Text

Document: 1R20 AF Buried Pipe Insp Results, Notification #20457262, Salem 1- Auxiliary Feedwater
	ML103010496
Person / Time
Site:	Salem
Issue date:	08/18/2010
From:	; Public Service Enterprise Group
To:	; Office of Information Services
References
	FOIA/PA-2010-0334, 20457262
	Download: ML103010496 (75)
	v • d • e

Notification Overview Run Date: 08/18/2010 Run Time: 14:01:52 U Page: 1 of Notification 20457262 2

Notification 20457262 Notification type N2 Description (88) 1R20 AF Bu*ried Pipe Insp Results Nuc. Activity Report Reporter MONTGOME1 781 19:34:16 Notification date 04/05/2010 Start date 04/06/2010 £-nd date Start time 11:40:211 -.nd time 00:00:00 Priority C-Routine Sig. Level 4 Main WorkCtr. S-EEP08 Funct. location S 1AF AUXILIARY FEEDWA TER (SALEM)

Equipment Assembly Order 70108698 PM planner grp 099 Nuclear Deifault 04/06/2010 11:42:18 THOMAS CACHAZA (NUT1C)

- - - - Long Text Object Identification**************

Notification 000020456999 Long text 04/05/2010 19:34:16 NUCLEARNOT (NUCLEARNOT)

Notification submitted by: Robert Montgomery 856-339-1781 ENTNBU\NURSM:

CONDITION DESCRIPTION/LOCATION (THE INAPPROPRIATE ACTION AND ITS NEGATIVE EFFECT/INCLUDE A DETAILED LOCATION DESCRIPTION):##

The Guided Wave inspection of the #12 & #14 Auxiliary Feedwater Buried Piping revealed a potential pipe external wall loss range of 20% to 44% in the buried portion of these lines. The resultant thickness comparisons are as follows: Design Nominal Thickness is 0.337 inches, Minimum allowable calculated for the inspection was 0.278 inches, and the wall loss range would result in a remaining wall thickness range of 0.270 inches down to 0.148 inches (ie. Less than the calculated minimum allowable for the inspection).

The extent of corrosion identified by the Guided Wave on the #14 train included a total length of approximately 90 feet, and for the #'12 train it was on a length of approximately 60 feet. Guided Wave was also performed on the #14 train from inside the Outer Penetration, to confirm the extent of the wall loss. (This end of the #14 train also exhibited 20 # 44% wall loss).

Additionally, confirmatory UT was performed by NDE Services on both pipe areas that were excavated for installation of the Guided Wave clamp on the SW side of the Unit 1 Containment Building. The UT thickness on the excavated portion of each train ranged from 0.316 inches to 0.235 inches on the #14 train, and from 0.335 inches to 0.252 inches on the #12 train.

These two buried lines were being inspected under Work Order 60084266. Pictures of the corroded area that was exposed are located at M:\Shared\Buried Piping\Salem Aux Feedwater.

ACTIVITIES, PROCESSES, PROCEDURES INVOLVED: A\

Work Order 60084266 Buried Piping ER-AA-5400 and ER-AA-5400-1002 WHY DID CONDITION HAPPEN?

Possible coating degradation of the buried pipe over time (almost 40 years).

Inspections were performed in support of the Salem Buried Pipe Program inspection of High Risk / Rank buried piping locations.

Notification Overview M1040k Run Date: 08/18/2010 Run Time: 14:01:52 Page: 2 of 2 U Notification 20457262 CONSEQUENCES:

Possible pipe replacement. Use of replacement contingencies in subject work order.

REQUIREMENTS IMPACTED:

Pipe wall loss below the minimum allowable that was calculated to support the inspection.

ADVERSE PHYSICAL CONDITIONS:

Apparent pipe degradation and pipe coating degradation of the entire buried portion of the WHO WAS NOTIFIED:

Outage Director EOM, ECC Engineering Mgr.

Buried Pipe Program Corporate Engineer Salem Programs Engineering Manager KNOWLEDGEABLE INDIVIDUALS:

J. Melchionna, R. Montgomery REPEAT OR SIMILAR CONDITION:

None IMMEDIATE ACTIONS AND RECOMMENDED ACTIONS:

Per ECC / OCC, Engineering to develop plan for evaluating G-wave results for continued operation, for contingency replacement implementation, or other alternatives. Suggest NUCR to Design Engineering for plan development / recommendations.

Resolution required prior to end of 1R20.

Reference Drawings:

P&ID 205236 (Zones F,8 & G,8)

Arrg. Dwg. # 207483 (Zones A # D, 4 - 9)

ISO # AF13A Sh. 1 04/06/2010 11:41:29 THOMAS CACHAZA (NUT1C) 04/06/2010 11:45:27 THOMAS CACHAZA (NUT1C)

N1 for NUCM work order 20456999 Detail Position 0001 Text AF Burried pipe corrosion Object part Damage Assembly Error class End of report

Work Order Shop Papers 08/18/2010 W011 4w, 11w i# FINOW 70108698 Order: 70108698 (88) 1R20 AF Buried Pipe Insp Results Order Type NUCR Status TECO CNF MANC NMAT PPRT PRC SETC Notification 20457262 Unit Sl Functional Location SlAF AUXILIARY FEEDWATER (SALEM)

Equipment Assembly Location Room System AF Priority 5 C-Routine Main Work Center S-EEP08 MONTGOMERY ROBERT Status TECO CNF MANC NMAT PPRT PRC SETC Basic Dates: Start: 04/30/2010 Finish: 04/30/2010 Overdue:

Sfty Rltd/QA Reqd Sfty Class Mrule Code REQD SEISMIC EQ Permission Date:

to Begin Work Time: 00:00:00 Description of Work (88) 1 R20 AF Buried Pipe Insp Results

- - - - Long Text Object Identification**************

Notification 000020456999 Long text 04/05/2010 19:34:16 NUCLEARNOT (NUCLEARNOT)

Notification submitted by: Robert Montgomery 856-339-1781 ENTNBU\NURSM:

CONDITION DESCRIPTION/LOCATION (THE INAPPROPRIATE ACTION AND ITS NEGATIVE EFFECT/INCLUDE A DETAILED LOCATION DESCRIPTION):##

SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Page 1 of 3

Work Order Shop Papers 08/18/2010 U FIM&JW The Guided Wave inspection of the #12 & #14 Auxiliary Feedwater Buried Piping revealed a potential pipe external wall loss range of 20% to 44% in the buried portion of these lines. The resultant thickness comparisons are as follows: Design Nominal Thickness is 0.337 inches, Minimum allowable calculated for the inspection was 0.278 inches, and the wall loss range would result in a remaining wall thickness range of 0.270 inches down to 0.148 inches (ie. Less than the calculated minimum allowable for the inspection).

The extent of corrosion identified by the Guided Wave on the #14 train included a total length of approximately 90 feet, and for the #' 12 train it was on a length of approximately 60 feet. Guided Wave was also performed on the #14 train from inside the Outer Penetration, to confirm the extent of the wall loss. (This end of the

14 train also exhibited 20 # 44% wall loss).

Additionally, confirmatory UT was performed by NDE Services on both pipe areas that were excavated for installation of the Guided Wave clamp on the SW side of the Unit 1 Containment Building. The UT thickness on the excavated portion of each train ranged from 0.316 inches to 0.235 inches on the #14 train, and from 0.335 inches to 0.252 inches on the #12 train.

These two buried lines were being inspected under Work Order 60084266. Pictures of the corroded area that was exposed are located at M:\Shared\Buried Piping\Salem Aux Feedwater.

ACTIVITIES, PROCESSES, PROCEDURES INVOLVED:

Work Order 60084266 Buried Piping ER-AA-5400 and ER-AA-5400-1002 WHY DID CONDITION HAPPEN?

Possible coating degradation of the buried pipe over time (almost 40 years).

Inspections were performed in support of the Salem Buried Pipe Program inspection of High Risk / Rank buried piping locations.

CONSEQUENCES:

Possible pipe replacement. Use of replacement contingencies in subject work order.

REQUIREMENTS IMPACTED:

Pipe wall loss below the minimum allowable that was calculated to support the inspection.

ADVERSE PHYSICAL CONDITIONS:

Apparent pipe degradation and pipe coating degradation of the entire buried portion of the WHO WAS NOTIFIED:

Outage Director EOM, ECC Engineering Mgr.

Buried Pipe Program Corporate Engineer Salem Programs Engineering Manager KNOWLEDGEABLE INDIVIDUALS:

J. Melchionna, R. Montgomery SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Page 2 of 3

Work Order Shop Papers 08/18/2010 nWf VIA All l REPEAT OR SIMILAR CONDITION:

40AuNU None IMMEDIATE ACTIONS AND RECOMMENDED ACTIONS:

Per ECC / OCC, Engineering to develop plan for evaluating G-wave results for continued operation, for contingency replacement implementation, or other alternatives.

Suggest NUCR to Design Engineering for plan development / recommendations.

Resolution required prior to end of 11R20.

Reference Drawings:

P&ID 205236 (Zones F,8 & G,8)

Arrg. Dwg. # 207483 (Zones A # D, 4 - 9)

ISO # AF13A Sh. 1 04/06/2010 11:41:29 THOMAS CACHAZA (NUT1C)

SAFETY: The Only C. H.0.1. C. E.

Commitment Help Oversight Involvement Page 3 of 3

Operation List Summary 08/18/2010 A004 U,

70108698 OP Sub Work Description Start Date Work No Durtn Op. Center 0010 S-EEP08 (88) 1 R20 AF Buried 04/30/2010 0.0 0 0.0 Pipe Insp Results 0020 S-EP02 ENTER TREND CODING 04/30/2010 0.0 0 0.0 003__0 1 S-EPB04 SA - PROVIDE OE REPO 04/07/2010 0.0 0 0.0 RT TO COORDINATOR 0040 S-LRA06 This operation is fo 04/11/2010 0.0 0 0.0 r the station OE coo 0050 S-EDM1 1 TE - max AFW pressur 04/10/2010 0.0 0 0.0 e in buried pipe F0060CF J S-EEP08 PROVIDE UPDATE OE 1R 04/30/2010 0.0 0 0.0 SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 1 of 2

Operation List Summary 08/18/20.10 A0041 rýw 20 AF Buried Pipe 0070 S-LRA06 Psot AF Buried Pipe 04/30/2010 0.0 0 0.0 Final 0080 S-EEP06 Evaluate for ASME Fa 04/13/2010 0.0 0 0.0 ilure 0090 S-OSHOO OP EVAL 10-006 Unit 04/26/2010 0.0 0 0.0 1

0100 S-EDM1 1 Revised TE - max AFW 04/18/2010 0.0 0 0.0 pressure 0110 S-EDM02 Prep/Rev/Appr Tech E 04/26/2010 0.0 0 0.0 val Past Operability 0120 S-EDM03 Perform Tech Eval Re 04/30/2010 0.0 0 0.0 vised Ul AFW Past Op SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 2 of 2

Operation Key Info 08/18/2010 U rn 70108698 Order: 70108698 (88) 11R20 AF Buried Pipe Insp Results Operation: 0010 (88) 11R20 AF Buried Pipe Insp Results Work center: S-EEP08 NNUC Status: TECO CNF MANC NMAT PPRT Number of People: 0 Scheduled Dates: Start: 04/30/2010 Finish: 04/30/2010 Planned Hours: 0.0 Actual Dates: Start: 04/09/2010 Finish:04/30/201 0 Actual Hours: 0.000 Personnel Number:

Completion Confirmation Number: 8161979 Confirmation Text:

Due Date Changed - See LT Due Date Changed - See LT Aux Feed pipe investigation is still in progress.

Signature: ROBERT S MONTGOMERY Confirmation Text:

See LT - Not Required See LT - Not Required Subject Tech Eval not required based on the following:

EQACE 70109108 has been assigned for this work - thus superceding this tech eval.

WO 60084266 Op. 10 has the Buried Pipe Program Engineer detailed evaluation of the Aux Feed Piping as required per ER-AA-5400-1002.

Subject NUCR has Tech Evals for Past Operability and Revised Pressure on AF System.

SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 1 of 68

Operation Key Info 08/18/2010 U

Signature: STEVEN B DAVIES Description of Work:

(88) 1 R20 AF Buried Pipe Insp Results Perform Tech Eval <insert short description>

NOTE: Revise short text to include a short, abbreviated, up to 35 character, title of the Technical Evaluation. For example:

"TE - Pipe Integrity w/ 1039A Valve Open" This note may be erased from the operation text.

Prepare a technical evaluation using the guidelines and template in CC-AA-309-101, Technical Evaluations Template, as follows:

Document Number: (The SAP order and operation number)

Title:

(The brief subject / title description assigned by the preparer)

Reason for Evaluation / Scope:

Detailed Evaluation:

Conclusions / Findings:

References:

Preparer (Name & Date):

Independent /Peer Reviewer (Name & Date):

Approved (Name & Date):

SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 5 of 68

Operation Key Info 08/18/2010 o rinmh Order: 70108698 (88) 1 R20 AF Buried Pipe Insp Results Operation: 0020 ENTER TREND CODING Work center: S-EP02 NNUC Status: TECO CNF MANC NMAT PPRT Number of People: 0 Scheduled Dates: Start: 04/3()/2010 Finish: 04/30/2010 Planned Hours: 0.0 Actual Dates: Start: 04/30//2010 Finish:05/04/2010 Actual Hours: 0.000 Personnel Number:

Completion Confirmation Number: 8161980 Confirmation Text:

Equipment trend coding completed Signature: GLENN D JONES Description of Work:

SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 6 of 68

Operation Key Info 08/18/2010 U0 41 Component Manufacturer:

Component Model Number:

Component Part Number:

Component Type: (for counterfeit or substandard parts or components)

Component Vendor/Supplier/Distributor: (for counterfeit or substandard parts or components)

Information

Contact:

Name:

Title:

Telephone:

E-mail:

Corrective Action Program Documents: (text here)

Attachments (Pictures, Root Cause, and so forth):

OE Author's Checklist:

OE Report Preparation Note: The preferred font is black Arial 12 point; however, any similar font is acceptable.

