the CRD pumps. This aluminum line is located between the Turbine Building and the Reactor Building on the northwest comer of the Reactor Building and is*

inaccessible. In 1998, a project was performed to core bore the concrete slab above the gap in this area. A sample well was then installed under the condensate transfer line. The well showed that there was no moisture under the line. Soil samples showed no residual traces of tritium in the soil. However no coating and wall thickness measurements were possible.

Oyster Creek UndergroundPiping ProgramDescriptionand Status Topical Report 116 Rev. 3 Page 26 of 82 The primary contributor the high corrosion rate of buried aluminum pipe at Oyster Creek is galvanic corrosion. The galvanic mechanism is due to the interaction between the aluminum pipe wall and the large copper-grounding grid located on the west side of the plant. The grounding grid protects the main transformers and other electrical equipment and lies in the same footprint as the majority of the direct buried aluminum pipe; before it was replaced by above ground pipe. The dissimilar metals and moisture in the soil result in a high electrical/chemical potential that drives the galvanic corrosion. Corrosion occurs in moist areas where the external coating was not properly applied or has broken down.

However, this line is not located near the grounding grid or any other cooper materials and the soil is dry. The technical literature indicates that corrosion rate for aluminum in dry soil is at least half magnitude of corrosion rates in wet soil (reference 8.10).

This line was assessed a medium consequence value since it supplies condensate to the CRD Pumps. Also a leak of this line would result in an unmonitored release.

The 1998, inspection did not inspect coating or pipe wall. It simply tested for leakage in the soil under the line. Since a pipe leak was not found in 1998 it was concluded that coating was properly applied and credit was taken for the coating service life.

Significant degradation of these lines will most likely be due to external attack on the coating and external corrosion of the carbon steel pipe wall in dry soil. Based on plant experience and technical references the coating has the potential service life of 15-40 years and the pipe wall has a potential life of 25 to 50 years, based on dry soil. Therefore assuming the coating was properly applied and a galvanic corrosion mechanism does not exist, this line has a minimum service life of 40 years. Therefore this line should be inspected by 2009.

In 2007, this line was inspected using Guided Wave Technology. The inspection showed that this line wall had no wall loss. Therefore, as of 2007, this line is acceptable. Follow up inspection should be within five years.

Reconciliation Between 2007 Segmented Risk Rank and 2005 Risk Rank The 2007 and the 2005 evaluations consistently rank this underground 'line as High Risk.

8.2.2.4) Radwaste Lines To Pipe Tunnel (CS-6, CS-7, and CS-8)

Three carbon steel lines: a 2" Laundry Drain line (CS-6), a 3" Reactor Building Sump line (CS-7), and a 2" DWEDT line (CS-8). These lines run from the Reactor Building to the Pipe Tunnel in the southeast Vault. These lines were inspected and repaired as necessary in 1993. These lines were once again inspected during 2001 and found with no coating degradation. They were again inspected in 2004 and coating degradation was observed. CAP 02004-2071 was issued to document the problem. Pipe wall thickness inspection of these lines confirmed that wall thickness was acceptable (reference 02004 2071). The external coating was then repaired. Based on this experience, the risk of a

OysierCreek UndergroundPipihg ProgramDescription and Siatus Topical Report 16 Rev. 3 Page 27 of 82 coating breakdown is ranked high. Since these lines carry contaminated water the consequences of a leak is considered medium.

The pipe in the southeast vault is located 10 to 12 feet below grade, which is below the water table. Therefore, these lines are submersed in ground water. In addition two of these lines operate at elevated temperature. Since the coating on these lines was acceptable in 2001 and not acceptable in 2004 no credit can be taken for coating service life. As part of the CAP Corrective Action the System manager has recommended establishing a PM to drain the southeast vault every two years and inspect these lines.

Based on plant experience, pipe wall on these lines has a potential life of at least 5 years.

Therefore these lines should be inspected every two years.

In 2007 an attempt was made to inspect this line using Guided Wave Technology from in side the pipe tunnel. Unfortunately the Guided Wave collar could not be placed on the lines due to interferences (see IR 00686711). A new project has been submitted for 2008 where these lines will be inspected from the Reactor Building side (PD 122655).

In 2008 the coating on these three lines was inspected as part of a new PM (PM PM57304M). This PM opens and drains water out of the vault. This PM was developed to support License Renewal Commitments (Passport assignment 00330592.26.20). The inspection found that the coating on these three lines had broken down and required repair. An IR was issued to document this condition. The IR (00813967) was accompanied by an evaluation, which concluded that the coating conditions did not pose an immediate operability concern. Repairs are planned per work order R2130898.

Reconciliation Between 2007 Segmented Risk Rank and 2005 Risk Rank The 2007 and the 2005 evaluations consistently rank these underground lines as High Risk.

8.2.3 Medium and Low Susceptibility and High Consequence 8.2.3.1) Reactor Cleanup Sludge Transfer Line (CS-1)

A I" carbon steel Reactor Cleanup Sludge Transfer line (CS-1) to Radwaste. This line is located approximately five to six feet below grade in the central vault south of the Reactor Building and is therefore not in direct contact with soil. Although this line was inspected in 1997 and repaired, the inspection was only an external visual inspection.

Since this line transfers highly contaminated RWCU filter sludge, the consequences of a leak would be severe due to the high contamination levels of the sludge.

This line is not expected to be submerged in ground water, as is the case of piping in the southeast vault. The piping in the central vault is located approximately four to six feet from grade, which is above the water table. While the pipe in the southeast vault is located 10 to 12 feet below grade, which is below the water table.

Oyster Creek UndergroundPijbing ProgramDescriptionand Status Topical Report H16 Rev. 3 Page 28 of 82 Degradation of this line would most likely be due to degradation of the coating and external corrosion of the carbon steel pipe wall. Based on plant operating experience the coating has the minimum service life of 15 years. No credit will be taken for the pipe wall since UT measurements were not performed in 1997. Therefore this line should be inspected within 15 years of the last inspection (2012).

In 2007, this line was considered for Guide Wave Inspection. Unfortunately, the technology cannot inspect lines that are 1 inch in diameter or smaller. In addition, this line is too short for "C Scan" Technology.

Therefore, a project to replace this line should be considered for funding 2010 for installation in 2012.

Reconciliation Between 2007 Segmented Risk Rank and 2005 Risk Rank The 2007 and the 2005 evaluations consistently rank this underground line as High Risk.

8.2.3.2) Reactor Cleanup Lines (SS-1 and SS-2)

Two 3" stainless steel Reactor Cleanup lines. These lines are direct buried south of the Reactor Building, between the RB and Pipe Tunnel. These lines were inspected in 1993.

The lines were then backfilled and are no longer accessible. Since these lines transfer contaminated RWCU Demin. Resins, and Condensate, a leak would result in an unmonitored release of contaminated fluid.

Degradation of these lines will most likely be due to degradation of the coating and external corrosion of the stainless steel pipe wall. Based on plant operating experience the coating has the potential service life of 15 to 40 years and the pipe wall has the potential life of 15 to 30 years. Therefore this line should be excavated and inspected within 30 years of the last inspection (2023). These lines are not submerged in ground water.

In 2007, an attempt was made to inspect this line using Guided Wave Technology from in side the pipe tunnel. Unfortunately the Guided Wave collar could not be placed on the lines due to interferences. A new project has been submitted for 2010 where these lines will be inspected from the Reactor Building side.

Reconciliation Between 2007 Segmented Risk Rank and 2005 Risk Rank The 2007 and the 2005 evaluations consistently rank this underground line as High Risk.

8.2.3.3) Air and Containment Spray Lines in SE Vault (CS-9, CS-10, and CS-11)

Three carbon steel lines: a 4" Instrument Air line (CS-10), a 4" Instrument Air line 2" (CS-11), and a 14" Containment Spray line (CS-9). These lines run from the Reactor Building to the Pipe Tunnel in the southeast a vault. These lines were inspected and repaired as necessary in 1993. UT inspection in 1993 showed the pipe wall was acceptable. These lines were once again inspected during 2001 and 2004 and the external coating was found to be acceptable. The pipe in the southeast vault is located 10 to 12 feet below grade, which is below the water table. However 2001 and 2004 inspections show that the coating has stood up fairly well since 1993.

Oyster Creek Underground PipingProgramDescription and Status Topical Report 116 Rev. 3 Page 29 of 82 Should the Instrument Air line develop a significant leak, the plant would probably trip due to loss of instrument air. Also a leak on the Containment Spray line could place the plant in an LCO. Therefore these lines were assessed a high consequence value.

Based on plant operating experience the coating has the potential service life of at least 10 years and the pipe wall has the potential life of 8 to 30 years. Therefore this line should be inspected within 18 years from of the last inspection. However since these lines are located in the same southeast vault as CS-6, CS-7, and CS-8, which have a much shorter expected service life (see section 8.2.2.4) they will be inspected at a greater frequency.

In 2007 these lines were inspected using Guided Wave Technology. The inspection showed that the line pipe wall was in acceptable condition. Therefore as of 2007 this line is acceptable. Follow up inspection shall be within 5 years.

In 2008 the coating on these three lines was inspected as part of a new PM (P.M PM57304M). This PM opens the vault and drains water out of the vault. This PM was developed to support License Renewal Commitments (Passport assignment 00330592.26.20). The inspection found that the coating on the two airlines had broken down and required repair. An IR (00813967) was issued to document this condition. The IR was accompanied by an evaluation, which concluded that the coating conditions did not pose an immediate operability concern.

Reconciliation Between 2007 Segmented Risk Rank and 2005 Risk Rank The 2007 and the 2005 evaluations consistently rank these underground lines as High Risk.

8.2.3.4) Control Air Line to Intake and Condensate Transfer Building (CS-37)

An approximately 600' long 1 1/22" and 2" brass Instrument Air line that runs from the southwest corner of the Turbine Building to the Condensate Transfer Building and to the Intake. Except for a small portion near the intake road this line has never been inspected.