Does the abstract concisely summarize what happened, the consequences, and the causes?

Does the title clearly describe the event, and is it free of acronyms?

Are preliminary and follow-up reports clearly identified at the beginning of the title?

Is the station name in parentheses (station name) at the end of the title?

Does the report include the correct calendar date for the event date?

Is the significance identified as consequential, near-miss, or nonconsequential?

"1 Are the most important lessons learned/barriers identified and accurately described?

Are the most applicable industry work groups identified?

Does the description provide sufficient detail-the facts-for readers to understand the event and the nature of the surrounding situation?

Are the consequences detailed and clear?

Are the causes clearly understood?

Do the corrective actions address the causes?

Is previous industry OE identified?

Is the equipment section completed?

Is the contact information complete with name, title, telephone number, and e-mail address?

Is the station corrective action program report number included?

"I Are there attachments that can add value or perspective to understand the event?

Posting to Nuclear Network "1 Use the OE report template. Do not use a table format.

SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 11 of 68

Operation Key Info AW0n 08/18/2010 W 'WJF AM If document changes were tracked in the file, ensure the changes been accepted or deleted before copying and posting the document in the Nuclear Network forum.

"1 Add attachments and save documents in Word 97-2003 before copying and pasting them into the forum because some stations may not have Word 2007.

"1 After the report message is created, run spell check to review the OE report.

if Review the OE report after it is posted, and make any needed revisions before midnight- when the report is automatically downloaded to the industry. Use the edit button to edit the message, and select "Update Post." After midnight, errors should be reported to your INPO station analyst and Nuclear Network staff to determine if an updated OE report should be posted.

IV Errors in the OE report subject/title can only be corrected by the Nuclear Network staff before 4:30 EST.

-Important Aspects of Event Included (e.g., Downpowers, Equipment ACE Results, etc.)

-Format Consistent with above Template

-Complete Sentences used for all Areas

-Tense is consistent throughout the OE report (Usually Past tense).

-All sections filled out (including abstract)

-Abstract is a summary of the entire event/issue.

-Reason for Message (it is more than: "to share the event with the industry")

-PSEG/Station Specific Nomenclature should be avoided (Notification 20285405 was written to identify the concern. Instead use: An issue request was written in the corrective action process.)

-Procedure/Notification Reference use Titles vs. Numbers

-Noun Names used vs. Component Numbers (e.g. valve numbers may be unique but the function of the valve by title is universally known like 1PS2, Use the words, Pressurizer Spray Valve)

-Learnings are Cleary Delineated

-Line Manager Approval SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 12 of 68

Operation Key Info 08/18/2010 MIn440&=N Order: 70108698 (88) 1 R20 AF Buried Pipe Insp Results Operation: 0040 This operation is for the station OE coo Work center: S-LRA06 NNUC Status: TECO CNF MANC NMAT PPRT Number of People: 0 Scheduled Dates: Start: 04/11 /2010 Finish: 04/11/2010 Planned Hours: 0.0 Actual Dates: Start: 04/11/ 2010 Finish:04/11/2010 Actual Hours: 0.000 Personnel Number:

Completion Confirmation Number: 8161982 Confirmation Text:_____________________________

Posted as OE30927 4/10 Signature: JOSEPH A ARENA III Description of Work:

This operation is for the station OE coordinator to ensure the OE message is

- - - - Long Text Object Identification**************

Order 000070108698 Operation 0040 Long text

- - - - -******* *** ***************** **l ****************

generated and issued in a timely manner.

SAFETY: The Only C.H.O.I.C.E.

-Commitment Help Oversight Involvement Communication Empowerment Page 13 of 68

Operation Key Info 08/18/2010 nW41 U 8 MM Order: 70108698 (88) 1R20 AF Buried Pipe Insp Results Operation: 0050 TE - max AFW pressure in buried pipe Work center: S-EDMi 1 NNUC Status: TECO CNF MANC NMAT PPRT Number of People: 0 Scheduled Dates: Start: 04/1( )/2010 Finish: 04/21/2010 Planned Hours: 0.0 Actual Dates: Start: 04/10/ 2010 Finish:04/21/2010 Actual Hours: 0.000 Personnel Number:

Completion Confirmation Number: 8163337 Confirmation Text:

Tech Eval prepared Tech Eval prepared Document #: 70108698-0050 TITLE: Maximum Pressure in Underground Auxiliary Feedwater Piping REASON FOR EVALUATION / SCOPE:

Degradation was found in the underground Auxiliary Feedwater (AFW) piping prior to entering the Outer Penetration Area per Notification 20456999. This is the supply piping to 12 & 14 Steam Generators (SGs), downstream of the AFW pumps. This Technical Evaluation determines the maximum potential pressure in this piping for input into a subsequent evaluation on minimum wall.

DETAILED EVALUATION:

Auxiliary Feedwater Operation:

SAFETY: The Only C.H.O.I.C.E.

Commitment Help gversight Involvement Communication Empowerment Page 14 of 68

Operation Key Info n 08/18/2010 VW1 AV The AFW System provides flow to the SGs during plant cooldown and startup conditions for decay heat removal when the Main Feedwater (MFW) System is out of service. The AFW System also provides flow to the SGs during transient conditions such as Steam Line Break (SLB), Feedwater Line Break (FLB), Small Break Loss of Coolant Accident (SBLOCA), Loss of Normal Feedwater (LONF), Loss of Offsite Power (LOOP) and Station blackout (SBO). The system consists of two Motor Driven AFW Pumps (MDAFPs), each of which feeds two SGs, and one Turbine Driven AFW Pump (TDAFP), which feeds all four SGs. During plant cooldown and startup, operators manually control AFW flow via the AF21 control valves for the MDAFPs and via the AF11 control valves for the TDAFP. During transient conditions, the AF21 control valves are in automatic and control to maintain MDAFP discharge pressure; the AF11 control valves are full open.

The maximum potential pressure in the system would be with all the AFW pumps deadheaded. However, this is an unrealistic condition. The actual maximum system pressure is a function of the maximum potential SG pressure. Per Reference 3, the maximum SG pressure is assumed to be the lowest Main Steam (MS) safety valve setting (1070 psig - Reference 2) plus 3% accumulation, or 1102 psig (1117 psia).

The maximum system pressure would occur with all three pumps running on their design performance curves. Reference 3 provides a hydraulic analysis for the system transient conditions, using the AFW System hydraulic model. The SLB Inside Containment transient is analyzed with this pump alignment for two conditions - no failures and MDAFP runout protection failure, which is a failure of one of the AF21 valves to the full open position. The actual maximum pressure in a particular SG supply line would occur for a failure of an AF21 valve to the full closed position, which maximizes pressure in the SG supply line that remains aligned to the associated MDAFP. This condition was not analyzed in Reference 3 as the parameter of concern was maximum total SG flow. As such, additional cases were run with 11AF21 closed, to maximize pressure in the 12 SG supply piping (Case A), and with 13AF21 closed, to maximize pressure in the 14 SG supply piping (Case B). For conservatism and simplicity, it was assumed that the remaining AF21 valves are full open. In reality they would be throttled to maintain MDAFP discharge pressure; however, determining their position is an iterative and cumbersome process. Case 4 from Reference 3 Proto-Flo database S-C-AF-MDC-0445-R3.DBD was modified accordingly.

The pressure in the underground piping is assumed to be that from the nearest upstream node in the model, which are the tie-ins between the MDAFP and TDAFP discharges in the Auxiliary Building. The resulting pressures at these nodes are 1259 psia (1244 psig) for 12 SG supply (Case A) and 1270 psia (1255 psig) for 14 SG supply (Case B). The Proto-Flo output reports are included as Attachments 1 and 2, respectively.

During normal plant cooldown and startup, it is unlikely all three AFW pumps would be running. Furthermore, the AF21s and/or AF11s are manually throttled to control cooldown rate and/or maintain SG level, which reduces the downstream pressure and thus the pressure in the buried piping. Therefore, this condition is bounded by the SLB transient condition with respect to pressure in the buried piping.

Auxiliary Feedwater System Testing:

SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 15 of 68

Operation Key Info A 0

08/18/2010 U f1MVUfW MP, AW MDAFP and TDAFP full flow testing to the SGs is performed per References 7 & 8 during each Refueling Outage. The highest pump discharge pressure occurs for the TDAFP test. The TDAFP discharge pressure was originally base lined at 1250 psig in 1998 (WO #960829007). Since then the TDAFP discharge pressure has varied been between 1235 and 1248 psig. These pressures are bounded by the limiting SLB Case from above (Case B, 13AF21 fails closed). Furthermore, similar to normal plant cooldown and startup, the AF21s and AF11 s are manually throttled during testing to set the required flow, and so the pressure in the buried piping to 12 and 14 SGs would be even less. Therefore, full flow testing is bounded by the SLB transient condition. During quarterly surveillance testing (References 4-6), the AF21s and AF11s are closed, with flow going through the respective pump recirculation line, and thus is not applicable to this evaluation.

Main Feedwater Operation:

During normal plant operation, the MFW System provides flow to the SGs, and the AFW System is isolated from the SGs. During this condition, there is a potential for back leakage through the AF23 stop check valves, which are located just upstream of the AFW tie-ins to the MFW System. A leak check of these valves is performed quarterly per Reference 9. Trending of past test results finds no indication of significant leakage past these check valves. Test results found AFW line pressures typically around 25-30 psig with a MFW pressure of around 835-845 psig. A couple exceptions were for the test on 8/30/09, where the 12AF23 upstream pressure was 150 psig, and for the test on 3/1/10, where the 11AF23 and 12AF23 upstream pressures were about 115 psig. If these couple results were an indication of actual leakage, the AFW line pressure was still significantly below the MFW line pressure.

Thus, even if the MFW System flow was low, with corresponding higher system pressure, the resulting AFW line pressure with any leakage past 12AF23 would still be very low compared to that with the AFW System in service.

CONCLUSIONS/FINDINGS:

The maximum potential pressure in the buried AFW piping during an accident is 1259 psia (1244 psig) for 12 SG supply and 1270 psia (1255 psig) for 14 SG supply.

This occurs for a SLB Inside Containment transient with a single failure of an AF21 valve to the closed position, at the maximum potential SG pressure. For conservatism, the maximum operating line pressure in the buried AFW piping is set at 1275 psi.

REFERENCES:

1. P&ID 205236, Revision 54, Unit 1 Auxiliary Feedwater

2. P&ID 205203, Sheet 1, Revision 77, Unit 1 Main, Reheat & Turbine By-Pass Steam

3. S-C-AF-MDC-0445, Revision 3, Auxiliary Feedwater System Hydraulic Analysis SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 16 of 68

Operation Key Info n0 41 AIIIII 08/18/2010 j# r1VIw Il M

4. Si.OP-ST.AF-0001, Revision 15, Inservice Testing - 11 Auxiliary Feedwater Pump

5. SI.OP-ST.AF-0002, Revision 16, Inservice Testing - 12 Auxiliary Feedwater Pump

6. SI.OP-ST.AF-0003, Revision 38, Inservice Testing - 13 Auxiliary Feedwater Pump

7. S1.OP-ST.AF-0005, Revision 11, Inservice Testing Auxiliary Feedwater Valves Mode 4-6

8. S1.OP-ST.AF-0007, Revision 19, Inservice Testing Auxiliary Feedwater Valves Mode 3

.9. SI.OP-ST.AF-0006, Revision 10, Inservice Testing Auxiliary Feedwater Valves

10. UFSAR Section 10.4.7.2, Auxiliary Feedwater System; Section 15, Accident Analysis ATTACHMENTS

1. Case A Proto-Flo Ouput Reports: SLB Inside Containment with 11AF21 Failing Close

2. Case B Proto-Flo Ouput Reports: SLB Inside Containment with 13AF21 Failing Close NOTE: The complete Technical Evaluation, including attachments, has been submitted to Records Management, Document Number 70108698.

CO-PREPARER: Kevin King Date: See SAP INDEPENDENT REVIEWER: Michael Crawford Date: See SAP APPROVED: Alan Johnson Date: See SAP Signature: KEVIN C KING Confirmation Text:

Independent review by NUMEC per telecon SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 17 of 68

Operation Key Info 08/18/2010 0

Signature: MICHAEL E CRAWFORD Confirmation Text:

Manager Approved Signature: ALAN A JOHNSON Confirmation Text:

Superseded by 70108698-0100 Signature: KEVIN C KING Description of Work:

TE - max AFW pressure in buried pipe

- - - - Long Text Object Identification**************

Order 000070108698 Operation 0050 Long text Perform Tech Eval <insert short description>

NOTE: Revise short text to include a short, abbreviated, up to 35 character, title of the Technical Evaluation. For example:

"TE - Pipe Integrity w/ 1039A Valve Open" This note may be erased from the operation text.

Prepare a technical evaluation using the guidelines and template in CC-AA-309-101, Technical Evaluations Template, as follows:

Document Number: (The SAP order and operation number)

Title:

(The brief subject / title description assigned by the preparer)

Reason for Evaluation / Scope:

SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 18 of 68

Operation Key Info 0W"1hýý WA 08/18/2010 o RUMMNW Detailed Evaluation:

Conclusions / Findings:

References:

Preparer (Name & Date):

Independent /Peer Reviewer (Name & Date):

Approved (Name & Date):

SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 19 of 68

Operation Key Info U' 08/18/2010 Order: 70108698 (88) 1R20 AF Buried Pipe Insp Results Operation: 0060 PROVIDE UPDATE OE 1R20 AF Buried Pipe Work center: S-EEP08 NNUC Status: TECO CNF MANC NMAT PPRT Number of People: 0 Scheduled Dates: Start: 04/30/2010 Finish: 04/30/2010 Planned Hours: 0.0 Actual Dates: Start: 04/30/2010 Finish:06/17/2010 Actual Hours: 0.000 Personnel Number:

Completion Confirmation Number: 8172073 Confirmation Text:

Update report provided to OE Coord. with Update report provided to OE Coord. with proper review and approval.

- - - - Long Text Object Identification**************

Order 000070108698 Operation 0060 Confirmation 0008172073 Confirmation counter 00000001 Long text Posted by OE Coordinator Signature: JOSEPH A ARENA III Description of Work:

PROVIDE UPDATE OE 1R20 AF Buried Pipe

- - - - Long Text Object Identification**************

Order 000070108698 Operation 0060 Long text SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 20 of 68

Operation Key Info A 0

08/18/2010 VIM 11W This notification has been determined by the Management Screening Committee to require an Operating Experience Report.

1. Use the INPO OE report template below to write the report.

2. Upload the report into a confirmation in this operation.

3. Obtain your Manager's approval in the above operation confirmation.

4. Email electronic version of the manager approved report to Joe Arena Salem (x1353) within 20 days of the event. Deliver a manager signed Traveler (available on the Opererating Experience Website)and the final version hard copy to the Regulatory Assurance Manager.

NOTE:

The INPO Goal is to issue reports within 50 days of the event.

Any extension beyond 30 days could impact meeting this goal.

Abstract:

(text here)

Title:

(text here)

Event Date: (text here)

Station Name/Unit Number: (text here)

Significance/Importance: (text here)

Lessons Learned for the Industry: (text here)

Applicability: (text here)

Description:

(text here)

Consequences: (text here)

Causes:

(text here)

Corrective Actions:

(text here)

Previous Industry OE/CE:

(text here)

Equipment Information:

NSSS/A-E:

Reactor Type:

SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 21 of 68

Operation Key Info A 0

08/18/2010 MW AV Affected System:

Component Manufacturer:

Component Model Number:

Component Part Number:

Component Type: (for counterfeit or substandard parts or components)

Component Vendor/Supplier/Distributor: (for counterfeit or substandard parts or components)

Information

Contact:

Name:

Title:

Telephone:

E-mail:

Corrective Action Program Documents: (text here)

Attachments (Pictures, Root Cause, and so forth):

OE Author's Checklist:

OE Report Preparation Note: The preferred font is black Arial 12 point; however, any similar font is acceptable.

IT Does the abstract concisely summarize what happened, the consequences, and the causes?

"1 Does the title clearly describe the event, and is it free of acronyms?

it Are preliminary and follow-up reports clearly identified at the beginning of the title?

it Is the station name in parentheses (station name) at the end of the title?

Does the report include the correct calendar date for the event date?

Is the significance identified as consequential, near-miss, or nonconsequential?

y Are the most important lessons learned/barriers identified and accurately described?

if Are the most applicable industry work groups identified?

If Does the description provide sufficient detail-the facts-for readers to understand the event and the nature of the surrounding situation?

Are the consequences detailed and clear?

Are the causes clearly understood?

Do the corrective actions address the causes?

Is previous industry OE identified?

"t Is the equipment section completed?

Is the contact information complete with name, title, telephone number, and e-mail address?

"1 Is the station corrective action program report number included?

if Are there attachments that can add value or perspective to understand the event?

Posting to Nuclear Network SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 22 of 68

Operation Key Info AW4 0 8/18/20 10 V W' '1W Use the OE report template. Do not use a table format.

If document changes were tracked in the file, ensure the changes been accepted or deleted before copying and posting the document in the Nuclear Network forum.

"1 Add attachments and save documents in Word 97-2003 before copying and pasting them into the forum because some stations may not have Word 2007.

If After the report message is created, run spell check to review the OE report.

"1 Review the OE report after it is posted, and make any needed revisions before midnight- when the report is automatically downloaded to the industry. Use the edit button to edit the message, and select "Update Post." After midnight, errors should be reported to your INPO station analyst and Nuclear Network staff to determine if an updated OE report should be posted.

it Errors in the OE report subject/title can only be corrected by the Nuclear Network staff before 4:30 EST.

-Important Aspects of Event Included (e.g., Downpowers, Equipment ACE Results, etc.)

-Format Consistent with above Template

-Complete Sentences used for all Areas

-Tense is consistent throughout the OE report (Usually Past tense).

-All sections filled out (including abstract)

-Abstract is a summary of the entire event/issue.

-Reason for Message (it is more than: "to share the event with the industry")

-PSEG/Station Specific Nomenclature should be avoided (Notification 20285405 was written to identify the concern. Instead use: An issue request was written in the corrective action process.)

-Procedure/Notification Reference use Titles vs. Numbers

-Noun Names used vs. Component Numbers (e.g. valve numbers may be unique but the function of the valve by title is universally known like 1PS2, Use the words, Pressurizer Spray Valve)

-Learnings are Cleary Delineated

-Line Manager Approval SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 23 of 68

Operation Key Info 40 48 A111111 MRA 08/18/2010 o0 rllNw" Order: 70108698 (88) 1 R20 AF Buried Pipe Insp Results Operation: 0070 Psot AF Buried PipeFinal Work center: S-LRA06 NNUC Status: TECO CNF MANC NMAT PPRT Number of People: 0 Scheduled Dates: Start: 04/3C)/2010 Finish: 04/30/2010 Planned Hours: 0.0 Actual Dates: Start: 04/30//2010 Finish:06/17/2010 Actual Hours: 0.000 Personnel Number:

Completion Confirmation Number: 8172074 Confirmation Text:

Posted UPDATE OE31083 Posted UPDATE 0E31083

- - - - Long Text Object Identification**************

Order 000070108698 Operation 0070 Confirmation 0008172074 Confirmation counter 00000001 Long text Signature: JOSEPH A ARENA III Description of Work:

Psot AF Buried PipeFinal rdinator to ensure the OE message is generated and issued in a timely mannei SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 24 of 68

Operation Key Info 08/18/2010 n004hl If 1

ý J# F'AJN Order: 70108698 (88) 11R20 AF Buried Pipe Insp Results Operation: 0080 Evaluate for ASME Failure Work center: S-EEP06 NNUC Status: TECO CNF MANC NMAT PPRT Number of People: 0 Scheduled Dates: Start: 04/1 3/2010 Finish: 04/13/2010 Planned Hours: 0.0 Actual Dates: Start: 04/13//2010 Finish:04/13/2010 Actual Hours: 0.000 Personnel Number:

Completion Confirmation Number: 8176974 Confirmation Text:

Evaluate for ASME Failure Evaluate for ASME Failure Determine to be a ASME Failure, UT Thickness measured wall thickness was below required code min. wall.

ASME flag set and ANII notified.

nuitg Signature: EDLEY T GILES Description of Work:

SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 25 of 68

Operation Key Info 0~

08/18/2010

1rmw Order: 70108698 (88) 1 R20 AF Buried Pipe Insp Results Operation: 0090 OP EVAL 10-006 Unit 1 Work center: S-OSH00 NNUC Status: TECO CNF MANC NMAT PPRT Number of People: 0 Scheduled Dates: Start: 04/26K/2010 Finish: 04/27/2010 Planned Hours: 0.0 Actual Dates: Start: 04/26/ 2010 Finish:04/27/2010 Actual Hours: ().000 Personnel Number:

Completion Confirmation Number: 8182640 Confirmation Text: ___________________________

OPEVAL NOT REQUIRED Signature: MICHAEL F ECKER Description of Work:

SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 26 of 68

Operation Key Info 08/18/2010 MIR AVw Order: 70108698 (88) 11R20 AF Buried Pipe Insp Results Operation: 0100 Revised TE - max AFW pressure Work center: S-EDMi 1 NNUC Status: TECO CNF MANC NMAT PPRT Number of People: 0 Scheduled Dates: Start: 04/1 E3/2010 Finish: 04/18/2010 Planned Hours: 0.0 Actual Dates: Start: 04/18//2010 Finish:04/18/2010 Actual Hours: 0.000 Personnel Number:

Completion Confirmation Number: 8186817 Confirmation Text:

Completed independent review of TE with Completed independent review of TE with minor editorial comments only. Concur with conclusion that the additional LONF case as posited is not a credible scenario and that the SLB inside containment remains the limiting case.

Signature: MICHAEL E CRAWFORD Confirmation Text:

Per Telecon: TE Prepared. Ready for Ind.

Per Telecon: TE Prepared. Ready for Ind. Rev.

Document #: 70108698-0100 TITLE: Maximum Pressure in Underground Auxiliary Feedwater Piping REASON FOR EVALUATION / SCOPE:

SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 27 of 68

Operation Key Info 08/18/2010 to rmNwW Degradation was found in the underground Auxiliary Feedwater (AFW) piping prior to entering the Outer Penetration Area per Notification 20456999. This is the supply piping to 12 & 14 Steam Generators (SGs), downstream of the AFW pumps. This Technical Evaluation determines the maximum potential pressure in this piping for input into a subsequent evaluation on minimum wall.

NOTE: This Technical Evaluation revises and supersedes Technical Evaluation 70108698-0050. It adds an additional scenario for evaluation of AFW pressure.

DETAILED EVALUATION:

Auxiliary Feedwater Operation:

The AFW System provides flow to the SGs during plant cooldown and startup conditions for decay heat removal when the Main Feedwater (MFW) System is out of service. The AFW System also provides flow to the SGs during transient conditions such as Steam Line Break (SLB), Feedwater Line Break (FLB), Small Break Loss of Coolant Accident (SBLOCA), Loss of Normal Feedwater (LONF), Loss of Offsite Power (LOOP) and Station blackout (SBO). The system consists of two Motor Driven AFW Pumps (MDAFPs), each of which feeds two SGs, and one Turbine Driven AFW Pump (TDAFP), which feeds all four SGs. During plant cooldown and startup, operators manually control AFW flow via the AF21 control valves for the MDAFPs and via the AF11 control valves for the TDAFP. During transient conditions, the AF21 control valves are in automatic and control to maintain MDAFP discharge pressure; the AF11 control valves are full open.

The maximum potential pressure in the system would be with all the AFW pumps deadheaded. However, this is an unrealistic condition. The actual maximum system pressure is a function of the maximum potential SG pressure. Per Reference 3, the maximum SG pressure is assumed to be the lowest Main Steam (MS) safety valve setting (1070 psig - Reference 2) plus 3% accumulation, or 1102 psig (1117 psia).

SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 28 of 68

Operation Key Info A n 08/18/2010 Ift AV The maximum system pressure would occur with all three pumps running on their design performance curves. Reference 3 provides a hydraulic analysis for the system transient conditions, using the AFW System hydraulic model. The SLB Inside Containment transient is analyzed with this pump alignment for two conditions - no failures and MDAFP runout protection failure, which is a failure of one of the AF21 valves to the full open position. The actual maximum pressure in a particular SG supply line would occur for a failure of an AF21 valve to the full closed position, which maximizes pressure in the SG supply line that remains aligned to the associated MDAFP. This condition was not analyzed in Reference 3 as the parameter of concern was maximum total SG flow. As such, additional cases were run with 11AF21 closed, to maximize pressure in the 12 SG supply piping (Case A), and with 13AF21 closed, to maximize pressure in the 14 SG supply piping (Case B). For conservatism and simplicity, it was assumed that the remaining AF21 valves are full open. In reality they would be throttled to maintain MDAFP discharge pressure; however, determining their position is an iterative and cumbersome process. Case 4 from Reference 3 Proto-Flo database S-C-AF-MDC-0445-R3.DBD was modified accordingly.

The pressure in the underground piping is assumed to be that from the nearest upstream node in the model, which are the tie-ins between the MDAFP and TDAFP discharges in the Auxiliary Building. The resulting pressures at these nodes are 1259 psia (1244 psig) for 12 SG supply (Case A) and 1270 psia (1255 psig) for 14 SG supply (Case B). The Proto-Flo output reports are included as Attachments 1 and 2, respectively.

During normal plant cooldown and startup, it is unlikely all three AFW pumps would be running. Furthermore, the AF21s and/or AF 11s are manually throttled to control cooldown rate and/or maintain SG level, which reduces the downstream pressure and thus the pressure in the buried piping. Therefore, this condition is bounded by the SLB transient condition with respect to pressure in the buried piping.

Auxiliary Feedwater System Testing:

MDAFP and TDAFP full flow testing to the SGs is performed per References 7 & 8 during each Refueling Outage. The highest pump discharge pressure occurs for the TDAFP test. The TDAFP discharge pressure was originally base lined at 1250 psig in 1998 (WO #960829007). Since then the TDAFP discharge pressure has varied been between 1235 and 1248 psig. These pressures are bounded by the limiting SLB Case from above (Case B, 13AF21 fails closed). Furthermore, similar to normal plant cooldown and startup, the AF21s and AF11 s are manually throttled during testing to set the required flow, and so the pressure in the buried piping to 12 and 14 SGs would be even less. Therefore, full flow testing is bounded by the SLB transient condition. During quarterly surveillance testing (References 4-6), the AF21s and AF11s are closed, with flow going through the respective pump recirculation line, and thus is not applicable to this evaluation.

Main Feedwater Operation:

SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 29 of 68

Operation Key Info 0 n 08/18/2010 AV During normal plant operation, the MFW System provides flow to the SGs, and the AFW System is isolated from the SGs. During this condition, there is a potential for back leakage through the AF23 stop check valves, which are located just upstream of the AFW tie-ins to the MFW System. A leak check of these valves is performed quarterly per Reference 9. Trending of past test results finds no indication of significant leakage past these check valves. Test results found AFW line pressures typically around 25-30 psig with a MFW pressure of around 835-845 psig. A couple exceptions were for the test on 8/30/09, where the 12AF23 upstream pressure was 150 psig, and for the test on 3/1/10, where the 11AF23 and 12AF23 upstream pressures were about 115 psig. If these couple results were an indication of actual leakage, the AFW line pressure was still significantly below the MFW line pressure.

Thus, even if the MFW System flow was low, with corresponding higher system pressure, the resulting AFW line pressure with any leakage past 12AF23 would still be very low compared to that with the AFW System in service.