The small portion (less then 7 feet) near the intake road was inspected during a 2004 excavation. The excavation was performed to tie-in the new ESW and Service water System underground piping. The inspection of the line was only external and did not perform thickness testing.

The technical literature indicates that corrosion rates of brass in soils are relatively low (i.e. 1 to 5 mpy (references 10.20 and 10.21). Based on plant operating experience the coating has the potential service life of 15 to 40 years and the pipe wall has the potential life of 25 to 60 years. Therefore this line should be inspected or tested within 40 years of the installation (2009). A significant leak on this line could result in a plant trip.

Therefore the operating consequence is rated high.

Oyster Creek UndergroundPiping ProgramDescriptionand Status Topical Report 116 Rev. 3 Page 30 of 82 In 2007, an attempt was made to inspect this line using Guided Wave Technology from in side the Chlorination Building. Unfortunately this line is 1 1/2" at this location and the vendor currently does not have a collar which fits pipe of this size.

In 2008, a spare line was laid across the northwest intake road during the modification which replaced the chlorination lines (reference ECR 07-00459). Since the most costly part of running a new small bore line from the Chlorination Building to the Intake is getting across the north to south intake road, it was decided to run a spare line for the air system. In the future a modification could be pursued to replace the remainder-of the line by 2010. IR has been submitted to pursue a modification.

Reconciliation Between 2007 Segmented Risk Rank and 2005 Risk Rank The 2007, segmented risk ranking evaluation did not rank this line with high-risk ranking (none in the top 30 segments). However, action are being pursued based on the 2005 evaluation. Future revisions of the data based should corrective this discrepancy.

8.2.3.5) Condensate Transfer Line to Reactor Building (A-2)

A 10-foot long portion of a 6" Condensate Transfer line from the Pipe Tunnel to the Reactor Building at the southwest corner of the Reactor Building. This is the main Condensate Transfer System line to the Reactor Building. In 1980 this line was excavated, inspected and repaired. Records indicate the coating was repaired. A vault was then built around the line.

The primary contributor for the high corrosion rate of buried aluminum pipe at Oyster Creek is galvanic corrosion. The galvanic mechanism is due to the aluminum pipe wall and the large copper-grounding grid located on the west side of the plant. However this line is not located near the ground grid and is no longer direct buried. Therefore the same corrosion mechanism may not be applicable. Since this line is located 4 feet from grade, it is not submerged in ground water.

This line was assessed a medium consequence value since it supplies condensate to the Reactor Building including the Isolation Condensers. Also a leak of this line would result in an unmonitored release. Therefore this line was assessed a medium radiological consequence.

Degradation of this line will most likely be due to degradation of the coating and external corrosion of the aluminum pipe wall. Based on plant operating experience the coating has the potential service life of 15 to 40 years and based on dry soil, the pipe wall has the potential life of 20 to 40 years. Therefore this line should be excavated and inspected within 35 years of the last inspection (2015).

In 2007 an attempt was made to inspect this line using Guided Wave Technology from in side the Pipe Tunnel. Unfortunately the GW collar could not be placed on the lines due to interferences (IR 00686711). A new project has been submitted for 2010 where these lines will be inspected from the Reactor Building side (PD 122655).

Oyster Creek UndergroundPiping ProgramDescriptionand Status Topical Report 116 Rev. 3 Page 31 of82 Reconciliation Between 2007 Segmented Risk Rank and 2005 Risk Rank The 2007 and the 2005 evaluation both consistently rank these underground lines with High Risk.

8.2.4 Medium Susceptibility and Medium Consequence 8.2.4.1) Radwaste Line to Pipe tunnel (CS-2, CS-3, CS-4, and CS-5)

Four lines located in the central vault south of the Reactor Building. These are: the Cleanup High Purity Transfer line to Radwaste, the Fuel Pool Cooling Transfer Line to Radwaste, the Cleanup System High Purity Transfer line to the Condensate System, and the RBEDT drain line to Radwaste.

In 1997 the 6" Fuel Pool Cooling line (NN-3, A-3) developed a leak. An excavation was performed to replace this line. The excavation exposed these four lines. Therefore these lines were inspected and the coating repaired. A vault was then built around these lines.

Therefore they are no longer direct buried. Also since these lines are located between 5 and 6 feet from they do experience ground water submergence.

Degradation of these lines will most likely be due to degradation of the coating and external corrosion of the carbon steel pipe wall. Based on plant operating experience the coating has the potential service life of 15 to 40 years and the pipe wall has the potential life of 6 to 25 years. Therefore these lines should be inspected within 21 years of the last inspection (2018).

In 2007 an attempt was made to inspect this line using Guided Wave Technology from in side the pipe tunnel. Unfortunately the GW collar could not be placed on the lines due to interferences . A new project has been submitted for 2010 where these lines will be inspected from the Reactor Building side (PD Number 122655).

8.2.4.2) RBCCW Lines (CS-17 and CS-18)

Two 8" carbon steel lines are direct buried between the south side of the Reactor Building and the Pipe Tunnel. These lines are RBCCW lines that run to Old Radwaste.

The equipment that these lines cool have long been abandoned. The lines were cut and capped in Old Radwaste. However, the portions of these lines that are direct buried and in the Pipe Tunnel are still pressurized. Therefore a leak would result in a loss of inventory in the RBCCW System and a significant leak could trip the plant.

These lines were assessed as a medium risk factor since they are direct buried carbon steel lines. These lines were assessed a medium factor since a leak could lead to a plant shutdown.

Degradation of these lines will most likely be due to degradation of the coating and external corrosion of the carbon steel pipe wall. Based on plant operating experience the

Oyster Creek UndergroundPiping Program Descriptionand Status Topical Report 116 Rev. 3 Page 32 of 82 coating has the potential service life of 15 to 40 years. Therefore these lines have a minimum service life of 15 years. No credit was taken for the pipe wall. Since these lines were inspected (coating only) in 1993 they should be abandoned by 2010.

In 2007 an attempt was made to inspect this line using Guided Wave Technology from in side the pipe tunnel. Unfortunately the GW collar could not be placed on the lines due to interferences. A new project has been submitted for 2010 where these lines will be inspected from the Reactor Building side (PD Number 122655).

8.2.4.3) AOG Lines (CS-22, CS-23 and CS-30)

Three Offgas lines are direct buried between the AOG Building and the Stack. These lines are AOG Offgas supply and return lines and the AOG Building sump Drain line and were installed in the early mid 1980's.

These lines were assessed as a medium risk factor since they are direct buried and have not been inspected since installation in the mid 1980's. These lines were assessed a medium Radiological factor, since a leak could lead to an unmonitored release.

Degradation of these lines will most likely be due to degradation of the coating and external corrosion of the carbon steel pipe wall. Based on plant operating experience the coating has the potential service life of 15 to 40 years and the pipe wall has the potential life of 10 to 40 years. Therefore assuming the coating was properly applied these lines have the service life of a minimum of 25 years. Therefore, these lines should be inspected or pressure tested.

In 2007, an attempt was made to inspect this line using Guided Wave Technology from an excavation near the Main Fuel Oil Tank. Unfortunately the excavation could not be performed in time to support the inspection scheduled. A new project has been submitted for 2009 where these lines will be inspected (PD Number 122655).

8.2.4.4) Condensate Transfer Line to Turbine Building (CS-24)

A 10" carbon steel line is direct buried between the Condensate Building and the Turbine Building. This line supplies flow from the Hot Level Control System in the Condensate Building to the Hotwell.

This line was assessed as a Medium Risk factor since it is direct buried carbon steel line.

This line was assessed a medium Radiological Consequence factor since a leak could lead to an unmonitored release and a Medium Consequence factor since a significant leak could lead to a plant shutdown.

Degradation of this line will most likely be due to degradation of the coating and external corrosion of the carbon steel pipe wall. Based on plant operating experience the coating has the potential service life of 15 to 40 years and the pipe wall has the potential life of

Oyster Creek UndergroundPiping ProgramDescription and Status Topical Report 116 Rev. 3 I Page 33 of 82 12 to 50 years. Therefore, these lines should have a minimum service life of 27 years.

Since this line was inspected in 1993 it should be inspected or pressure tested by 2020.

In 2007, an attempt was made to inspect this line using Guided Wave Technology from inside the Condensate Building. Unfortunately the inspection was not successful due to high acoustic signals created by the hotwell level control valves in the Condensate Building. A new project has been submitted for 2010 where these lines will be inspected from inside the Turbine Building during 1R23 (PD Number 122655).

8.2.4.5 Condensate Pump Startup Seal Water Line and CST Return Line (CS-26 and CS-38)

These are two carbon steel 1-inch lines, which run from the Turbine Building to either the Condensate Building or to the CST. One line is direct buried between the Condensate Building and the Turbine Building (CS-26) and supplies flow from the Hotwell Level Control System to the Condensate Pump Seals, only during plant startup and shutdown.

The other Line runs from the Northeast Comer of the Turbine Building to the CST (CS-

38) and provides minimum recirculation flow from the CRD Pumps.

These lines were assessed as a medium risk factor since they are direct buried and could result in an unmonitored radiological leak and possibly lead to a plant shutdown.

Degradation of these lines will most likely be due to degradation of the coating and external corrosion of the carbon steel pipe wall. Based on plant operating experience the coating has the potential service life of 15 to 40 years and the pipe wall has the potential life of 4 to 15 years. Therefore these lines should have a minimum service life of 19 years. Since these line were inspected in 1993 they should be re-inspected, pressure tested or replaced by 2012.

In 2007, these lines were considered for Guide Wave Inspection. Unfortunately the technology cannot inspect lines that are 1 inch in diameter or smaller. In addition these lines are too short for "C Scan" Technology.

Therefore, a project to replace these lines willbe pursued for funding in 2009 for and installation in 2010. An IR has been submitted to pursue modification of these lines.

8.2.4.6 Chlorination Lines CS-35 Three 3" carbon steel lines are direct buried between the Condensate Building and the intake. These lines supply chlorination water to the Service Water and the ESW Systems.