Special LONE Scenario Another plant transient scenario that potentially could challenge the above case is a LONE to one SG. In this condition the level in that SG would drop rapidly. The possibility that operators could initially align the associated motor-driven pump and the turbine-driven pump to this one SG to regain level as quick as possible is considered, which would result in a higher pressure in the buried piping than that determined for a SLB inside containment with a single failure of an AF21 valve to the closed position.

A LONE event would result in a reactor trip on low-low level in at least one SG. The motor-driven pumps automatically start on low-low level in any one SG and the turbine-driven pump automatically starts on low-low level in any two SGs. Initially the control valves are in automatic. In this mode, the AF11s are full open, and the AF21s throttle as a function of motor-driven pump discharge pressure.

The operators enter Emergency Operating Procedure 1-EOP-TRIP-1 (Reference 11) upon a reactor trip. Step 5 of 1-EOP-TRIP-1 sends the operator into 1-EOP-TRIP-2 (Reference 12) by noting that Safety Injection is not actuated and is not required.

Upon entering 1-EOP-TRIP-2, the operators ensure or establish at least 22E4 Ibm/hr total AFW flow (approximately 440 gpm) by placing the control valves in manual, and adjusting position as necessary. The turbine-driven pump speed is then lowered until either the total flow drops to 22E4 Ibm/hr or the minimum speed is reached. The operators maintain AFW flow until at least one SG level is greater than 9%, then maintain the level between 9% and 33%.

SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 30 of 68

Operation Key Info 08/18/2010 MIR .1W Per Operations, AFW flow is adjusted by simultaneously adjusting the positions of all the control valves from the Control Console. The immediate concern is to have at least one SG in the required level range, and not necessarily the one that experienced a LONF. At some point, pending the need for other priority actions, level will be attempted to be restored in any remaining SGs not within the required range. Also note that establishment of SG level is done after the turbine-driven pump speed is lowered. Therefore, the postulated LONE scenario is not credible, and the SLB inside containment with a single failure of an AF21 valve to the closed position remains the bounding condition.

CONCLUSIONS/FINDINGS:

The maximum potential pressure in the buried AFW piping during an accident is 1259 psia (1244 psig) for 12 SG supply and 1270 psia (1255 psig) for 14 SG supply.

This occurs for a SLB Inside Containment transient with a single failure of an AF21 valve to the closed position, at the maximum potential SG pressure. For conservatism, the maximum operating line pressure in the buried AFW piping is set at 1275 psi.

REFERENCES:

1. P&ID 205236, Revision 54, Unit 1 Auxiliary Feedwater

2. P&ID 205203, Sheet 1, Revision 77, Unit 1 Main, Reheat & Turbine By-Pass Steam

3. S-C-AF-MDC-0445, Revision 3, Auxiliary Feedwater System Hydraulic Analysis

4. S1.OP-ST.AF-0001, Revision 15, Inservice Testing - 11 Auxiliary Feedwater Pump

5. S1.OP-ST.AF-0002, Revision 16, Inservice Testing - 12 Auxiliary Feedwater Pump

6. S1 .OP-ST.AF-0003, Revision 38, Inservice Testing - 13 Auxiliary Feedwater Pump

7. S1 .OP-ST.AF-0005, Revision 11, Inservice Testing Auxiliary Feedwater Valves Mode 4-6

8. S1 .OP-ST.AF-0007, Revision 19, Inservice Testing Auxiliary Feedwater Valves Mode 3

9. S1.OP-ST.AF-0006, Revision 10, Inservice Testing Auxiliary Feedwater Valves

10. UFSAR Section 10.4.7.2, Auxiliary Feedwater System; Section 15, Accident Analysis

11. 1-EOP-TRIP-1 F, Revision 26, Reactor Trip or Safety Injection

12. 1-EOP-TRIP-2 F, Revision 24, Reactor Trip Response SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 31 of 68

Operation Key Info AW0n 08/18/2010 VIR A /

13. UFSAR Section 15.2.8, Loss of Normal Feedwater ATTACHMENTS

1. Case A Proto-Flo Ouput Reports: SLB Inside Containment with 1 1AF21 Failing Close

2. Case B Proto-Flo Ouput Reports: SLB Inside Containment with 13AF21 Failing Close NOTE: The complete Technical Evaluation, including attachments, has been submitted to Records Management, Document Number 70108698-0100.

CO-PREPARER: Kevin King Date: See SAP INDEPENDENT REVIEWER: Michael Crawford Date: See SAP APPROVED: Phil Hennessy Date: See SAP Signature: MICHAEL E CRAWFORD Confirmation Text:

Mgr Approved Signature: PHILIP J HENNESSY Description of Work:

Revised TE - max AFW pressure

- - - - Long Text Object Identification**************

Order 000060060785 Operation 0100 Long text Perform Tech Eval <insert short description>

SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 32 of 68

Operation Key Info 08/18/2010 U

NOTE: Revise short text to include a short, abbreviated, up to 35 character, title of the Technical Evaluation. For example:

"TE - Pipe Integrity w/ 1039A Valve Open" This note may be erased from the operation text.

Prepare a technical evaluation using the guidelines and template in CC-AA-309-101, Technical Evaluations Template, as follows:

Document Number: (The SAP order and operation number)

Title:

(The brief subject / title description assigned by the preparer)

Reason for Evaluation / Scope:

Detailed Evaluation:

Conclusions / Findings:

References:

Preparer (Name & Date):

Independent /Peer Reviewer (Name & Date):

Approved (Name & Date):

SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 33 of 68

Operation Key Info 08/18/2010 n ~

U F~W Order: 70108698 (88) 11R20 AF Buried Pipe Insp Results Operation: 0110 Prep/Rev/Appr Tech Eval Past Operability Work center: S-EDM02 NNUC Status: TECO CNF MANC NMAT PPRT Number of People: 0 Scheduled Dates: Start: 04/26/2010 Finish: 04/27/2010 Planned Hours: 0.0 Actual Dates: Start: 04/26/2010 Finish:04/27/2010 Actual Hours: 0.000 Personnel Number:

Completion Confirmation Number: 8204263 Confirmation Text:

Co-prepared Tech Eval for Ul Past Operab Co-prepared Tech Eval for Ul Past Operability of Buried AFW Pipe Signature: Ml CHAEL E CRAWFORD Confirmation Text:

Co-preparer signoff complete Signature: ROBERT E DOWN Confirmation Text:

Uploaded TE Uploaded TE Unit 1 AFW Past operability evaluation

- - - - Long Text Object Identification**************

Order 000070108698 Operation 0110 SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 34 of 68

Operation Key Info 08/18/2010 AW0n VIM Ar Reference Documents:

Technical Specifications Section(s):

T/S 3/4.7 Plant Systems, LCO 3.7.1.2, Auxiliary Feedwater System UFSAR Section(s):

10.4.7.2, Auxiliary Feedwater System 15.2.8, Loss of Normal Feedwater 15.2.9, Loss of Offsite Power to Station Auxiliaries (LOP) 15.3.1, Loss of Reactor Coolant from Small Ruptured Pipes (SBLOCA) 15.4.1, Major Reactor Coolant System Pipe Ruptures (LBLOCA) 15.4.2, Major Secondary System Pipe Rupture (MSLB) 15.4.3, Major Rupture of Main Feedwater Line (FWLB) 15.4.4, Steam Generator Tube Rupture (SGTR)

Other:

Technical Evaluation 70108698, Rev. 0 ANSI B31.1, 1967 Ed., Power Piping S-C-MPOO-MGS-0001, SPS54, Rev. 6, Piping Schedule, Auxiliary Feedwater S-C-AF-MDC-0445, Rev. 3, Auxiliary Feedwater System Hydraulic Analysis S-C-A900-MDC-005, Rev. 0, Pipe Wall Thickness Calculations SC.DE-BD.AF-0001(Q), Rev. 0, Auxiliary Feedwater System

[Structural Integrity Associates Calculation, "ASME Code,Section III, Desigi n by Analysis Evaluation of a 4-inch Auxiliary Feedwater Piping" (draft provided under S-TODI-2010-0005)

SCI-94-877 LTR dated 12/16/1994 - Excavated Auxiliary feedwater Piping Walkdown/Disposition of Coating Requirements MPR Associates to Mr. Mohammad Ahmed, "Review of Degraded AFW Pip ing Past-Operability Evaluation", dated 24 April 2010.

PREPARER: Michael Crawford Date: See SAP Robert Down Date: See SAP INDEPENDENT REVIEWER: Gary Luh Date:

See SAP APPROVED: Lane Oberembt Date: See SAP SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 41 of 68

.Operation Key Info n A 08/18/2010 MW1rV* /

70108698 0110 Unit 1 AFW Past Operability Evaluation - Engineering

Title:

Salem Ul Past Operability Buried AFW Pipe - Past Operability Determination Reason for Evaluation / Scope:

As part of planned buried pipe inspections during the Salem Unit 1 refueling outage S1R20, guided wave inspection of the buried 4 inch Auxiliary Feedwater (AFW) piping that supplies the #12 and #14 steam generators identified localized wall thinning in several regions where more detailed examination was necessary. These piping regions were excavated and revealed significant external corrosion on the AFW buried piping. Straight beam ultrasonic measurements were then taken to determine the pipe wall thickness profile. The corrosion exceeded the design minimum wall criteria. This finally lead to excavating all the AFW buried pipe, which exposed general exterior corrosion and wall thinning affecting all of the buried AFW piping.

This evaluation reviews the impact in terms of past operability of the discovery of the non-conforming Salem Unit 1 AFW buried piping that was below design minimum wall thickness.

Background Information The buried AFW pipes that connect to the #12 and #14 main feedwater lines in the outer penetration area (OPA) travel approximately 30 feet underground along the edge of the containment building before entering the OPA at elevations 94' 8" (#12) and 96' 2" (#14).

The piping is 4-inch NPS, Schedule 80, A106 Gr B seamless carbon steel. It is classified as Nuclear 3, Seismic Category I. Per the Pipe Specification S-C-MPOO-MGS-0001, SPS 54E, the system design Pressure-Temperature limit is 1950 psi at 140 F. The nominal wall thickness is 0.337 inches +/- 12.5%.

Guided Wave inspections of the Salem Unit 1 AFW buried piping revealed regions of degraded pipe wall thinning. Follow-up excavations unearthed more piping showing heavy external uniform corrosion. The apparent cause of the corrosion was the improper application (or lack) of the specified pipe coatings, X-Tru-Coat, an adhered polyethylene protection system, and Bitumastic, which was specified per drawings and pipe specifications to be applied at the welded joints.

Careful visual inspections of the excavated piping revealed a lack of coating. The only remnant of coating found was a portion of coal tar which was approximately 9 inches in length and 7 inches in circumference. This piece of coating was in the shape of the 4 inch AFW piping and conformed to that same profile.

SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 35 of 68

Operation Key Info 08/18/2010 MIR U Aw r w'AM Using the Guided Wave inspection results to target three specific areas (limiting measurements 12AF, 0.152 inch; 14AF, 0.160 inch; and 14AK, 0.166 inch wall) of buried AFW piping for excavation and examination, NDE Services initially performed confirmatory UT measurements on 378 grid areas. Approximately 76 percent of these UT measurements were non-conforming, having a minimum wall thickness less than the design minimum wall thickness of 0.278 inches. Based on these initial findings, the entire accessible portions of AFW buried pipe in Salem Unit 1 were excavated. A second set of UT measurements was then taken on a 1-inch by 1-inch grid for the full circumference of the pipe along the entire length of exposed AFW buried pipe (limiting measurement AF13T, 0.141 inch wall). The following numbers of UT readings were taken:

14 AFW Line (Upper Pipe): 8,904 readings total. 1,194 are below 0.278"

12 AFW Line (Lower Pipe): 8,852 readings total. 192 readings are below 0.278" Finally a third sample set of UT measurements was taken of the bottoms of AFW buried pipe that rest on the construction aid supports (hangers),

from which the overall worst case derived (14AF4T/14AF5T, 0.077 inch wall).

In summary, the worst case UT measurements, those having the least minimum wall thickness, were as follows:

For the #12 AFW buried piping, a 55 percent loss (0.152 inches).

For the #14 AFW buried piping, an approximately 78 percent loss (0.077 inches).

Removal of sections of the buried AFW piping in Salem Unit 1 during the $1R20 outage and subsequent visual examinations have validated that the identified corrosion is external.

Further examinations have also revealed evidence of the X-Tru-Coat on the through-wall portions of the buried AFW piping where it passes into the fuel transfer tube area (FTTA).

The coating system was not found on the remaining buried portions of these lines, which validates that the observed heavy general corrosion is due to a lack of coating.

The ground fill of the AFW piping is not a harsh environment (harsh with regard to coating), and there does not appear to be a correlation between the missing or deteriorated coating and the buried pipe environment.

Past Operability Evaluation SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 36 of 68

Operation Key Info n 08/18/2010 As part of the planned inspections of buried pipe, the Buried Pipe Program requested that the #12 and #14 Auxiliary Feedwater (AFW) buried piping be inspected during the Salem Unit 1 refueling outage 1R20. The buried AFW piping runs underground from the Mechanical Penetration to the Outer Penetration Area, passing alongside the west end of the Containment from north to south. [Dwg.

207483] The buried portions of AFW pipe are downstream of the AFW SG Level Control valves 12AF21 through 14AF21 for the motor-driven AFW pumps (MDAFPs) and the AFW SG Level Control valves 12AF1 1 through 14AF1 1 for the turbine-driven AFW pump (TDAFP) and are upstream of the 12AF23 through 14AF23 AFW SG Inlet Stop Check valves. [Drawing. 205236]

The minimum wall thickness (tmin) for the buried AFW pipe is governed by the ANSI B31.1, 1967 Edition, Power Piping code, Equation 104.1:

tmin = PD / 2(SE+PY)

19504.5 / 2(15000+19500.4) = 0.278 inches Where pipe outside diameter (D) = 4.5 inches, design Pressure (P)

1950 psi, and SE is the material allowable of 15000 psi for seamless pipe, and Y -

0.4 per the ANSI B31.1.