These lines are internally coated with a plastic liner and externally coated with coal tar.

These lines were assessed as a medium risk factor since they are direct buried carbon steel lines. These lines were assessed a medium consequence factor since a leak could result in an unmonitored release for chlorine.

Oyster Creek Undergroundt Piping ProgramDescription andi Status Topical Report 11 6 Rev. 3 Page 34 of 82 Degradation of these lines will most likely be due to degradation of the external coating and external corrosion of the carbon steel pipe wall. Based on plant operating experience the coating has the potential service life of 15 to 40 years and the pipe wall has the potential life of 8 to 30 years. Therefore these lines should have a minimum service life of 23 years. Since these lines were installed in the mid 1980's the 2005 assessment of these lines concluded that they should have been inspected by 2006. An opportunity had been planned to inspect these lines during the planned modification to the ESW and Service Water System in 2006. Unfortunately in 2006 the modification was deferred until 2008, which also deferred the inspection.

In 2006, the Chlorine Line to the Service Water System leaked at a location that was below under the Chlorination Building (IR A2144398). The leakage caused a large "sink hole" on the south side of the Chlorination Building near the north Startup Transformer.

The leak was terminated about 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> later by slipping a pancake flange between two flanges. The line was then abandoned and was temporarily replaced by a hose (reference the TCCP 06-00506).

As a result of this 2006 leak, the scope of the existing project to replace underground ESW and Service Water line was increased to also replace the three Chlorination Lines (ECR 07-00459). Completion was scheduled for 2008.

In 2008, all three chlorination lines to the ESW and Service Water System were replaced with double-wall pipe. The Risk Evaluation for these lines has been revised (Appendix 2, 4 and 5) and they are no longer considered Priority I "High Risk".

8.2.4.7 Torus to TWST Transfer Line CS-31 This line is a 4" Carbon Steel Line that was originally used to transfer water from the Torus to the Torus Water Storage Tank (TWST). This line may be used in future outages to transfer water from Torus to the TWST during Torus coating inspections and repairs.

In the past this line was occasionally used to transfer radwaste water to the TWST.

Therefore the internal wall of the line is considered contaminated. The material condition of this line is not known.

This line was assessed as a medium risk factor since it is a direct buried carbon steel line with a medium Consequence factor since a leak could result in an unmonitored release of contaminated water.

Degradation of this line will most likely be due to degradation of the external coating and external corrosion of the carbon steel pipe wall. Based on plant operating experience the coating has the potential service life of 15 to 40 years and the pipe wall has the potential life of 8 to 30 years. Therefore, these lines should have a minimum service life of 23 years. Since these lines were installed in the mid 1980's lines should be inspected by 2008.

Oyster Creek UnderroundPipingProgram Description and Status Topical Report 116 Rev. 3 Page 35 of 82 Approximately 70 to 90 feet of this line from the TWST Tank was inspected using Guided Wave Technology in 2007. Results showed 40% to 70 % wall loss in large sections of the inspected pipe. Therefore per the directions of corporate procedure ER-AA-5400 this line shall no longer be used for service. IR 00709720 was issued to document the material condition of this line and to recommend flushing this line and abandonment.

During a separate modification to install a dedicated demineralized water tank for the Isolation Condensers in 2008, this line was excavated and found to be in the footprint of the new tank. Therefore, approximately .60 feet of this line was removed.

8.2.4.8 Heating Steam Line Leak in 2007 In 2007, per WO C2016333 an excavation exposed about 6 to 8 feet of the underground 8" Reactor Building Boiler Steam Supply Line located just south of Reactor Building.

This excavation was performed because the line has a steam leak in the Pipe Tunnel penetration. The excavation was necessary to expose the outside of the penetration so that the location of the leak could be identified and the line inside the penetration could be replaced.

The general condition of the exposed 8" line was that the external coating has completely broken down which. has allowed soil to contact the carbon steel pipe wall. The exposed pipe wall showed signs of general corrosion. UT inspections were performed in four separate areas. The UT inspections found pipe wall thicknesses that varied between 0.08 inches and 0.2 inches. The original pipe wall was 0.322 inches.

Corrective action was to excavate and replace the entire line. This underground portion of this line is only about 10 to 12 feet long. About 6 to 8 feet have already been excavated.

The replacement included an improved coating system for the elevated temperatures of this steam line.

Oyster Creek Underground PipinigProgram Descriptionandi Status Topical Report 116 Rev. 3 Page 36 of 82 9.0 Corrective Actions 9.1 Program Actions Actions 9.1.1 and 9.1.2 are complete and have been deleted.

9.1.3) Three Offgas lines which are direct buried between the AOG Building and the Stack should be inspected before December 2010. These lines are direct buried within 5 feet of grade and may be inspected online.

IR 00696852 and PD 122655 have been issued to obtain funding approval in 2009.

9.1.4) Three 3" carbon steel Chlorination lines that are direct buried between the Condensate Building and the Intake Structure will be replaced per ECR 07-00459. This project is scheduled for complete in 2008.

Status: COMPLETE 9.1.5) Two 500 foot long 36" and 48" Offgas Holdup Lines (AE-1, CS-19; AE-1, CS-19) should be inspected before December 2010. These lines have not been inspected since installation in the early 1969 and have been assessed with high risk and medium consequence and high consequence. These lines have an expected minimum service life of 40 years.

IR 00698332 and PD 134307 have been issued to obtain funding approval in 2010.

Status: Delayed by 2 years 9.1.6) An approximate 25' long portion of a 6" Condensate Transfer line (CH-5, A4) should be inspected before December 2008. This is a direct buried aluminum line that is the main Condensate Transfer System supply line to the plant that is with 5 feet below grade. (CM-1)

Status: COMPLETE AR A2116126 was performed in 2008.

Risk of this line developing a through wall leak is high and the radiological and consequences are medium. Plant experience shows that direct buried aluminum lines have leaked many times at Oyster Creek. In the past 15 years Oyster Creek has replaced all but four of its direct buried aluminum lines with above ground pipe. Past experience indicates that the service life of direct buried aluminum lines is 15 to 20 years. This line was last inspected in 1993 and has an expected minimum service life of 15 years, which will be exceeded in 2008.

The inspection of this line is a License Renewal commitment (reference Passport Item 00330592-26-26)

Oyster Creek UndergroundPili}i' Program Descriptionand Siatus Topical Report 116 Rev. 3 Page 37 of 82 Line CS-26 should be inspected at the same time due to its proximity to line A-4. This is a 1" carbon steel direct buried line that runs between the condensate Building and the Turbine Building.

This line was assessed as a medium risk factor and a medium factor. The project service life of this line was until 2012..

9.1.7) Two 8" carbon steel lines are direct buried between the south side of the Reactor Building and the Pipe Tunnel (CC-4 CS-17, CC-3, CS-I 8) and should be modified before December 2010. These lines have been assessed with medium risk and medium operation consequence.

These lines are RBCCW lines that run to Old Radwaste. The equipment that these lines cool have long been abandoned. The lines were cut and capped in Old Radwaste.

However, the portions of these lines that are direct buried and in the Pipe Tunnel are still pressurized. Therefore, a leak would result in a loss of inventory in the RBCCW System and a significant leak could trip the plant. A2018689 Eval 05 has been issued for Engineering to sponsor this modification to PHC in 2008 for implementation in 2010.

Status: On Track 9.1.8) A 1 /" and 2" brass steel line is direct buried between the Turbine Building and the Condensate Transfer Building and the Intake (CA-2, CS-37). These lines should be pressure tested before December 2010. This line has been assessed with low risk and high consequence. IR 00861654 has been issued to sponsor a modification or a pressure test on this line.

Status: On Track 9.1.10) An approximate 400' long section of a 4" Torus to TWST Transfer line (CH-3 1) should be pressure tested before December 2008. In addition this line should be tested prior to each time it is used. This is a direct buried carbon steel line that contains contaminated water and is within 5 feet of grade. Guided Wave Inspection in 2007 has shown that this pipe is significantly degraded.

IR 00709720 has been issued to abandon this line.

Status: COMPLETE 9.1.11) Guided Wave inspections were planned for 2009 approximately 20 lines.

(Reference PD 122655)

IR 00696852 and PD 122655 have been issued to obtain funding approval in 2008. PRC decided that these lines should be inspected in 2010.

Status: Delayed by 2 years

Ovster Creek Undergroundl Piping Program Description anI Status Topical Report 116 Rev. 3 Page 38 of 82 9.1.12) A Cathodic Protection assessment is being performed of the Oyster Creek Site.

The goal of the assessment is to understand what the cost would be to install cathodic protection on important underground piping. The results of the assessment will be used to determine if it makes economic sense to pursue a wholesale installation of cathodic protection system. The results of the assessment are expected in the first quarter of 2009.

This work is being tracked by passport item 00625121 Status: On Track 9.1.13) Five underground lines with high risk are 1" in diameter. These lines cannot be inspected using Guided Wave or "C Scan" Technology. Given that these lines will be expected to be in service for up to 60 years it has been decided to pursue replacing these lines with aboveground lines.

IRs 00861654, 00861649 and 00861645have been issued to obtain funding approval.

Status: On Track 9.1.14) Upon entering the period of extended operation, focused inspection of buried piping and components will be performed within ten years, unless an opportunistic inspection occurs within this ten-year period. The inspections will include at least one carbon steel, one aluminum and one casi iron pipe or component. In addition, for each of these materials, the locations selected for inspection will include at least one location where the pipe or component has not been previously replaced or recoated, if any such locations remain. The stainless steel piping in the vault will continue to be periodically inspected, and the bronze material is addressed by the buried carbon steel pipe coating inspections (CM-1). Repetitive tasks PM53216M, PM42419M, and PM81501M have been developed and are schedule for these inspections

Oyster Creek UndergroundPiping Program Descriptionand Status Topical Report 116 Rev. 3 Page 39 of 82 10.0 References 10.1 TDR 1162, Rev. 0 "OC Plant Optimization and License Renewal (POLR)".

10.2 TDR 1178, Rev. 0 "Service Water System Underground Piping Decision Analysis" 10.3 TDR 1179, Rev. 0 "Emergency Service Water System Underground Piping Decision Analysis" 10.4 B&R Drawings B&R 2192 through 2196, Composite Yard Drawings 10.5 SP-1302-12-261, Service Water (SW-1) and Emergency Service Water (SW-2)

Inspection Program.

10.6 SP-1302-12-268, "Underground Piping Inspections" 10.7 OCMM-323721-001, "Spent Fuel Cooling Piping Relocation Reactor Building South Wall Elevation 18', 11" 10.8 Drawing, 3E-SK-M-049, Site Composite, Underground Facilities" 10.9 Oyster Creek Startup and Test Results Tracking Form - MTX NO. 104.13.1.6 10.10 TDR 1032, Rev. 1, "The Identification of Potentially Radioactive Systems" 10.11 TDR 1218 Rev. 0, "Evaluation of Oyster Creek Underground Piping Which Contain Contaminated Fluids" 10.12 Oyster Creek Procedure 341 "Emergency Diesel Generators" 10.13 GPUN Process plan 1000-PLN-7340.00, "Project Approval and Management Process" 10.14 Budget Activity 402972 10.15 Budget Activity 328376 10.16 Topical Report 140, Revision 2 "Emergency Service Water and Service Water System Piping Plan" 10.17 Operability Evaluation OC-2003-E-001 3, 10.18 B&R Drawings B&R 2192 through 2196, Composite Yard Drawings 10.19 TDR 1032, Rev. 1, "The Identification of Potentially Radioactive Systems"

Oyster Creek UndergroundPiping Program Descriptionand Status Topical Report 16 Rev. 3 Page 40 of 82 10.20 The Corrosion Handbook edit by UHLIG, John Wiley and Sons Inc., C 1948 10.21 Corrosion Control in Soils, by Samuel A. Bradford, Casti Publishing C 2001 10.22 ER-AA-5400, "Buried Piping and Raw Water Corrosion Program (BPRWCP)

Guide" 10.23 Altran Solutions Report 07-0807-TR-002 Revision 0, Buried Piping Systems Susceptibility Analysis Document", Dated July 2007 10.24 STI Report (Guided Wave) 10.25 ER-AA-5400-1002, Rev 000, BURIED PIPING EXAMINATION GUIDE 10.26 Passport Assignment 00330952.26 - Buried Piping Program Commitments 10.27 Station Commitment (Action Tracking Item) AR 00330592.26, License Renewal Aging Management (section 1.0, section 9.0, Corrective Action 10; Appendix(s) 2 and 3)

(CM-1)

Oyster Creek UndergroundPipitgProgram Descriptionand Status Topical Report 116 Rev. 3 Page 41 of 82 Page 41 Intentionally Blank

Oyster Creek UndergroundPiping ProgramDescription and Status Topical Report 116 Rev. 3 Page 42 of 82 Annenrli, 1 - ,~nifie~nt ITnderrnnmind Pine Ienk~

Appendix 1 - Sipnificant Underground Pine le iks Item Year System/ Line Material/Coating Root Cause Comments/ Section in Report

.1 I _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ I__

1 1980 Underground 6" & Al Pitting Corrosion/ Galvanic During the repair of these lines it was 10" Condensate Original Aluminum piping found that all the Condensate and Transfer lines exterior coating was Coal Tar Demin. Water underground piping in the vicinity of the CST and Condensate Transfer Building had severe pitting corrosion. As a result a significant modification was performed which completely replaced all underground aluminum piping on these two systems in 1980. The modification added cathodic protection in the area to attempt to solve the galvanic corrosion mechanism (section 6.1).

1980 Underground 4" & 6" Akl Pitting Corrosion/ Galvanic See note above 2 Demin Transfer Lines Original Aluminum piping exterior coating was Coal Tar 3 1985 ESW, Coating failures CS/ Coal Tar Pitting Corrosion/ Galvanic See section 6.3 4 1986 Underground 2" CS/ Coal Tar See section 7.4 Emergency Diesel Generator Fuel Oil line 5 1989 Underground 3" Aux. CS Coal Tar Steam and Condensate 6 ____ line .. _._ ...

6 1991 Underground 2" AL Pitting Corrosion! Galvanic See section 6.1 Oemin. Water, Exterior surfaces coated with Augmented Off Gas liquid primer and protective line, and Auxiliary tape; with magnesium anode Steam lines" Cathodic protection

Oyster Creek UndergroundPiping Program Descriptionand Status Topical Report 116 Rev. 3 Page 43 of 82 ADnendix 1 - 5~ipnifit'nnt Tlndprornuunh1 P~ng~ ~

Item Year System/ Line Material/Coating Root Cause Comments/ Section in Report 7 1991 Underground CS/ Coal Tar Condensate Transfer Lines 1" and 8" 8 1991 Underground 10" AL Exterior surfaces coated Pitting Corrosion/ Galvanic This line was replaced in 1980. See Condensate Transfer with liquid primer and items #1 and # 2 above Line protective tape; with magnesium anode Cathodic protection 9 1992 Underground I" CS See Section 6.1 Domestic Water Line 10 1992 20" Service Water CS/Coal Tar Degradation of the piping external Line- Just south of the coating- may have been due to Condensate Transfer improper original coating application Building 11 1993 Underground 4" AL Exterior surfaces coated Pitting Corrosion/ Galvanic This line was replaced in 1980. See Demin Water Transfer with liquid primer and items #1 and # 2 above. Section 6.1 Line protective tape; with magnesium anode Cathodic protection 12 1994 Underground 6" AL Exterior surfaces coated Pitting Corrosion! Galvanic This line was replaced in 1980. See Condensate Transfer with liquid primer and items #1 and # 2 above. See section Line protective tape; with 6.1 magnesium anode Cathodic

-,, protection__ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

13 1994 Underground 20" CS/ Coal Tar Improper application of See Section 6.2 Service Water Line Internal Coating.

Northwest of the Turbine Building (Tee installed in 1987)

Oyster Creek UndergroundPiping Program Description and Status Topical Report 116 Rev. 3 Page 44 of 82 Appendix 1 - Significant Underground Pipe leaks Item Year System/ Line Material/Coating Root Cause Comments/ Section in Report 14 1994 Underground 30" CS/ Coal Tar Degradation of internal See Section 6.2 Overboard Discharge coating due to flow Line near the impingement downstream discharge canal. of an elbow.

15 1995 78" #4 Circ. Water CS! Coal Tar Degradation of internal See Section 6.2 Pump Discharge Line coal tar coating

- Above ground 16 1995 Two leaks on 24" CS/ Coal Tar Degradation of internal See Section 6.2 Service Water and coal tar coating - Possibly Circ. Water System due to flow impingement.

Lines - Inside the

_ Turbine Building 17 1996 4" SW supply to the CS/ Coal Tar Unknown See Section 6.2 Service water line -

off the 20" Service Water Line 18 1999 30" Overboard CS/ Coal Tar Degradation of internal See Section 6.2.2 and OC-MD-H496-Discharge Line Leak coal tar coating -Due to 001

_ Near Seal Well flow impingement.

19 2001 ESW System 2 CS! Coal Tar Degradation or improper See Section 6.2.1 application in internal coating at a branch connection.

20 2004 SW South of Devoe 235 and 238 Coating Improper application in See CAP 02004-3331 Condensate Building System internal coating (no sand blasting) of Devote coating in 1996.

21 2006 Chlorination Line Carbon Steel. Plastic lined Unknown - Line was See AR A2"144398 South of Condensate inside and Epoxy coating abandoned with excavation Transfer Line outside.

Oyster Creek UndergroundPiping ProgramDescriptionand Status Topical Report 116 Rev. 3 Page 45 of 82 Appendix I - Significant Underground Pipe leaks Item Year System/ Line Material/Coating Root Cause Comments/ Section in Report 22 2007 Heating Steam Line 8" Line south of Reactor External Corrosion IR 00699131 See 8.2.4.8 Building.

21 2008 Service Water System CS/ Coal Tar Coating Breakdown Line has since been Replaced Line At the Intake Road.

Oyster Creek UndergroundPiping Program Descriptionand Status Topical Report 116 Rev. 3 Page 46 of 82 Appendix 2 -Program Systems. Priorities and Basis System Priority Reference Basis / Program Description ESW 2 TP 140/ 100% of all buried Safety Related underground lines were replaced in PD 102153 2008 Diesel Fuel Oil 3 PD 102026 These lines were replaced in 2006 with double wall pipe. Priority of the lines was changed from 1 to 3 in 2007.

Service Water I TP 140 / The majority of direct buried underground lines will be rehabilitated Line Item 121275 by 2010 Fire Protection 2 TR 116 Section 7.5 Inspections show no on going degradation mechanisms Turbine Oil I TR 116 Section 7.6 Tested before each use. Guided wave Inspection shows no degradation Condensate Transfer 1 TR 116 Section 8.2 Bulk of the system has been relocated above ground a with remaining underground lines in inspection program Chlorination Lines 2 TR 116 Section 8.2 Replaced in 2008 Overboard Discharge 3 OC-MM-H496-001 Rehabilitated with Cure In Place Pipe in 2000 (priority change from 1 to 3 in 2000)

Off-Gas Holdup Lines 1 TR 116 Section 8.2 Partial inspection by 2010 Service Air 2 TR 116 Section 8.2 Coating inspection every two years Instrument Air 2 TR 116 Section 8.2 Partial inspection by 2009.

Demineralized Water Transfer 3 TR 116 Section 8.2 Bulk of the system has been relocated above ground, with remaining underground lines in inspection program.

Heating Steam 2 TR 116 Section 8.2 Inspections are in the program (see section 8.2) Replacement??