Because the buried AFW pipe is continuously supported, the deadweight and seismic loads are consildered minimal. Therefore, the minimum wall thickness determined by using the design pressure is too restrictive with respect to determining operability. Instead, the Maximum Credible Operating Pressure (MCOP) was developed based on all AFW system operating conditions, and was used to evaluate tmin for the buried AFW pipe. Technical Evaluation 70108698-0100 determined that all AFW conditions that the MCOP for the buried Auxiliary Feedwater piping is conservatively bounded by 1275 psi. The corresponding minimum wall thickness based on a MCOP pressure of 1275 psi is 0.185 inches.

1275*4.5 / 2(15000 + 1275*0.4) = 0.185 inches using MCOP The 0.185 inch minimum wall thickness was originally increased 12 mils to provide an allowance for an additional cycle of operation based on an assumed maximum corrosion rate of 8 mils per year. [Ref. NUCR 70103767] The intent was to replace any section of buried pipe that had a minimum wall less than 0.198 inches. In addition, all of the AFW buried piping, remnant and replacement, was to be re-coated before being buried again. However, as more UT measurements came in, it became clear that all of the buried AFW pipe should be replaced. DCP 80101382 was written to replace the inaccessible sections of AFW buried piping near and below the Fuel Transfer Tube and ECP 80101381 was written to replace the accessible portions of the AFW buried piping. Thus, all the AFW buried piping was replaced.

SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 37 of 68

Operation Key Info 08/18/2010 n

MIR, AV Additional UT measurements were taken from the bottom of the AFW buried pipe where it rested on carbon steel construction aides (hangers). These areas were added due to the inability of the Guided Wave technology to distinguish the boundary between the pipe and hanger metal and were thus suspect. During the inspection and UT measurements of these areas, the greatest pipe wall loss was discovered on the #14 AFW discharge line. A localized area having a minimum wall thickness measurement of 77 mils, the flaw was 0.25 inches in diameter and 0.75 inches in length before the surrounding pipe material increased to greater than 150 mils.

Upon discovery of these limited extreme localized areas of loss, Engineering requested Structural Integrity Associates, Inc. (SIA) to perform a rigorous Finite Element Analysis (FEA) of the AFW buried pipe using the most limiting cases (12AF, 14AF, 14AK, AF13T, and AF4T.AF5T) from the complete set of UT measurements. The SIA report, "ASME Code,Section III Design Analysis Evaluation of 4-inch Auxiliary Feedwater Piping," details the results of the FEA. The technical approach used was to assume that although piping may have localized thinned regions that violate the design tmin requirements, the non-uniform wall thickness of the pipe cross-section may still be shown to meet the design stress allowable. The approach is similar to the basis for qualifying pipe penetrations using branch reinforcement rules in the ASME Code and is possible for pipe sections exhibiting thinning when a remaining wall greater than tmin surrounds the thinning region. Note that the FEA did not use the Piping Specification SPS 54E design pressure for the piping but instead used the MCOP from Technical Evaluation 70108698-0100. An additional 35 psi was conservatively added to the MCOP at Design Engineering's request to provide operating margin.

The buried AFW pipe at Salem Unit 1 was designed to the tmin requirement given in the B31.1 Power Piping Code that does not provide specific criteria for evaluation of non-uniform wall thickness or thinning. However, guidance for stress analysis may be derived from the ASME Code,Section III, which can be used to supplement the B31.1 requirements.

Design requirements for Class 3 piping are provided in ND-3600 of the ASME Code,Section III, Division 1, 2004 Ed. Alternate methods are allowed under Section ND-3611.3, which permits use of a more rigorous piping design analysis such as NB-3200 to calculate stresses required to satisfy ND-3600 requirements. The calculated stresses must be compared to the allowable stresses in ND-3600. Thus to show acceptance of the degraded piping having a non-uniform pipe wall, the design loadings are determined using the design analysis methods in NB-3200. A finite element model is implemented incorporating the irregular pipe section profile defined by the UT thickness measurements. Current ASME Code allowable stresses are based on a factor of 3.5 on tensile strength instead of the factor of 4 as used in Salem's B31.1 Code of Construction.

Summary of Structural Integrity Associates (SIA) Finite Element Analysis Report Per the ASME Code:

SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 38 of 68

Operation Key Info A 08/18/2010 MIR MW "The specific design requirements of ND-3600 are based on a simplified engineering approach. A more rigorous analysis such as described in NB-3600 or NB-3200 may be used to calculate the stresses required to satisfy these requirements. These calculated stresses must be compared to the allowable stresses in this Subsection. In such cases, the designer shall include the appropriate justification for the approach taken in the Certified Design Report."

Thus, NB-3200 design by analysis is employed. Based on the linear-elastic finite element analysis results which showed that the thinned section of pipe (0.077 inch) was bounding, it was required to perform additional analysis only for that section of pipe in order to show operability. The more rigorous analysis employed is described in Section NB3228.1, Limit Analysis. Specifically Section NB-3228.1 states that limits on Local Membrane Stress Intensity need not be satisfied at a specific location if it can be shown by limit analysis that the specified loadings do not exceed two-thirds of the lower bound collapse load. Also, NB-3228.1 states that the yield strength to be used in this calculation is 1.5 Sm. In this evaluation, the value of yield strength is equal to 1.5 S, where S is taken as the value of Sh, 15.0 ksi, from the original 1967 B31.1 Power Piping Code. Thus, a yield strength of 22.5 ksi is used.

The thinned section of pipe is modeled using the as-found wall thickness values for the region specified in S-TODI-2010-0005 which includes a minimum wall thickness of 0.077 inches. A pressure load of 1.5 times the PSEG specified operating pressure is applied (1943 psi = 1.5*[1310psia-14.7psi]) to the pipe per the more rigorous methodology to ensure that the operating pressure remains less than two-thirds of the failure pressure (1943

0.667 = 1295 psi).

The results of the finite element analysis show that the thinned pipe in this section remains structurally stable at 1.5 times the PSEG specified operating pressure and therefore passes the limit load analysis.

MPR's independent Review of SIA's Finite Element Analysis Report MPR Associates was contracted to perform an independent, third party review of SIA's Finite Element Analysis that was performed to address external wall thinning of buried Auxiliary Feedwater (AF) piping at Salem Unit 1. The SIA calculation concludes that the degraded piping was operable prior to replacement during the current refueling outage. MPR's review focused on the approach, bases for assumptions and design inputs, and conclusions of the SIA calculation. MPR found the approach and conclusions of the subject calculation to be reasonable, and concur with the calculation conclusion that the degraded AF piping was operable prior to its recent replacement.

Extent of Condition SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 39 of 68

Operation Key Info A 0

08/18/2010 VIM, AV Because the Salem Unit 1 AFW discharge piping to the #11 and #13 steam generators runs from Containment to the Mechanical Penetration to the Pipe Alley to the Auxiliary Building, it is neither buried nor subject to the same corrosive environment as the AFW discharge lines to the #12 and #14 Steam Generators. The Buried Pipe Program inspection examined the Control Air (CA) and Station Air (SA) piping buried with the AFW pipe. A small pinhole leak was found in the CA pipe and was repaired to original condition. The overall condition of the CA and SA pipe was found with the protective coating intact and not degraded in the fashion as seen by the AFW pipe.

In operating Modes 5, 6, and Defueled, AFWS has no required safety function. The decay heat removal safety function is provided by the Residual Heat Removal (RHR) system. The AFWS does provide a means for refilling the secondary side of the SGs after eddy current testing and removal of the SG nozzle dams is complete. The secondary side water provides an additional heat sink in case of a loss of RHR cooling. In Mode 4 when RCS temperature is greater than 212'F but less than 3500 F, the SGs can provide for decay heat removal if shutdown cooling is lost. Finally, in Modes 1 through 3, Technical Specification 3/4.7 Plant Systems, LCO 3.7.1.2, Auxiliary Feedwater System, requires at least three independent Auxiliary Feedwater pumps and their flow paths be operable to ensure that the RCS can be cooled down to a hot leg temperature less than 350'F in the event of a loss of offsite power (LOOP). This permits entry into the shutdown cooling mode of operation for the RHR system if RCS pressure is less than 340 psig.

Conclusions / Findings:

Despite being found in a degraded condition, the AFWS has always performed its safety and design functions in the past. No evidence has been found of a through wall flaw in the piping surveyed. The piping has maintained structural integrity during normal operation. The limiting design basis accident, the steam line break (SLB) inside containment event from which the MCOP pressure is derived, has yet to occur. The results of the SIA FEA support the conclusion that the generalized corrosion observed has not yet degraded the pipe wall below a minimum thickness that would make it inoperable or subject to failure. The system is degraded but operable. Per the SIA analysis, the existing AFWS #12 and #14 buried pipe is capable of operating for one more cycle if re-coated properly to ensure a minimal, near zero corrosion rate. MPR's independent Review of SIA's Finite Element Analysis Report on past-operability found the approach and conclusions of the subject calculation to be reasonable, and concurred with the calculation conclusion that the degraded AF piping was operable prior to its recent replacement.

Based on the above information it is concluded that there are no past operability concerns associated with Salem Unit 1 AFW piping found below minimum wall. This past operability evaluation shows that the operability concerns associated with Salem Unit 1 AFW piping found below minimum wall are unfounded. Therefore, there is no past operability concerns associated with the Salem Unit 1 AFW piping found below minimum wall. This evaluation was reviewed with Operations and Safety and they concur with the conclusions.

SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 40 of 68

Operation Key Info MP 08/18/2010 4J Signature: GARY G LUH Confirmation Text:

Independent Reviewed, SAT Signature: GARY G LUH Confirmation Text:

OBEREMBT - See long text:

NSSS Branch Manager review completed. nulto x-1471 Signature: LANE T OBEREMBT Description of Work:

Prep/Rev/Appr Tech Eval Past Operability AFW Buried Pipe

- - - - Long Text Object Identification**************

Order 000070108698 Operation 0110 Long text Unit 1 AFW Past operability evaluation

- - - - Long Text Object Identification**************

Order 000070108698 Operation 0110 70108698 0110 Unit 1 AFW Past Operability Evaluation - Engineering

Title:

Salem Ul Past Operability Buried AFW Pipe - Past Operability Determination Reason for Evaluation / Scope:

SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 42 of 68

Operation Key Info 08/18/2010 MWA

-o 15.2.9, Loss of Offsite Power to Station Auxiliaries (LOP) 15.3.1, Loss of Reactor Coolant from Small Ruptured Pipes (SBLOCA) 15.4.1, Major Reactor Coolant System Pipe Ruptures (LBLOCA) 15.4.2, Major Secondary System Pipe Rupture (MSLB) 15.4.3, Major Rupture of Main Feedwater Line (FWLB) 15.4.4, Steam Generator Tube Rupture (SGTR)

Other:

Technical Evaluation 70108698, Rev. 0 ANSI B31.1, 1967 Ed., Power Piping S-C-MPOO-MGS-0001, SPS54, Rev. 6, Piping Schedule, Auxiliary Feedwater S-C-AF-MDC-0445, Rev. 3, Auxiliary Feedwater System Hydraulic Analysis S-C-A900-MDC-005, Rev. 0, Pipe Wall Thickness Calculations SC.DE-BD.AF-O001(Q), Rev. 0, Auxiliary Feedwater System

[Structural Integrity Associates Calculation, "ASME Code,Section III, Design by Analysis Evaluation of a 4-inch Auxiliary Feedwater Piping" (draft provided under S-TODI-2010-0005)

SCI-94-877 LTR dated 12/16/1994 - Excavated Auxiliary feedwater Piping Walkdown/Disposition of Coating Requirements MPR Associates to Mr. Mohammad Ahmed, "Review of Degraded AFW Piping Past-Operability Evaluation", dated 24 April 2010.

PREPARER: Michael Crawford Date: See SAP Robert Down Date: See SAP INDEPENDENT REVIEWER: Gary Luh Date:

See SAP APPROVED: Lane Oberembt Date: See SAP SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 49 of 68

Operation Key Info 08/18/2010

'io Order: 70108698 (88) 11R20 AF Buried Pipe Insp Results Operation: 0120 Perform Tech Eval Revised Ul AFW Past Op Work center: S-EDM03 NNUC Status: TECO CNF MANC NMAT PPRT Number of People: 0 Scheduled Dates: Start: 04/3C)/2010 Finish: 04/30/2010 Planned Hours: 0.0 Actual Dates: Start: 04/29/ 2010 Finish:04/30/2010 Actual Hours: ).000 Personnel Number:

Completion Confirmation Number: 8218369 Confirmation Text:

Prepared Revised TE for Ul AFW Past Oper Prepared Revised TE for Ul AFW Past Operability This revised TE supersedes previous TEs under Operations 0050 and 0110.

Signature: MICHAEL E CRAWFORD Confirmation Text:

Uploaded Revised TE Uploaded Revised TE Unit 1 AFW Past Operability Evaluation

- - - - Long Text Object Identification**************

Order 000070108698 Operation 0120 70108698 0120 Unit 1 AFW Past Operability Evaluation - Engineering SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 50 of 68

Operation Key Info n A 08/18/2010

Title:

Salem Ul Past Operability Buried AFW Pipe - Past Operability Determination Reason for Evaluation / Scope:

As part of planned buried pipe inspections during the Salem Unit 1 refueling outage S1R20, guided wave inspection of the buried 4 inch Auxiliary Feedwater (AFW) piping that supplies the #12 and #14 steam generators identified localized wall thinning in several regions where more detailed examination was necessary. These piping regions were excavated and revealed significant external corrosion of the AFW buried piping. Straight beam ultrasonic measurements were then taken to determine the pipe wall thickness profile. The corrosion exceeded the design minimum wall criteria. This finally lead to excavating all of the accessible AFW buried pipe, which exposed general exterior corrosion and wall thinning affecting to a variable degree all of the exposed buried AFW piping. Only the portion of buried pipe that runs beneath the Fuel Transfer Tube to the Mechanical Penetration was not excavated.