Torus Water Transfer 2 - Abandoned in placed (IR 00709720) See 8.2.4.7 Hydrogen 3 Run To Failure Nitrogen 3 Run To Failure Old Radwaste Piping 2 TR 116 Section 8.2 Inspections are in the program New Radwaste Service Water 2 TR 116 Section 8.2 Inspections are in the program AOG 2 TR 116 Section 8.2 Inspections are in the program AOG Drains 2 TR 116 Section 8.2 Inspections are in the program Domestic Water 3 Run To Failure Gas Station 3 Run To Failure - all lines have be relocated above ground RBCCW 2 TR 116 Section 8.2 Modify by 2010 Inspection IST Cleanup Dremineralizer 2 TR 116 Section 8.2 Inspections are in the program

Oyster Creek Underground Piping Program D~escriptionand Status Topical Report 116 Rev. 3 Page 47 of 82 Appendix 2 -Program Systems. Priorities and Basis System Priority Reference Basis / Program Description TB Floor and Equipment 2 TR 116 Section 8.2 Inspections are in the program Drains Laundry/Laboratory 2 TR 116 Section 8.2 Inspections are in the program

Oyster Creek UndergroundPiping Program Descriptionand Status Topical Report 116 Rev. 3 Page 48 of 82 Appendix 3 - Underground Piping Inspections Item Year System/Location Pipe and Coating Inspection Results Comments/

Section in Report 1 1991 100 feet of Demin. AL Exterior surfaces External exposed Sporadic Coating damage Inspected Water and Condensate coated with liquid primer by excavation with External pitting. during repair Transfer. Vicinity of and protective tape; with to items 7, 8, the CST and the magnesium anode and 9 of condensate Transfer Cathodic protection appendix 1 Building _

2 1992 50 feet of Fire CS/ Coal Tar Exterior External exposed External Coating in good Inspected Protection by excavation and shape. during repair some internal Internal in good shape to item 10 of appendix 1:

3 1992 50 feet of Service CS/ Coal Tar Exterior and External and External Coating in good Inspected Water - South of the Interior internal inspections shape. during repair condensate Transfer performed during Internal Coating in poor to item 10 of Building repair activities see condition appendix I item #10 app #1 4 1993 25 feet of ESW CS/ Coal Tar Exterior and External and External Coating in good System II - Interior internal inspections shape.

Isolated Internal Coating Deterioration 5 1993 20 feet of RBBCW CS/ Coal Tar Exterior and External Coating in good Interior External and shape.

Internal 1993 Lube Oil Transfer CS! Coal Tar Exterior Passed successfully Line pressure test ,. ._IIII

Oyster Creek UndergroundPiping Programn Descriptionond Status Topical Report 116 Rev. 3

_1 Page 49 of 82 Appendix 3- Underground Piping Insoections Item Year System/Location Pipe and Coating Inspection Results Comments/

Section in Report 7 1993 15 feet of Condensate AL Exterior surfaces Exterior Severe Pitting corrosion Inspected Transfer and Fuel Pool coated with liquid primer during repair cooling - South of the and protective tape; with to item 12 of Reactor Building magnesium anode appendix 1 Cathodic protection 8 1993 15 feet Radwatse CS/ Coal Tar Exterior Exterior External Coating defects Inspected Piping CS - South of during repair the Reactor Building to item 12 of appendix 1 9 1993 10 feet of Fire CS/ Coal Tar Exterior Exterior Sporadic External Coating Inspected Protection defects during repair to item 12 of appendix 1 10 1993 15 feet of Turbine Stainless/ Coal Tar Exterior Sporadic External Coating Inspected Building Drains and defects during repair Equipment Drains to item 12 of South of the Reactor appendix 1 Building 11 1993 15 feet of Roof Drains CS / Coal Tar Exterior Sporadic External Coating Inspected South of the Reactor defects during repair Building to item 12 of

___ __. _appendix 1 12 1993 20 feet of RB CS / Coal Tar Exterior Sporadic External Coating Inspected Equipment Drain Tank defects during repair discharge - South of to itemn 12 of the Reactor Building appendix 1 13 1993 15 feet of CS / Coal Tar Exterior Sporadic External Coating Inspected Laundry/Lab Drain defects during repair South of the Reactor to item 12 of Building appendix 1

Oyster Creek Underground Piping Program Description and Status Topical Report 116 Rev. 3 Page 50 of 82 Appendix 3 - Underground Piping Inspections Item Year System/Location Pipe and Coating Inspection Results Comments/

Section in Report 14 1994 600 feet of 30" CS / Coal Tar Internal Video General in good condition / Inspected Overboard Discharge inspection Visible coating defects and during repair rust blooms to item 14 of appendix 1 15 1994 400 feet of 20" CS / Coal Tar Internal Video Marine build-up and some Inspected Service Water North inspection rust blooms same condition during repair of Reactor Building as pipe in item #3 to item 15 of and West of turbine appendix 1 building 16 1994 Service Water During repair Internal visual Coating degradation with 4 Inspected Northeast of Reactor significant pits found, 1 pit during repair building was 50 mils from through to item 15 of

_ wall appendix 1 17 1994 Service Water During repair Internal visual Coating degradation with Inspected Northwest of Turbine pitting found, 1 pit was during repair Building 50% through wall to item 15 of

_ _ _appendix 1 18 1996 200 feet of 20" During repair Internal Video Marine build-up and some Inspected Service Water, West inspection rust blooms same condition during repair Turbine Building as pipe in item #3 to item 18 of

.. .. ___,appendix 1 19 1996 80 feet of ESW During modification to the Internal Video - Occasional localized System II piping system Inspection pitting corrosion, rust piles, inside the Turbine coating bubbles and small building

_ openings in the coating.

Oyster Creek UndergroundPiping Program Descriptionand Status Topical Report 116 Rev. 3 Page 51 of 82 Appendix 3 - Underground Piping Inspections Item Year System/Location Pipe and Coating Inspection Results Comments/

Section in Report 20 1999 Inspected 900 feet of During modification to Internal Video Marine build-up and some Section 6.2.2 30" overbroad install an internal liner Inspection rust blooms discharge line just before the application of the new internal liner 21 2001 Inspected 150 feet of During investigate into the Internal Video Marine build-up only Section 6.2.1 ESW 2 piping from 2001 ESW System Inspection except for leak at the penetration at the underground leak (CAP branch connection weld.

Northwest corner of 2001-1233) the Turbine Building to the area near the leak at the branch connection 22 2004 UT inspection on Devoe External and Visual and UT Coating and pipe wall in general Section 6.3, Submerged ESW and Internal good condition with one SW pipe in the north exception.

intake bay 23 2007 Guided Wave The following lines were Guided Wave Results Described reference Inspection of Lines inspected: A-1, A-4, CS-6, Technology 10.24 and section 7 and 8.

CS-8, CS-9, CS-10, CS-11, CS-24, CS-27, CS-31, CS-36, CS-37, CS-39, CS-40.

24 2008 South East Vault of CS-6, CS-7, CS-8, CS-9, Visual Coating Break Downs, IR See Section Reactor Building CS- 10, and CS- 11. 00813967 issued 8.2.2.4 25 2008 Condensate Transfer A-4 Visual Coating in Good Condition See Section Lines 8.2.2.2

Oyster Creek Underground PipingProgram Descriptionand Status Topical Report. 16 Rev. 3 Page 52 of 82 Appendix 3 - Underground Piping Inspections Item Year System/Location Pipe and Coating Inspection Results Comments/

Section in Report 26 2008 SW/ESW pipe 10 foot of SW and 20 foot Visual Coating in Good Condition 6.2 of ESW removed from Intake Road

-y

Oyster Creek Underground Piping ProgramDescription and Status Topical Report 116 Rev. 3 Page 53 of 82 Appendix 4 - Inventory of Risk and Consequence Significant Lines - Aluininu Pipe ID Description Suscepti Consequ Len. Fluid/ Coating/ EL/ Draw. Located Inspections and Repairs Action/ Basis System/ Line size bility ence Conta Protecti Depth minati on on A-I CH-3, 12" High Medium 3' Conde Unknow 17' 2004 Between the TB In 1998 a project was performed Action: reinsert Condensate nsate n GE and RB on to-core bore the concrete slab by 2013 years Transfer line from 885D781 Northwest corner above the gap in this area. A CST to Core 237E487 of the RB, sample well was then installed Spray System and 4076 under the condensate transfer line.

CRD system. AL 4079 The well showed that there was 6061 2132 no moisture under the line. Soil 2138 samples indicated no condensate 2140 leak. Reference ETTS 4031 Section 8.2.2.3 In 2007 this line was inspected using Guided Wave. Results were

. . ..______ .. satisfactory. ._..

A-2 CH-5; 6" Medium Medium <10' Demin Unknow 19' 2195 Under Office This line was repaired in 1980. A To be GW Condensate. Water/ n 2134 Building. vault was built around the line. inspected in 2010 Transfer from Mediu 2004 This line is not direct buried (IR 00686711)

Turbine Building m to pipe tunnel to the Reactor Building Al. 6061 Section 8.2.2.5 A-3 NN-3 6" Fuel Low Medium <10' Reacto Epoxy 19' BR 2193 Central Vault/ This line was replaced in 1993, To be GW*

Pool Cooling line r Coating 2153 GE per BA 323721, OC-MM- inspected in to Fuel Pool Filter Water/ w/ 237E756 323721-001 and SP-1302-12-268. 2010=8 (JR in Radwaste - Mediu Nukon 00686711)

New line installed m Wrap in 1993 Al. 6061 A-4 CH-5; 6" from the Medium Medium 25' Conde Epoxy 17' 2193 Between the Original Vintage Piping. Original Excavate and Condensate nsate Coating 2132 Condensate Plant underground line. However inspect per pumps to TB Transf Transfer Building Coating Was repaired in 1992 ARA2116126 Al. 6061 er and the Turbine License Renewal Section 8.2.2.2 Building. Partially inspected in 2008 with Commitment good results

Oyster Creek UndergroundPiping Program Description and Status Topical Report 116 Rev. 3 Page 54 of 82 Apnendix 4 - Inventory of Risk and Conseauenct Siionificant Lines - Sti-'nler- P*i Pi-np ID Description Suscepti Consequ Len. Fluid Coating/ EL/ Drawing Located Inspections and Repairs Action System bility ence / Protecti Depth s Cont on amin ation SS- SD-4A; 3" Low- High <15' RWC Coal 18' 2195 Under the Office Line was inspected and repaired To be GW I RWCU Dtemin inspected U TAR and -5' 2143 Building; as necessary in 1993 inspected in Resin Sluice/ in 1993 Resin Repaired 148F444 Southwest of This line is used once per cycle. 2010 (IR Resin Transfer to s Epoxy shl3 Reactor Building Radwaste SS 304 Coating 00686711) w/

Section 8.2.3.2 Nukon Wrap SS- SD-4C; 3" Low- High <10' Cond Coal Tar 18' 2195 Under the Office Line was inspected and repaired To be GW 2 Condensate for inspected ensate and -5' 2143 Building; as necessary in 1993 inspected in RWCU Denin in 1993 /medi Repaired 148F444 Southwest of 2010 (IR Resin Transfer um Epoxy Reactor Building 00686711)

SS 304 Coatinig w/

Section 8.2.3.2 Nukon I Wrap-SS- NV-2; I 1/2/2" Low Medium <10' Water Coal Tar 12' 2195 Southeast Vault A PM has been established to To be GW 3 Laundry drains to / and - II' 2184 GE inspect coating of pipe in the inspected in Radwaste Medi Repaired 148F432 southeast vault every 2 years (AR 2008 (IR SS 3041 um Epoxy A2008369). Inspections of this 00686711) 316 Coating line in 2001 and 2004 showed the W/ coating is in good condition (CAP Nukon 02004-2071).

Wrap Inspected in 2008 SS- CH-2; 8" from Low Medium 30' Cond SS/Polyk 18' 2193 From the Turbine Building. To be GW 4 TB to ensate en Tape Condensate Replaced in 1992 OC-MM- inspected in Sucker/Dumper Tar GU 3D- transfer Building 323643-001 2010 (IR Station; SS 421 to the TB west 00686711)

Replaced in 1992 1000 wall.

Oyster Creek UndergroundPiping Program Description and Status Topical Report 116 Rev. 3 Page 55 of 82 Appendix 4 - Inventory of Risk and Consequence Significant Lines - Carbon Steel Pipe ID Description Suscep Consequen Len. Fluid Coating/ EL/ Drawing Located Inspections and Repairs Action System tibility ce I Protectio Depth s Cont n amin ation CS- ND-15; I" Mediu High; This <10' Clean Coal Tar/ 19' 2195 Central Vault/ In 1997 this line was in inspected Pursue I Cleanup Sludge m line is up and -4 2143 and coatings repaired as modification to Transfer Line to Inspect probably Sludg Repaired 148F444 necessary per the repair activities replace this line sludge Tank A106 ed in the worst e/ with GE to NN-3, per BA 323721 and SP-1997 with High Epoxy 148F437 1302-12-268.

Section 8.2.3.1. respect to Coating sit 5 contaminati w/ This Line cannot be Guided Wave on levels Nukon Inspected Wrap Medium CS- NN-2; 6" Fuel Mediu Medium <10' React Coal Tar 19' 2195 Central Vault/ In 1997 this line was in inspected To be GW 2 Pool cooling to m or and -4 2153 GE and coatings repaired as inspected in Radwaste (Fuel Water Repaired 237E756 necessary per the repair activities 2010 (IR Pool Filter) A106 / Epoxy to NN-3, per BA 323721 and SP- 00686711)

Filter Bypass Medi Coating 1302-12-268.

um w/

Section 8.2.4.1 Nukon Wrap _

CS- ND-1l;6" Mediu Medium <I5' React CoalTar 18' 2195 Central Vault/ In 1997 this line was in inspected TobeGGW 3 Cleanup to High m; or and -5' 2143 and coatings repaired as inspected in Purity Tank Water Repaired 148F444 necessary per the repair activities 2010 (IR

-This line is not / Epoxy to NN-3, per BA 323721 and SP- 00686711) used any more; Medi Coating 1302-12-268.

However it is still um w/

available for Nukon service. A 106 Wrap Section 8.2.4.1 CS- ND- I1; 6" Mediu Medium <15' React Coal Tar 18' 2195 Central Vault/ This line was inspected'coating To be OW 4 Cleanup to rn or and -5' 2143" was found degraded - pipe wall inspected in I Condensate Inspect Water Repaired 148F444 was acceptable. Coating was 20 10 (IR

Oysier Creek Underground Piping Program Descriplionant Starus Topical Report 116 Rev. 3 Page 56 of 82 Appendix 4- Inventory of Risk and Consequence Significant Lines - Carbon Steel Pipe ID, Description Suscep Consequen Len. Fluid Coating/ EL/ Drawing Located Inspections and Repairs Action System tibility ce I Protectio Depth s Cont n amin ation System A 106 ed / Epoxy repaired MNCR 93-101 00686711)

Section 8.2.4.1 Medi Coating um w/

Nukon Wrap CS- NV-6; I Mediu Medium <15' Water Coal Tar 18'4" "2195 Partially in This linewas in inspected and To be GW 5 '"RBEDTline to m / and -5' 2184 central Vault and coatings repaired as necessary per inspected in Radwaste - Inspect Medi Repaired 147434 under the Office the repair activities to NN-3, per 2010 (IR Ties in with NV-7 ed urn Epoxy building/ BA 323721 and SP- 1302-12-268 00686711) in the pipe Coating Tunnel; A53 w/ This Line may not be Guided Section 8.2.4.1 Nukon Wave Inspected due to size Wrap limitation.

CS- NV-4; 2" Laundry High Medium <10' Water Coal Tar 12' 2195 Southeast Vault Inspected in 1993; coating PM57304M will 6 Drains to Low Iand -II' 2184 satisfactory - MNCR 93-143 inspect this line Radwaste Medi Repaired 148F437 Inspections of this line in 2001 every 2 years A53 urn Epoxy was found satisfactory. This Coating coating was again inspected in Section 8.2.2.4 w/ 2004 showing coating Nukon degradation requiring repairs Wrap (CAP 02004-2071). 2004 UT Inspection of this line showed no wall thinning. Coating degradation is believed to be due to the elevated temperatures this lines experiences.

Inspected Using Guided wave in 2007 see reference 10.24

.. ... ... . - Inspected in ;008 CS- NV-8; 3" RB Low Medium <10' Water Coal Tar 12' 2195 Southeast Vault Inspected in 1993; coating was PM57304M will 7 sump to Radwaste / and -II' 2184 found degraded; repaired. UT inspect this line A53 Medi Repaired 148F437 showed piping wall acceptable - every 2 years

Oyster Creek UndergroundPipingProgram Descriptionand Status Topical Report 116 Rev. 3 Page 57 of 82 Appendix 4 - Inventory of Risk and Consequence Significant Lines - Carbon Steel Pipe ID Description Suscep Consequen Len. Fluid Coating/ EL/ Drawing Located Inspections and Repairs Action System tibility ce / Protectio Depth s Cont n amin ation urn Epoxy MNCR 93-143 Section 8.2.2.4. Coating Inspections of this line in 2001 w/ and 2004 showed the coating is in Nukon good condition (CAP 02004-Wrap 2071).

Inspected in 2008 CS- NV-7; 2" High Medium <10' Water Coal Tar 12' 2195 Southeast Vault Inspected in 93; coating PM57304M will 8 DWEDT to / -II' 2184 satisfactory - MNCR 93-143. inspect this line Radwaste Medi 148F437 Inspections of this line in 2001 every 2 years Ties into NV-6 in utn and 2004 show coating the pipe tunnel. degradation requiring repairs A53 (CAP 02004-207 1). UT Inspection of this line showed a Section 8.2.2.4. slight amount of wall thinning.

Coating degradation is believed to be due to the elevated temperatures this lines experiences.

Inspected in 2008 Inspected Using Guided wave in 2007 see reference 10.24 CS- NQ-2; 14" Low- Medium <0' Torus Coal Tar 11'6" 2195 Southeast Vault Inspected in 1993; coating was PM57304M will 9 Containment Water and found degraded; repaired. UT inspect this line Spray A53 / Repaired showed piping wall acceptable - every. 2 years None Epoxy MNCR 93-143 Inspections of Section 8.2.3.3 Coating this line in 2001 and 2004 showed W/ the coating is in good condition Nukonl (CAP 02004-2071).

Wrap Inspected Using Guided wave in

Oyster Creek Underground Piping Program Description and Status Topical Report 116 Rev. 3 Page 58 of 82 Anng.ni4iy d - In~,rntnrv nf Rkk ~anA Cnn~sn.wnro ~innifi~.o.,t T ~ - ('urhnn gtnal Ping~

ID Description Suscep Consequen Len. Fluid Coating/ EL/ Drawing Located Inspections and Repairs Action System tibility ce / Protectio Depth s Cont n amin ation 2007 see reference 10.24 CS- SA-2; 4" Service Low Medium <10' Air/ Coal Tar 12' 2195 Southeast Vault Inspected in 1993; coating was PM57304M will 10 Air A I06 None and -I ' 2154 found degraded; repaired. UT inspect this line Repaired showed piping wall acceptable - every 2 years Section 8.2.3.3 Epoxy MNCR 93-143. Inspections of Coating this line in 2001 and 2004 showed w/ the coating is in good condition Nukon (CAP 02004-2071).

Wrap Inspected Using Guided wave in 2007 see reference 10.24 Inspected in 2008 CS- CA; 4" Instrument Low High <10' Air/ Coal Tar I ' 2195 Southeast Vault Inspected in 93; coating was PM57304M will II Air A106 None and -12' 2154 found degraded; repaired. UT inspect this line Repaired showed piping wall acceptable - every-2 years Section 8.2.3.3 Epoxy MNCR 93-143. Inspections of Coating this line in 2001 and 2004 showed W/ the coating is in good condition Nukon (CAP 02004-2071).