This evaluation reviews the impact in terms of past operability of the non-conforming Salem Unit 1 AFW buried piping that was discovered to be below design minimum wall thickness.

Background Information The buried AFW pipes connect the discharges of the AFW pumps in the Auxiliary Building to the #12 and #14 main feedwater lines in the outer penetration area (OPA). The two lines travel a total of approximately 170 feet underground. They exit underground from the Mechanical Penetration at the 82' 11"

(#12) and 83' 11" (#14) elevations and run horizontally under the Fuel Transfer Tube.

Skirting the containment wall, they rise to the 94' 6" (#12) and 96' 0" (#14) elevations before passing through the Fuel Handling Building stub wall. They then continue horizontally, still underground at that depth along the edge of the containment building and then turning before entering the OPA to connect to the #12 and #14 SG feedwater lines.

The piping is 4-inch NPS, Schedule 80, A106 Gr B seamless carbon steel. It is classified as Nuclear 3, Seismic Category I. Per the Pipe Specification S-C-MPOO-MGS-0001, SPS 54E, the system design Pressure-Temperature limit is 1950 psi at 140 F. The nominal wall thickness is 0.337 inches +/- 12.5%.

SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 51 of 68

Operation Key Info n 08/18/2010 MIR AV Guided Wave inspections of the Salem Unit 1 AFW buried piping revealed regions of degraded pipe wall thinning. Follow-up excavations unearthed more piping showing heavy external uniform corrosion. The apparent cause of the corrosion was the improper application (or lack) of the specified pipe coatings, X-Tru-Coat, an adhered polyethylene protection system, and Bitumastic, which was specified per drawings and pipe specifications to be applied at the welded joints.

Careful visual inspections of the excavated piping revealed a lack of coating. The only remnant of coating found was a portion of coal tar which was approximately 9 inches in length and 7 inches in circumference. This piece of coating was in the shape of the 4 inch AFW piping and conformed to that same profile.

Using the Guided Wave inspection results to target three specific areas (limiting measurements 12AF, 0.152 inch; 14AF, 0.160 inch; and 14AK, 0.166 inch wall) of buried AFW piping for excavation and examination, NDE Services initially performed confirmatory UT measurements on 378 grid areas. Approximately 76 percent of these UT measurements were non-conforming, having a minimum wall thickness less than the design minimum wall thickness of 0.278 inches. Based on these initial findings, the entire accessible portions of AFW buried pipe in Salem Unit 1 were excavated. A second set of UT measurements was then taken on a 1-inch by 1-inch grid for the full circumference of the pipe along the entire length of exposed AFW buried pipe (limiting measurement AF13T, 0.141 inch wall). The following numbers of UT readings were taken:

14 AFW Line (Upper Pipe): 8,904 readings total. 1,194 are below 0.278"

12 AFW Line (Lower Pipe): 8,852 readings total. 192 readings are below 0.278" The upper AFW buried pipe, which serves the #14 SG, was observed to be more corroded than the lower AFW pipe, which serves the #12 SG and which was buried 1 to 1-1/2 feet deeper. In fact, there were more than 6 times as many below minimum wall UT readings on the upper (#14) than on the lower (#12) AFW buried pipe.

Finally a third sample set of UT measurements was taken of the bottoms of AFW buried pipe that rest on the construction aid supports (hangers),

from which the overall worst case derived (14AF4T/14AF5T, 0.077 inch wall).

In summary, the worst case UT measurements, those having the least minimum wall thickness, were as follows:

For the #12 AFW buried piping, a 55 percent loss (0.152 inches).

For the #14 AFW buried piping, an approximately 78 percent loss (0.077 inches).

Removal of sections of the buried AFW piping in Salem Unit 1 during the $1R20 outage and subsequent visual examinations have validated that the identified corrosion is external.

SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 52 of 68

Operation Key Info A n 08/18/2010 MP, 11W Further examinations have also revealed evidence of the X-Tru-Coat on the through-wall portions of the buried AFW piping where it passes into the fuel transfer tube area (FTTA).

The coating system was not found on the remaining buried portions of these lines, which validates that the observed heavy general corrosion is due to a lack of coating.

The ground fill of the AFW piping is not a harsh environment (harsh with regard to coating), and there does not appear to be a correlation between the missing or deteriorated coating and the buried pipe environment.

Past Operability Evaluation As part of the planned inspections of buried pipe, the Buried Pipe Program requested that the #12 and #14 Auxiliary Feedwater (AFW) buried piping be inspected during the Salem Unit 1 refueling outage 1R20. The buried AFW piping runs underground from the Mechanical Penetration to the Outer Penetration Area, passing alongside the west end of the Containment from north to south. [Dwg.

207483] The buried portions of AFW pipe are downstream of the AFW SG Level Control valves 12AF21 through 14AF21 for the motor-driven AFW pumps (MDAFPs) and the AFW SG Level Control valves 12AF11 through 14AF11 for the turbine-driven AFW pump (TDAFP) and are upstream of the 12AF23 through 14AF23 AFW SG Inlet Stop Check valves. [Drawing. 2052361 The minimum wall thickness (tmin) for the buried AFW pipe is governed by the ANSI B31.1, 1967 Edition, Power Piping code, Equation 104.1:

tmin = PD / 2(SE+PY)

- 1950*4.5 / 2(15000+1950*0.4) = 0.278 inches Where pipe outside diameter (D) = 4.5 inches, design Pressure (P) -

1950 psi, and SE is the material allowable of 15000 psi for seamless pipe, and Y -

0.4 per the ANSI B31.1.

Because the buried AFW pipe is continuously supported, the deadweight and seismic loads are considered minimal. Therefore, the minimum wall thickness determined by using the design pressure is too restrictive with respect to determining operability. Instead, the Maximum Credible Operating Pressure (MCOP) was developed based on all AFW system operating conditions, and was used to evaluate tmin for the buried AFW pipe. Technical Evaluation 70108698-0100 determined that all AFW conditions that the MCOP for the buried Auxiliary Feedwater piping is conservatively bounded by 1275 psi. The corresponding minimum wall thickness based on a MCOP pressure of 1275 psi is 0.185 inches.

1275*4.5 / 2(15000 + 1275*0.4) = 0.185 inches using MCOP SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 53 of 68

Operation Key Info b n f A 08/18/2010 MW 11W The 0.185 inch minimum wall thickness was originally increased 12 mils to provide an allowance for an additional cycle of operation based on an assumed maximum corrosion rate of 6 to 8 mils per year. [Ref. NUCR 701037671 The intent was to replace any section of buried pipe that had a minimum wall less than 0.198 inches. In addition, all of the AFW buried piping, remnant and replacement, was to be re-coated before being buried again. However, as more UT measurements came in, it became clear that all of the buried AFW pipe should be replaced. DCP 80101382 was written to replace the inaccessible sections of AFW buried piping near and below the Fuel Transfer Tube and ECP 80101381 was written to replace the accessible portions of the AFW buried piping. Thus, all the AFW buried piping was replaced.

Additional UT measurements were taken from the bottom of the AFW buried pipe where it rested on carbon steel construction aides (hangers). These areas were added due to the inability of the Guided Wave technology to distinguish the boundary between the pipe and hanger metal and were thus suspect. During the inspection and UT measurements of these areas, the greatest pipe wall loss was discovered on the #14 AFW discharge line. A localized area having a minimum wall thickness measurement of 77 mils, the flaw was 0.25 inches in diameter and 0.75 inches in length before the surrounding pipe material increased to greater than 150 mils.

Upon discovery of these limited extreme localized areas of loss, Engineering requested Structural Integrity Associates, Inc. (SIA) to perform a rigorous Finite Element Analysis (FEA) of the AFW buried pipe using the most limiting cases (12AF, 14AF, 14AK, AF13T, and AF4T.AF5T) from the complete set of UT measurements. Four of the five worst cases of wall thinning were found on the upper buried AFW pipe that serves the #14 SG, which was found to be more corroded and have greater wall loss than the lower buried AFW pipe that serves the

12 SG. The SIA report, "ASME Code,Section III Design Analysis Evaluation of 4-inch Auxiliary Feedwater Piping," details the results of the FEA. The technical approach used was to assume that although piping may have localized thinned regions that violate the design t requirements, the non-uniform wall thickness of the pipe cross-section may still be shown to meet the design stress allowable. The approach is similar to the basis for qualifying pipe penetrations using branch reinforcement rules in the ASME Code and is possible for pipe sections exhibiting thinning when a remaining wall greater than tmin surrounds the thinning region. Note that the FEA did not use the Piping Specification SPS 54E design pressure for the piping but instead used the MCOP from Technical Evaluation 70108698-0100. An additional 35 psi was conservatively added to the MCOP at Design Engineering's request to provide operating margin.

The buried AFW pipe at Salem Unit 1 was designed to the tmin requirement given in the B31.1 Power Piping Code that does not provide specific criteria for evaluation of non-uniform wall thickness or thinning. However, guidance for stress analysis may be derived from the ASME Code,Section III, which can be used to supplement the B31.1 requirements.

SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 54 of 68

Operation Key Info - n A 08/18/2010 MW 11W Design requirements for Class 3 piping are provided in ND-3600 of the ASME Code,Section III, Division 1, 2004 Ed. Alternate methods are allowed under Section ND-3611.3, which permits use of a more rigorous piping design analysis such as NB-3200 to calculate stresses required to satisfy ND-3600 requirements. The calculated stresses must be compared to the allowable stresses in ND-3600. Thus to show acceptance of the degraded piping having a non-uniform pipe wall, the design loadings are determined using the design analysis methods in NB-3200. A finite element model is implemented incorporating the irregular pipe section profile defined by the UT thickness measurements. Current ASME Code allowable stresses are based on a factor of 3.5 on tensile strength instead of the factor of 4 as used in Salem's B31.1 Code of Construction.

Summary of Structural Integrity Associates (SIA) Finite Element Analysis Report Per the ASME Code:

"The specific design requirements of ND-3600 are based on a simplified engineering approach. A more rigorous analysis such as described in NB-3600 or NB-3200 may be used to calculate the stresses required to satisfy these requirements. These calculated stresses must be compared to the allowable stresses in this Subsection. In such cases, the designer shall include the appropriate justification for the approach taken in the Certified Design Report."

Thus, NB-3200 design by analysis is employed. Based on the linear-elastic finite element analysis results which showed that the thinned section of pipe (0.077 inch) was bounding, it was required to perform additional analysis only for that section of pipe in order to show operability. The more rigorous analysis employed is described in Section NB3228.1, Limit Analysis. Specifically Section NB-3228.1 states that limits on Local Membrane Stress Intensity need not be satisfied at a specific location if it can be shown by limit analysis that the specified loadings do not exceed two-thirds of the lower bound collapse load. Also, NB-3228.1 states that the yield strength to be used in this calculation is 1.5 Sm. In this evaluation, the value of yield strength is equal to 1.5 S, where S is taken as the value of Sh, 15.0 ksi, from the original 1967 B31.1 Power Piping Code. Thus, yield strength of 22.5 ksi is used.

The thinned section of pipe is modeled using the as-found wall thickness values for the region specified in S-TODI-2010-0005 which includes a minimum wall thickness of 0.077 inches. A pressure load of 1.5 times the PSEG specified operating pressure is applied (1943 psi = 1.5*[1310psia-14.7psi]) to the pipe per the more rigorous methodology to ensure that the operating pressure remains less than two-thirds of the failure pressure (1943

0.667 = 1295 psi).

The results of the finite element analysis show that the thinned pipe in this section remains structurally stable at 1.5 times the PSEG specified operating pressure and therefore passes the limit load analysis.

MPR's independent Review of SIA's Finite Element Analysis Report SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 55 of 68

Operation Key Info 08/18/2010 A n VW' NV MPR Associates was contracted to perform an independent, third party review of SIA's Finite Element Analysis that was performed to address external wall thinning of buried Auxiliary Feedwater (AF) piping at Salem Unit 1. The SIA calculation concludes that the degraded piping was operable prior to replacement during the current refueling outage. MPR's review focused on the approach, bases for assumptions and design inputs, and conclusions of the SIA calculation. MPR found the approach and conclusions of the subject calculation to be reasonable, and concur with the calculation conclusion that the degraded AF piping was operable prior to its recent replacement.

Extent of Condition Because the Salem Unit 1 AFW discharge piping to the #11 and #13 steam generators runs from Containment to the Mechanical Penetration to the Pipe Alley to the Auxiliary Building, it is neither buried nor subject to the same corrosive environment as the AFW discharge lines to the #12 and #14 Steam Generators. The Buried Pipe Program inspection examined the Control Air (CA) and Station Air (SA) piping buried with the AFW pipe. A small pinhole leak was found in the CA pipe and was repaired to original condition. The overall condition of the CA and SA pipe was found with the protective coating intact and not degraded in the fashion as seen by the AFW pipe.

In operating Modes 5, 6, and Defueled, AFWS has no required safety function. The decay heat removal safety function is provided by the Residual Heat Removal (RHR) system. The AFWS does provide a means for refilling the secondary side of the SGs after eddy current testing and removal of the SG nozzle dams is complete. The secondary side water provides an additional heat sink in case of a loss of RHR cooling. In Mode 4 when RCS temperature is greater than 212'F but less than 350'F, the SGs can provide for decay heat removal if shutdown cooling is lost. Finally, in Modes 1 through 3, Technical Specification 3/4.7 Plant Systems, LCO 3.7.1.2, Auxiliary Feedwater System, requires at least three independent Auxiliary Feedwater pumps and their flow paths be operable to ensure that the RCS can be cooled down to a hot leg temperature less than 350'F in the event of a loss of offsite power (LOOP). This permits entry into the shutdown cooling mode of operation for the RHR system if RCS pressure is less than 340 psig.