Wrap Inspected in 2008 Inspected Using Guided wave in 2007 see reference 10.24 CS- CH-8; 3" Heating Low Medium <20' Water Coal Tar 19' 2195 South of RB Replaced in 2003. To be GW 12 steam Condensate / -4' 2197 BR Between the inspected in A53 Medi 2015 Central vault and 2010 (IR um the Southeast Coating was inspected in 2007 00686711)

Vault.

CS- SH; 8" Heating Low Medium <20' Steam Coal Tar 18' 2195 South of RB Inspected in 2003 Subsequent The entire Iline 13 Steam A53 / -5' 2197 BR Between the analysis showed this line is from the Pipe Medi 2015 Central vault and acceptable See CAP 02003-1418 Tunnel to about urn I the Southeast 2.off the Reactor

Oyster Creek UndergroundPiping Program Descriptionand Status Topical Report 116 Rev. 3 Page 59 of 82 Appendix 4 - Inventory of Risk and Consequence Significant Lines - Carbon Steel Pipe ID Description Suscep Consequen Len. Fluid Coating/ EL/ Drawing Located Inspections and Repairs Action System tibility ce I Protectio Depth s Cont n amin ation Vault. Line leaked in the Pipe Tunnel Building was Penetration in November 2007. replaced in The line was excavated and found November 2008 to be in degraded condition (IR (AR A2181302).

00703721). A new coating system was used due to the elevated temperature of the line.

CS- CC-4; 8" Mediu Medium <10' Water Coal Tar 18 7"! 2195 Under Office Inspected in 1993 To be GW 17 RBCCW supply m / -4 1/2' 2145 BR Building inspected in Radwaste (Waste None 2006 between the Pipe 2010 (IR concentrator tunnel and the 00686711) condenser and Reactor waste Building.

concentrator This line is not cooling coils), used butis A 106 pressurized.

Section 8.2.4.2 CS- CC-3; 8"RBCCW Medit, <10' Water Coal Tar 18'7" 2195 Under Office Inspected in 1993 To be 6W 18 return from m Medium / and 2145 8R Building inspected in Radwaste None Repaired 2006 between the Pipe 2010 (IR A 106 Epoxy tunnel and the 00686711)

Coating Reactor Section 8.2.4.2 w/ Building.

Nukon This line is not Wrap used but is pressurized.

Oyster Creek UndergroundPiping PrograamDescription and Status Topical Report 116 Rev. 3 Page 60 of 82 Annendix 4 - Inventor- nf Risk and Cnn en,cnn.Siaonifleant in--.r- -hn.,n .1 P; ID Description Suscep Consequen Len. Fluid Coating/ ELI Drawing Located Inspections and Repairs Action System tibility ce I Protectio Depth s Cont n amin ation CS- AE-1; 30/36" High High 410' Offga Coal Tar 2'8" - 2192 Between the To be GW 19 Mechanical s/ and 9'6" 4005 Turbine building inspected in Vacuum Pump mediu Repaired 2008 and the stack and 2010 (IR Offgas Line; m Epoxy 2009 the AOG. 00686711)

A 106 Coating w/

Section 8.2.2.1 Nukon I Wrap CS- AE- l; 48" Offgas High High 510' Offga Coal Tar 2'8" - 2192 Between the To be GW 20 Hold up; A 106 s/ 9'6" 4005 Turbine building inspected in Medi 2009 and the stack and 2010 (IR Section 8.2.2.1 um 20008 the AOG. 00686711)

CS- 4" Off gas to Mediu Medium 100' Offga Denso 18' M690 Between The To be GW 22 AOG; A 106; Line m s Anti 2009 Stack and AOG inspected in Spec- OG- 100 Corrosio Building 2010 (IR n Tape 00686711)

Section 8.2.4.3 1 -

CS- 2" Off gas from Mediu Medium 100' Offga Denso 18' M690 Between The To be GW 23 AOG; A]06; Line m s Anti Stack and AOG inspected in Spec- OG- 125 Corrosio Building 2010 (IR n Tape 00686711)

Section 8.2.4.3 CS- CH-I; 10" from Mediu Medium 30' Cohd CoalTar 17' 2193 From the Inspected in 1993.

-24 Cond. Tank & m ensate Condensate Re inspect in Cond. Building to transfer Building Inspected Using Guided wave in 2012 Hot-well; A 106 to the west wall 2007 see reference 10.24 of the Turbine Section 8.2.4.4 Building.

Oyster Creek Underground Piping ProgramDescriptionanti Stanis Topical Report 116 Rev. 3 Page 61 of 82 Appendix 4 - Inventor of Risk and Consequence Significant Lines - Carbon Steel Pipe ID Description Suscep Consequen Len. Fluid Coating/ EL/ Drawing Located Inspections and Repairs Action System tibility ce I Protectio Depth s Cont n amin ation

-CS- CH-1; I" from Mediu Medium 30' Cond Coal Tar 18' 2193 From the This Line cannot be Guided Wave Pursue 26 Cond. Building to m ensate Condensate Inspected modification to Turbine Building; transfer Building replace this line A 106 to the west wall of the Turbine Section 8.2.4.5 Building CS- CH-6; 12" Mediu Low 75' Air Coal Tar 16' 2193 From the Inspected Using Guided wave in 27 overflow line m 2180 Condensate 2007 see reference 10.24 Re inspect in from Cond. Tank transfer tank and 2012

& Demin Tank to Demin tank to Turbine Building; the west wall of A 106 the Turbine Building CS- CW; 2 1/2z' Mediu Low 100' Salt Unknow 15' 2193 From TB to the To be GW 28 Vacuum Priming m Water n top of the intake inspected in Lines tunnel. A leak 2010 (IR would results in 00686711) a sinkhole.

CS- DW-3; 3" Mediu Medium >400' Dome Coal Tar 18' 2193 Runs north to To be GW 29 Domestic water; in stic 2192 south west of the inspected in A 106 Water turbine building 2010 (IR 0068671l)

CS- DS-100, I 1/2"; Mediu Medium 175' Sump Denso 18' M690 From AOG to To be GW 30 AOG Drains and m Anti Boiler House inspected in Sumps: A016 Corrosio 2010 (IR Section 8.2.4.3 1 n Tape - 00686711)

CS- 4"; Torus Water Mediu Low 1000 Torus Coal Tar 19 6" S&W Between TWST Inspected Using Guided wave in 31 Tank Return Line m Water 15050- Tank and North 2007 see reference 10.24 () Re inspect in to the Torus 1 1 11 I10-EM- face of the 1 2012

Oyster Creek Underground PipingProgranm Descriptionand Status Topical Report 116 Rev. 3 Page 62 of 82 Appendix 4 - Inventory of Risk and Consequence Significant Lines - Carbon Steel Pipe ID Description Suscep Consequen Len. Fluid Coating/ EL/ Drawing Located Inspections and Repairs Action System tibility ce / Protectio Depth s Cont n amin ation 650 and Reactor Section 8.2.4.7 651 Building.

CS- 3" Chlorine line Low Medium 400 Chlor Internal 12' BR2192 Between These three lines 35 from Chlorine each inated is Plastic Chlorine House The SW system line leak in 2007. were replaced in Building to the water external and Intake These three lines were replaced in 2008 Intake. (Three is coal 2008 individual lines) tar Section 8.2.4.6 CS- 4" Chlorine line Mediu Low 200 Chlor Internal 12' BR2192 Between 36 from Chlorine m inated is Plastic Chlorine House To be GW Building to the to water external and Turbine inspected in top of Intake is coal Building 2010 (IR tunnel tar 00686711)

CS- CA - 2" Control Low High 600 Air External 8' BR2192 From SW Corner To be GW 37 Air Line Possible is coal of Turbine to inspected in Plant trip tar Cond. Transfer 2010 (IR Section 8.2.3.4 Building and to 00686711)

Pipe is the Intake Brass CS- I" Condensate Mediu Medium 30 Cond External 6' BR 2193 From CST to Pursue 38 Line m ensate is coal Turbine Building modification to Section 8.2.4.5 tar replace this line CS- 12" Fire Low Low 200 Fire External 6' B9 2195 From Redundant Inspected using Guided Wave in Re inspect in 39 Protection Line Water is coal Fire Pump 2007 2012 From Redundant tar Fire Pump CS- 10" Fire Low Medium 5 Fire External 6' BR 2193 Line to CST Inspected using Guided Wave in 40 Protection Line to Water is coal 2007 Re inspect in CST tar 2012

Oyster Creek Underganuin Piping Program Description and Status Topical Report 116 Rev. 3 Page 63 of 82 Appendix 4 - Inventory of Risk and Consequence Significant Lines - Carbon Steel Pipe ID Description Suscep Consequen Len. Fluid Coating/ EL/ Drawing Located Inspections and Repairs Action System tibility ce I Protectio Depth s Cent n amin ation Cs- Turbine Lube Oil Mediu High 250' Cont. Coal Tar 7' BR 2193 West of Turbine Inspected using Guided Wave in 42 Transfer Lines m Oil Building 2007 Re inspect in 2012 Two Lines a 3"-

LO-5 and a 4" LO-4 The following lines have been removed from the matrix since the last revision based on the following reasons:

The line has been modified above ground The Line was abandoned and replaced by another line The line was found to be above ground by a walkdown The line carries Demineralized Water, which is no longer considered potentially contaminated.

Appendix 4 - Line no lon ger in the Program ID Description Suscep Conseque Len. Fluid Coating/ EL/ Drawing Located Comments Action System/ Line size tibility nce I Protecti Depth Cont on amin ation .

A-5 WD-2; 3" Demin Low Low <15' Demi Above 18'4" 2195 From Demin Demineralized Water system is y o further water to Turbine n ground 2134 Trailer to Turbine no longer considered potentially Action Building Water 2004 Building. contaminated.