Conclusions / Findings:

SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 56 of 68

Operation Key Info n im i 08/18/2010 Despite being found in a degraded condition, the AFWS has always performed its safety and design functions in the past. No evidence has been found of a through-wall flaw in the piping surveyed. The piping has maintained structural integrity during normal operation. The limiting design basis accident, the steam line break (SLB) inside containment event from which the MCOP pressure is derived, has yet to occur. The results of the SIA FEA support the conclusion that the generalized corrosion observed has not yet degraded the pipe wall below a minimum thickness that would make it inoperable or subject to failure. The system is degraded but operable. Per the SIA analysis, the existing AFWS #12 and #14 buried pipe would be capable of operating for one more cycle if re-coated properly to ensure a minimal, near zero corrosion rate. However, PSEG has chosen to replace all the buried piping in Salem Unit 1. MPR's independent Review of SIA's Finite Element Analysis Draft Report on past-operability found the approach and conclusions of the subject calculation to be reasonable, and concurred with the calculation conclusion that the degraded AF piping was operable prior to its recent replacement. (Final Report at VTD 901979)

Based on the UT measurements of remaining wall thickness, it is evident that the buried AFW pipe serving the #14 SG suffered a greater degradation than the buried AFW pipe serving the #12 SG. By simple inspection of the data and noting that there are more than 6 times the instances of below minimum wall UT findings on the upper (#14) pipe to the lower (#12) pipe, it is apparent that the lower the depth of the piping, the less the amount of corrosion. The UT data obtained from the buried AFW pipes below where they were cut and capped to weld on the new above ground AFW piping tend to support this line of reasoning. The UT data taken from the cut and capped stub sections of the buried AFW piping that descend to approximately the 83 foot elevation and pass through the FTTA show less overall corrosion, which was confirmed visually, also. The minimum cases of wall thinning found were 0.220 and 0.237 inches. The average, wall thickness based on the 14 circumferential UT readings for each of these minimum cases was 0.272 and 0.371 inches. The maximum wall thicknesses measured in this section of buried AFW pipe actual exceed nominal wall thickness for 4-inch NPS Schedule 80 pipe.

Two possible reasons for this difference are (1) the concentration of oxygen in the soil and (2) the temperature of the soil. Each factor is greater the closer to the surface the pipe is and each factor increases the corrosion rate. The lowest portions of the buried AFW pipe were those that passed beneath the Fuel Transfer Tube and were buried at an elevation of 84'- 0" (#14) and 83'- 0" (#12) in the FTTA, which were inaccessible for excavation and UT examination. The AFW pipes that were in the accessible areas for excavation and UT measurement were buried at the more shallow elevations of 96'-0" (#14) and 94'-6" (#12). Assuming that the amount of corrosion decreases with depth, then it is likely that the sections of AFW pipe that were buried deeper were in better condition and less corroded than those that were buried approximately 12 feet higher, closer to the surface of the ground. This would assert that the worst cases of corrosion and sections of buried pipe with the greatest wall loss were those UT'd and analyzed by SIA. Hence, the conclusions in the FEA (VTD 901979) apply to the inaccessible buried AFW pipe as well. These sections of the buried AFW pipe were also operable over the past cycle.

SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 57 of 68

Operation Key Info Wn 08/18/2010 MR AV Based on the above information it can be concluded that there are no past operability concerns associated with Salem Unit 1 AFW piping found below minimum wall. The SIA finite element analysis demonstrates that the buried AFW piping in Salem Unit 1 had not degraded to a condition where it would have failed under the most severe operating condition. The AFW piping found being below minimum wall was operable in the past and up to the present as-found condition. Therefore, there is no past operability concerns associated with the Salem Unit 1 AFW piping found below minimum wall. This evaluation was reviewed with Operations and Safety and they concur with the conclusions.

Reference Documents:

Technical Specifications Section(s):

T/S 3/4.7 Plant Systems, LCO 3.7.1.2, Auxiliary Feedwater System UFSAR Section(s):

10.4.7.2, Auxiliary Feedwater System 15.2.8, Loss of Normal Feedwater 15.2.9, Loss of Offsite Power to Station Auxiliaries (LOP) 15.3.1, Loss of Reactor Coolant from Small Ruptured Pipes (SBLOCA) 15.4.1, Major Reactor Coolant System Pipe Ruptures (LBLOCA) 15.4.2, Major Secondary System Pipe Rupture (MSLB) 15.4.3, Major Rupture of Main Feedwater Line (FWLB) 15.4.4, Steam Generator Tube Rupture (SGTR)

Other:

Technical Evaluation 70108698, Rev. 0 ANSI B31.1, 1967 Ed., Power Piping S-C-MPOO-MGS-0001, SPS54, Rev. 6, Piping Schedule, Auxiliary Feedwater S-C-AF-MDC-0445, Rev. 3, Auxiliary Feedwater System Hydraulic Analysis S-C-A900-MDC-005, Rev. 0, Pipe Wall Thickness Calculations SC.DE-BD.AF-0001(Q), Rev. 0, Auxiliary Feedwater System VTD 901979, Structural Integrity Associates, Inc., "ASME Code,Section III, Design by Analysis Evaluation of a 4-inch Auxiliary Feedwater Piping" SCI-94-877 LTR dated 12/16/1994 - Excavated Auxiliary feedwater Piping Walkdown/Disposition of Coating Requirements MPR Associates to Mr. Mohammad Ahmed, "Review of Degraded AFW Piping Past-Operability Evaluation", dated 24 April 2010.

PREPARER: Michael Crawford Date: See SAP INDEPENDENT REVIEWER: Gary Luh Date:

See SAP SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 58 of 68

Operation Key Info 08/18/2010 APPROVED: Steve Davies Date: See SAP Signature: GARY G LUH Confirmation Text:

Independent Reviewed, SAT Signature: GARY G LUH Confirmation Text:

engr suprv revd and apprvd Signature: STEVEN B DAVIES Description of Work:

Perform Tech Eval Revised U1 AFW Past Operability

- - - - Long Text Object Identification**************

Order 000070108698 Operation 0120 Long text NOTE: Revise short text to include a short, abbreviated, up to 35 character, title of the Technical Evaluation. For example:

"TE - Pipe Integrity w/ 1039A Valve Open" This note may be erased from the operation text.

Prepare a technical evaluation using the guidelines and template in CC-AA-309-101, Technical Evaluations Template, as follows:

SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 59 of 68

Operation Key Info - n 1 08/18/2010 VW1 AV Unit 1 AFW Past Operability Evaluation

- - - - Long Text Object Identification**************

Order 000070108698 Operation 0120 70108698 0120 Unit 1 AFW Past Operability Evaluation - Engineering

Title:

Salem Ul Past Operability Buried AFW Pipe - Past Operability Determination Reason for Evaluation / Scope:

As part of planned buried pipe inspections during the Salem Unit 1 refueling outage $1R20, guided wave inspection of the buried 4 inch Auxiliary Feedwater (AFW) piping that supplies the #12 and #14 steam generators identified localized wall thinning in several regions where more detailed examination was necessary. These piping regions were excavated and revealed significant external corrosion of the AFW buried piping. Straight beam ultrasonic measurements were then taken to determine the pipe wall thickness profile. The corrosion exceeded the design minimum wall criteria. This finally lead to excavating all of the accessible AFW buried pipe, which exposed general exterior corrosion and wall thinning affecting to a variable degree all of the exposed buried AFW piping. Only the portion of buried pipe that runs beneath the Fuel Transfer Tube to the Mechanical Penetration was not excavated.

This evaluation reviews the impact in terms of past operability of the non-conforming Salem Unit 1 AFW buried piping that was discovered to be below design minimum wall thickness.

Background Information The buried AFW pipes connect the discharges of the AFW pumps in the Auxiliary Building to the #12 and #14 main feedwater lines in the outer penetration area (OPA). The two lines travel a total of approximately 170 feet underground. They exit underground from the Mechanical Penetration at the 82' 11"

(#12) and 83' 11" (#14) elevations and run horizontally under the Fuel Transfer Tube.

Skirting the containment wall, they rise to the 94' 6" (#12) and 96' 0" (#14) elevations before passing through the Fuel Handling Building stub wall. They then continue horizontally, still underground at that depth along the edge of the containment building and then turning before entering the OPA to connect to the #12 and #14 SG feedwater lines.

The piping is 4-inch NPS, Schedule 80, A106 Gr B seamless carbon steel. It is classified as Nuclear 3, Seismic Category I. Per the Pipe Specification S-C-MPOO-MGS-0001, SPS 54E, the system design Pressure-Temperature limit is 1950 psi at 140 F. The nominal wall thickness is 0.337 inches +/- 12.5%.

SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 60 of 68

Operation Key Info - 0 ý 08/18/2010 P, 14I Guided Wave inspections of the Salem Unit 1 AFW buried piping revealed regions of degraded pipe wall thinning. Follow-up excavations unearthed more piping showing heavy external uniform corrosion. The apparent cause of the corrosion was the improper application (or lack) of the specified pipe coatings, X-Tru-Coat, an adhered polyethylene protection system, and Bitumastic, which was specified per drawings and pipe specifications to be applied at the welded joints.

Careful visual inspections of the excavated piping revealed a lack of coating. The only remnant of coating found was a portion of coal tar which was approximately 9 inches in length and 7 inches in circumference. This piece of coating was in the shape of the 4 inch AFW piping and conformed to that same profile.

Using the Guided Wave inspection results to target three specific areas (limiting measurements 12AF, 0.152 inch; 14AF, 0.160 inch; and 14AK, 0.166 inch wall) of buried AFW piping for excavation and examination, NDE Services initially performed confirmatory UT measurements on 378 grid areas. Approximately 76 percent of these UT measurements were non-conforming, having a minimum wall thickness less than the design minimum wall thickness of 0.278 inches. Based on these initial findings, the entire accessible portions of AFW buried pipe in Salem Unit 1 were excavated. A second set of UT measurements was then taken on a 1-inch by 1-inch grid for the full circumference of the pipe along the entire length of exposed AFW buried pipe (limiting measurement AF13T, 0.141 inch wall). The following numbers of UT readings were taken:

14 AFW Line (Upper Pipe): 8,904 readings total. 1,194 are below 0.278"

12 AFW Line (Lower Pipe): 8,852 readings total. 192 readings are below 0.278" The upper AFW buried pipe, which serves the #14 SG, was observed to be more corroded than the lower AFW pipe, which serves the #12 SG and which was buried 1 to 1-1/2 feet deeper. In fact, there were more than 6 times as many below minimum wall UT readings on the upper (#14) than on the lower (#12) AFW buried pipe.

Finally a third sample set of UT measurements was taken of the bottoms of AFW buried pipe that rest on the construction aid supports (hangers),

from which the overall worst case derived (14AF4T/14AF5T, 0.077 inch wall).

In summary, the worst case UT measurements, those having the least minimum wall thickness, were as follows:

For the #12 AFW buried piping, a 55 percent loss (0.152 inches).

For the #14 AFW buried piping, an approximately 78 percent loss (0.077 inches).

Removal of sections of the buried AFW piping in Salem Unit 1 during the S1R20 outage and subsequent visual examinations have validated that the identified corrosion is external.

SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 61 of 68

Operation Key Info 4 0

08/18/2010 Further examinations have also revealed evidence of the X-Tru-Coat on the through-wall portions of the buried AFW piping where it passes into the fuel transfer tube area (FTTA).

The coating system was not found on the remaining buried portions of these lines, which validates that the observed heavy general corrosion is due to a lack of coating.

The ground fill of the AFW piping is not a harsh environment (harsh with regard to coating), and there does not appear to be a correlation between the missing or deteriorated coating and the buried pipe environment.

Past Operability Evaluation As part of the planned inspections of buried pipe, the Buried Pipe Program requested that the #12 and #14 Auxiliary Feedwater (AFW) buried piping be inspected during the Salem Unit 1 refueling outage 11R20. The buried AFW piping runs underground from the Mechanical Penetration to the Outer Penetration Area, passing alongside the west end of the Containment from north to south. [Dwg.

207483] The buried portions of AFW pipe are downstream of the AFW SG Level Control valves 12AF21 through 14AF21 for the motor-driven AFW pumps (MDAFPs) and the AFW SG Level Control valves 12AF11 through 14AF11 for the turbine-driven AFW pump (TDAFP) and are upstream of the 12AF23 through 14AF23 AFW SG Inlet Stop Check valves. [Drawing. 2052361 The minimum wall thickness (tmin) for the buried AFW pipe is governed by the ANSI B31.1, 1967 Edition, Power Piping code, Equation 104.1:

tmin = PD / 2(SE+PY)

19504.5 / 2(15000+19500.4) = 0.278 inches Where pipe outside diameter (D) = 4.5 inches, design Pressure (P) 1950 psi, and SE is the material allowable of 15000 psi for seamless pipe, and Y

0.4 per the ANSI B31.1.

Because the buried AFW pipe is continuously supported, the deadweight and seismic loads are considered minimal. Therefore, the minimum wall thickness determined by using the design pressure is too restrictive with respect to determining operability. Instead, the Maximum Credible Operating Pressure (MCOP) was developed based on all AFW system operating conditions, and was used to evaluate tmin for the buried AFW pipe. Technical Evaluation 70108698-0100 determined that all AFW conditions that the MCOP for the buried Auxiliary Feedwater piping is conservatively bounded by 1275 psi. The corresponding minimum wall thickness based on a MCOP pressure of 1275 psi is 0.185 inches.

1275*4.5 / 2(15000 + 1275*0.4) = 0.185 inches using MCOP SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 62 of 68

Operation Key Info Wn 08/18/2010 MIR, 11 The 0.185 inch minimum wall thickness was originally increased 12 mils to provide an allowance for an additional cycle of operation based on an assumed maximum corrosion rate of 6 to 8 mils per year. [Ref. NUCR 70103767]

The intent was to replace any section of buried pipe that had a minimum wall less than 0.198 inches. In addition, all of the AFW buried piping, remnant and replacement, was to be re-coated before being buried again. However, as more UT measurements came in, it became clear that all of the buried AFW pipe should be replaced. DCP 80101382 was written to replace the inaccessible sections of AFW buried piping near and below the Fuel Transfer Tube and ECP 80101381 was written to replace the accessible portions of the AFW buried piping. Thus, all the AFW buried piping was replaced.