Pipe is PVC /

Reference S &S Very Specification Low

!15050.66-1001 A-6 WD-2; 2" Demin Low Low <5' Demi Above 19'6" 2196 Turbine Building Demineralized Water System is No further Water transfer n ground 2004 to Condensate no longer considered potentially Action pump recirc lines Water Transfer Building. contaminated.

to tank _ _ I/ Replaced in 1998

Oyster Creek UndergroundPiping Program Descriptionand Status Topical Report 116 Rev. 3 Page 64 of 82 Appendix 4 -Line no longer in the Program ID Description Suscep Conseque Len. Fluid Coating/ EL/ Drawing Located Comments Action System/ Line size tibility nce / Protecti Depth Cont on amin ation Al. 6061 Very with above No longer underground Pipe Low ground piping.

A-7 WD-2, 4" Demin Low Low > 125' Demi Above 16' 2192 Replaced in 1998 with above No further water from TB n ground ground piping. Action and Demin Trailer Water to Demin. Storage / Demineralized Water System is Tank. Very no longer considered potentially Al 6061 Low contaminated.

_______._No longer underground Pipe A-8 WD-l; 6" From Low Low >75' Demi Above 16' 2192 Demin Tank To Replaced in 1998 with above No further the Demin Tank n ground Cond. Transfer ground piping. Action To Cond. Transfer Water Building Building / Al 6061 Al 6061 Very Low A-9 WD-2,'4' Detain Mediu Low > 125' Demi Cathodic 16' 2192 West of Cond. Deemineralized Water System is No further water to Reactor m n Protectio Transfer Building. no longer considered potentially Action Building, Located Water n Line was replaced contaminated.

south of the / in 1993.

Reactor Building, Very Al 6061 Low A- WD-2, 2' Detain Mediu Low > 125' Demi Unknow 16' 2192 From base of the Demineralized Water System is No further 10 From base of the m n n Stack to the no longer considered potentially Action

'Stack to the Water Boiler house, Al contaminated.

Boiler house, Al / 6061 6061 1 Very I I I III_ _

Oyster Creek Underground Piping Program Descriptionand States Topical Report 116 Rev. 3 Page 65 of 82 Appendix ID 4 - Line no loneer Description in tit Proarsn---

Suscep -a--

Conseque Len. Fluid Coating/_ __

EL/ Drawing Located Comments Action System/ Line size tibility nce I Protecti Depth Cont on amin ation Low CS- CH -2; 8" from NA NA 30' Cond Coal Tar 18' 2193 From the Replaced In 1992 With a No further action 25 TB to ensate Condensate Stainless Steel Line Reference Basis line Sucker/Dumper transfer Building OC-MM-323643-001 - replaced with SS Station; A] 06' to the west wall of line is being the Turbine Removed from this list and added tracked on SS Building to the SS list as SS-4 table as SS-4 CS- CH-8; 3" Low Low <5' Water Coal Tar 19'6" 2196 BR Boiler house to Walkdown shows this line is not No further 14 Condensate A53 / -3'6" 2015 base of the Stack underground Action.

Medi urn CS- SH; 8" Heating Low Low <5' Steam Coal Tar 19'6".- 2196 BR Boiler house to Walkdown shows this line is not No further 15 Steam A53 / 3'6" 2015 base of the Stack underground Action.

Medi

_________________________ um ______

Oyster Creek UndergroundPiping ProgramDescription and Status Topical Report 116 Rev. 3 Page 66 of 82 ApDendix 5 -Siecitic Service Life Asse~~ment~ 2007.

Configuration/ Degradation Specific Expected Expected Expected Last Assumptions End of Basis/ Reference.

Process Fluid Mechanism Lines Coating Corrosion Minimum Inspection (3) Predicted Reference/ Sectionl Life (1) Rate (2) Service Life or Repair Service Action Life 1+(3/2)

Carbon Steel Pipe Internal ESW 0 to 40 10- 18 mpy ESW and SW with Coal Tar localized years History/ TDR 829 Enamel internal coating failure ESW 0 to 40 19 to 30 Minimum of Replaced Assumed 350 mil 2027 6.2.1 coating and Salt Lines years years 19 years in 2008 margin to Tnain water SW 0 to 40 4 - 16 mpy ESW and SW years History/ TDR 829 SW lines 0 to 40 25-60 Minimum of 20% Assumed 400 mil 6.2.1 years 25 years Replaced margin to Tmin

.in

____ 2008 Carbon Steel Pipe Coating End General 15 to 40 5 to 20 mpy 1992 SW Leak /

with Coal Tar of Service Life years TP 116 Enamel external CS-19 15 to 40 25 -60 Minimum of 1969 Assumed 475 mil 2009 GW Planned in 8.2.2.1.

coating direct and CS- years 40 years margin to Tmin 2010 buried 20 CS-I 15 to 40 No Credit Minimum of 1997 2012 Replacement ,8.2.3.1 15 years Planned CS-1 7 & 15 to 40 No Credit Minimum of 1993 2008 GW Planned in -8.2.4.2 CS-18 15 years _ 2010 CS-24 15 to 40 12-50 Minimum of 1993 Assumed 250 mil 2012 8.2.4.4 years 27 years 2007(GW) margin to Tmin , . I_.....

CS-26 15 to 40 4 - 15 years Minimum of 1993 Assumned 75 mil- 2012 Replacement 8.2.4.5 19 years margin to Tmin Planned CS-27 15 to 40 5 to 20 mpy Minimum of 2007(GW) Assumed 75 mil 2012 Re inspect 2012

- 20 years margin to Trinn -.

CS-35 15 to 40 8-30 years Minimum of Early 1980 Assumed 150 mil 2029 8.2.4.6 23 years margin to Tmin Replaced all in

_____________2008 CS-2, 15 to40 6-25 years Minimum of 1997 Assumed 125 mil 2018 GWPlanned in 8.2.4.1 CS-3, 21 years margin to Trin[ 2010 CS,4, and CS-5 _ .

CS-3 I 15 to 40 8 - 30 years Minimum of Mid Assumed 150 mil 2008 Abandoned 8.2.4.7 23 years 1980's margin to T[min I ___ -

Oyster Creek Underground Piping Program Description and Statos Topical Report It 6 Rev. 3 Page 67 of 82 ADnendix 5 -S~eciflc Service Life A ~~~ment~ 2007 Configuration/ Degradation Specific Expected Expected Expected Last Assumptions End of Basis/ Reference Process Fluid Mechanism Lines Coating Corrosion Minimum Inspection (3) Predicted Referencel Section!

Life (1) Rate (2) Service Life or Repair Service Action Life 1+(3/2)

CS-22, 15 to 40 10-40 Minimum of Early Assumed 200 mil 2010 GW Planned in 8.2.4.3 CS-23 years 25 years 1980's margin to Tmin 2010

&CS-30 Elevated General 2-10 5 to 20 mpy 2003/ Heat Steam process years Condensate Return temperatures. line failure!

Small bore TP1 16 lines CS-10 10 years 8 to 30 Minimum of 2007 GW Assumed 150 mil 2022 Re inspect 8.2.3.3 CS- Il years 18 years Inspected margin to Tmin 2010\Per PM CS-9, in 2008 PM57304M CS-6 No credit 5 to 20 Minimum of 2004 Assumed 100 mil 2009 GW Planned in 8.4.2.4 CS-7 years 5 years Inspected margin to Tmin 2010 CS-8 in 2008 Per PM PM57304M Aluminum Pipe Improper General 15-40 16-20 1980 and 1996 with Coal Tar Application mnpy in wet DW- I and DW-2 Enamel external soil failures and TP coating direct 116 buried 5 to 10 mpy in dry soil The Corrosion Handbook edit by jUHL1 -G, A-4 0 30 mpy Minimum of 1993 Assumed 250 mil 2016 Re inspect in 2016 8.2.2.3 8 years 2007 GW margin to Tmin Inspected

_____._ in 2008 ....

A-2 15-40 Dry soil - Minimum of "mid 1980's Assumed 200 mi 2015 GW Planned in 8.2.3.5 20 to 40 35 years margin to Tmrin 2010 Iyears ... .

A-I 0 Dry soil - Minimum of 1998 Assumed 200 mit 2012 Re inspect in 2012 8.4.2.3 20 to 40 40 years 2007 GW margin to Train

___________________________________years _________________

Oysrer Creek UndergroundPiping ProgramDescription anti Staras Topical Report 116 Rev. 3 Page 68 of 82 Appendix 5 -Specific Service Life Assessments 2007.

Configuration/ Degradation Specific Expected Expected Expected Last Assumptions End of Basis/ Reference Process Fluid Mechanism Lines Coating Corrosion Minimum Inspection (3) Predicted Reference/ Section/

Life (1) Rate (2) Service Life or Repair Service Action Life 1+(3/2)

Stainless steel Unknown General 15 to 40 5 to 10 mpy Limited corrosion with Devoe or years data is available Coal Tar Coating However from Corrosion Engineering by M Fontana C 1986-a rate of 5 to 10 MPY was observed SS-I and 15 to 40 15 to 30 Minimum of 1993 Assumed 150 mil 2022 GW Planned in 8.2.3.2 SS-2 years years , 30 years margin to Tnain 2010 Brass Unknown General 15 to 40 1-5 mpy Corrosion rate years range from Corrosion Handbook from UHLIGTable!O

_page 458 CS-37 I5 to 40 25- 60 year Minimum of 1968 Assumed 125 mil 2009 Replace in 2010 8.2.3.4 years 40 years margin to Tmin

From Drawing BR 2193 Af r 7A.9 CS-42 I

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From Drawing BR 2193 TR 116 Appendix 6 page 77 of 82

From Drawing BR 2193 TRk 116 Appendix 6 page 78 of 82

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From Drawing 15050-11 0o-EM-651 TR 116 Appendix 6 page 82 of 82