Additional UT measurements were taken from the bottom of the AFW buried pipe where it rested on carbon steel construction aides (hangers). These areas were added due to the inability of the Guided Wave technology to distinguish the boundary between the pipe and hanger metal and were thus suspect. During the inspection and UT measurements of these areas, the greatest pipe wall loss was discovered on the #14 AFW discharge line. A localized area having a minimum wall thickness measurement of 77 mils, the flaw was 0.25 inches in diameter and 0.75 inches in length before the surrounding pipe material increased to greater than 150 mils.

Upon discovery of these limited extreme localized areas of loss, Engineering requested Structural Integrity Associates, Inc. (SIA) to perform a rigorous Finite Element Analysis (FEA) of the AFW buried pipe using the most limiting cases (12AF, 14AF, 14AK, AF13T, and AF4T.AF5T) from the complete set of UT measurements. Four of the five worst cases of wall thinning were found on the upper buried AFW pipe that serves the #14 SG, which was found to be more corroded and have greater wall loss than the lower buried AFW pipe that serves the

12 SG. The SIA report, "ASME Code,Section III Design Analysis Evaluation of 4-inch Auxiliary Feedwater Piping," details the results of the FEA. The technical approach used was to assume that although piping may have localized thinned regions that violate the design t requirements, the non-uniform wall thickness of the pipe cross-section may still be shown to meet the design stress allowable. The approach is similar to the basis for qualifying pipe penetrations using branch reinforcement rules in the ASME Code and is possible for pipe sections exhibiting thinning when a remaining wall greater than tmin surrounds the thinning region. Note that the FEA did not use the Piping Specification SPS 54E design pressure for the piping but instead used the MCOP from Technical Evaluation 70108698-0100. An additional 35 psi was conservatively added to the MCOP at Design Engineering's request to provide operating margin.

The buried AFW pipe at Salem Unit 1 was designed to the tmin requirement given in the B31.1 Power Piping Code that does not provide specific criteria for evaluation of non-uniform wall thickness or thinning. However, guidance for stress analysis may be derived from the ASME Code,Section III, which can be used to supplement the B31.1 requirements.

SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 63 of 68

Operation Key Info 0

08/18/2010 MR AV Design requirements for Class 3 piping are provided in ND-3600 of the ASME Code,Section III, Division 1, 2004 Ed. Alternate methods are allowed under Section ND-3611.3, which permits use of a more rigorous piping design analysis such as NB-3200 to calculate stresses required to satisfy ND-3600 requirements. The calculated stresses must be compared to the allowable stresses in ND-3600. Thus to show acceptance of the degraded piping having a non-uniform pipe wall, the design loadings are determined using the design analysis methods in NB-3200. A finite element model is implemented incorporating the irregular pipe section profile defined by the UT thickness measurements. Current ASME Code allowable stresses are based on a factor of 3.5 on tensile strength instead of the factor of 4 as used in Salem's B31.1 Code of Construction.

Summary of Structural Integrity Associates (SIA) Finite Element Analysis Report Per the ASME Code:

"The specific design requirements of ND-3600 are based on a simplified engineering approach. A more rigorous analysis such as described in NB-3600 or NB-3200 may be used to calculate the stresses required to satisfy these requirements. These calculated stresses must be compared to the allowable stresses in this Subsection. In such cases, the designer shall include the appropriate justification for the approach taken in the Certified Design Report."

Thus, NB-3200 design by analysis is employed. Based on the linear-elastic finite element analysis results which showed that the thinned section of pipe (0.077 inch) was bounding, it was required to perform additional analysis only for that section of pipe in order to show operability. The more rigorous analysis employed is described in Section NB3228.1, Limit Analysis. Specifically Section NB-3228.1 states that limits on Local Membrane Stress Intensity need not be satisfied at a specific location if it can be shown by limit analysis that the specified loadings do not exceed two-thirds of the lower bound collapse load. Also, NB-3228.1 states that the yield strength to be used in this calculation is 1.5 Sm. In this evaluation, the value of yield strength is equal to 1.5 S, where S is taken as the value of Sh, 15.0 ksi, from the original 1967 B31.1 Power Piping Code. Thus, yield strength of 22.5 ksi is used.

The thinned section of pipe is modeled using the as-found wall thickness values for the region specified in S-TODI-2010-0005 which includes a minimum wall thickness of 0.077 inches. A pressure load of 1.5 times the PSEG specified operating pressure is applied (1943 psi = 1.5*[1310psia-14.7psi]) to the pipe per the more rigorous methodology to ensure that the operating pressure remains less than two-thirds of the failure pressure (1943

0.667 = 1295 psi).

The results of the finite element analysis show that the thinned pipe in this section remains structurally stable at 1.5 times the PSEG specified operating pressure and therefore passes the limit load analysis.

MPR's independent Review of SIA's Finite Element Analysis Report SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 64 of 68

Operation Key Info - l 08/18/2010 MPR Associates was contracted to perform an independent, third party review of SIA's Finite Element Analysis that was performed to address external wall thinning of buried Auxiliary Feedwater (AF) piping at Salem Unit 1. The SIA calculation concludes that the degraded piping was operable prior to replacement during the current refueling outage. MPR's review focused on the approach, bases for assumptions and design inputs, and conclusions of the SIA calculation. MPR found the approach and conclusions of the subject calculation to be reasonable, and concur with the calculation conclusion that the degraded AF piping was operable prior to its recent replacement.

Extent of Condition Because the Salem Unit 1 AFW discharge piping to the #11 and #13 steam generators runs from Containment to the Mechanical Penetration to the Pipe Alley to the Auxiliary Building, it is neither buried nor subject to the same corrosive environment as the AFW discharge lines to the #12 and #14 Steam Generators. The Buried Pipe Program inspection examined the Control Air (CA) and Station Air (SA) piping buried with the AFW pipe. A small pinhole leak was found in the CA pipe and was repaired to original condition. The overall condition of the CA and SA pipe was found with the protective coating intact and not degraded in the fashion as seen by the AFW pipe.

In operating Modes 5, 6, and Defueled, AFWS has no required safety function. The decay heat removal safety function is provided by the Residual Heat Removal (RHR) system. The AFWS does provide a means for refilling the secondary side of the SGs after eddy current testing and removal of the SG nozzle dams is complete. The secondary side water provides an additional heat sink in case of a loss of RHR cooling. In Mode 4 when RCS temperature is greater than 212°F but less than 350 0 F, the SGs can provide for decay heat removal if shutdown cooling is lost. Finally, in Modes 1 through 3, Technical Specification 3/4.7 Plant Systems, LCO 3.7.1.2, Auxiliary Feedwater System, requires at least three independent Auxiliary Feedwater pumps and their flow paths be operable to ensure that the RCS can be cooled down to a hot leg temperature less than 350'F in the event of a loss of offsite power (LOOP). This permits entry into the shutdown cooling mode of operation for the RHR system if RCS pressure is less than 340 psig.

Conclusions / Findings:

SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 65 of 68

Operation Key Info n 08/18/2010 MP, AV Despite being found in a degraded condition, the AFWS has always performed its safety and design functions in the past. No evidence has been found of a through-wall flaw in the piping surveyed. The piping has maintained structural integrity during normal operation. The limiting design basis accident, the steam line break (SLB) inside containment event from which the MCOP pressure is derived, has yet to occur. The results of the SIA FEA support the conclusion that the generalized corrosion observed has not yet degraded the pipe wall below a minimum thickness that would make it inoperable or subject to failure. The system is degraded but operable. Per the SIA analysis, the existing AFWS #12 and #14 buried pipe would be capable of operating for one more cycle-if re-coated properly to ensure a minimal, near zero corrosion rate. However, PSEG has chosen to replace all the buried piping in Salem Unit 1. MPR's independent Review of SIA's Finite Element Analysis Draft Report on past-operability found the approach and conclusions of the subject calculation to be reasonable, and concurred with the calculation conclusion that the degraded AF piping was operable prior to its recent replacement. (Final Report at VTD 901979)

Based on the UT measurements of remaining wall thickness, it is evident that the buried AFW pipe serving the #14 SG suffered a greater degradation than the buried AFW pipe serving the #12 SG. By simple inspection of the data and noting that there are more than 6 times the instances of below minimum wall UT findings on the upper (#14) pipe to the lower (#12) pipe, it is apparent that the lower the depth of the piping, the less the amount of corrosion. The UT data obtained from the buried AFW pipes below where they were cut and capped to weld on the new above ground AFW piping tend to support this line of reasoning. The UT data taken from the cut and capped stub sections of the buried AFW piping that descend to approximately the 83 foot elevation and pass through the FTTA show less overall corrosion, which was confirmed visually, also. The minimum cases of wall thinning found were 0.220 and 0.237 inches. The average wall thickness based on the 14 circumferential UT readings for each of these minimum cases was 0.272 and 0.371 inches. The maximum wall thicknesses measured in this section of buried AFW pipe actual exceed nominal wall thickness for 4-inch NPS Schedule 80 pipe.

Two possible reasons for this difference are (1) the concentration of oxygen in the soil and (2) the temperature of the soil. Each factor is greater the closer to the surface the pipe is and each factor increases the corrosion rate. The lowest portions of the buried AFW pipe were those that passed beneath the Fuel Transfer Tube and were buried at an elevation of 84'- 0" (#14) and 83'- 0" (#12) in the FTTA, which were inaccessible for excavation and UT examination. The AFW pipes that were in the accessible areas for excavation and UT measurement were buried at the more shallow elevations of 96'-0" (#14) and 94'-6" (#12). Assuming that the amount of corrosion decreases with depth, then it is likely that the sections of AFW pipe that were buried deeper were in better condition and less corroded than those that were buried approximately 12 feet higher, closer to the surface of the ground. This would assert that the worst cases of corrosion and sections of buried pipe with the greatest wall loss were those UT'd and analyzed by SIA. Hence, the conclusions in the FEA (VTD 901979) apply to the inaccessible buried AFW pipe as well. These sections of the buried AFW pipe were also operable over the past cycle.

SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 66 of 68

Operation Key Info 4 08/18/2010 V ' I A I M Based on the above information it can be concluded that there are no past operability concerns associated with Salem Unit 1 AFW piping found below minimum wall. The SIA finite element analysis demonstrates that the buried AFW piping in Salem Unit 1 had not degraded to a condition where it would have failed under the most severe operating condition. The AFW piping found being below minimum wall was operable in the past and up to the present as-found condition. Therefore, there is no past operability concerns associated with the Salem Unit 1 AFW piping found below minimum wall. This evaluation was reviewed with Operations and Safety and they concur with the conclusions.

Reference Documents:

Technical Specifications Section(s):

T/S 3/4.7 Plant Systems, LCO 3.7.1.2, Auxiliary Feedwater System UFSAR Section(s):

10.4.7.2, Auxiliary Feedwater System 15.2.8, Loss of Normal Feedwater 15.2.9, Loss of Offsite Power to Station Auxiliaries (LOP) 15.3.1, Loss of Reactor Coolant from Small Ruptured Pipes (SBLOCA) 15.4.1, Major Reactor Coolant System Pipe Ruptures (LBLOCA) 15.4.2, Major Secondary System Pipe Rupture (MSLB) 15.4.3, Major Rupture of Main Feedwater Line (FWLB) 15.4.4, Steam Generator Tube Rupture (SGTR)

Other:

Technical Evaluation 70108698, Rev. 0 ANSI B31.1, 1967 Ed., Power Piping S-C-MPOO-MGS-0001, SPS54, Rev. 6, Piping Schedule, Auxiliary Feedwater S-C-AF-MDC-0445, Rev. 3, Auxiliary Feedwater System Hydraulic Analysis S-C-A900-MDC-005, Rev. 0, Pipe Wall Thickness Calculations SC.DE-BD.AF-0001(Q), Rev. 0, Auxiliary Feedwater System VTD 901979, Structural Integrity Associates, Inc., "ASME Code,Section III, Design by Analysis Evaluation of a 4-inch Auxiliary Feedwater Piping" SCI-94-877 LTR dated 12/16/1994 - Excavated Auxiliary feedwater Piping Walkdown/Disposition of Coating Requirements MPR Associates to Mr. Mohammad Ahmed, "Review of Degraded AFW Piping Past-Operability Evaluation", dated 24 April 2010.

PREPARER: Michael Crawford Date: See SAP INDEPENDENT REVIEWER: Gary Luh Date:

See SAP SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 67 of 68

Operation Key Info 08/18/2010 APPROVED: Steve Davies Date: See SAP SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 68 of 68

Operation Key Info - n A 08/18/2010 MR .1W Per discussion with Salem Engineering Programs Mgr. NUKAC & Salem Design Engineering Mgr - NUAAJ, this eval is not required.

NURSM 4/29/2010.

Signature: ROBERT S MONTGOMERY Confirmation Text:

se long text se long text although the responsible engineers disposition is acurate, the following information applies; and was copied from 60084266 op 10.

Below are the Buried Pipe Program Inspection Reports for the #12 & #14 Aux Feedwater Lines that were inspected during the 1R20 Excavation. These forms and pictures are maintained by the Salem Buried Pipe Program Manager in the Program Notebook. Their format had to change slightly to be loaded into SAP.

ER-AA-5400-1002 Revision 1 Page 1 of 6 ATTACHMENT 8 AS-FOUND BURIED PIPING VISUAL INSPECTION REPORT LINE NUMBER: S1-AF-1075-04 AF, AH -AN WORK ORDER: 60084266 System: Auxiliary Feed Water Risk Ranking: 1400 - 1505 LOCATION: Salem Unit 1 - 4" AUXILIIARY FEEDWATER LINE NO. 12 TRAIN AS IT WRAPS AROUND UNIT 1 CONTAINMENT BUILDING SOUTH SIDE Backfill: Contains Very Few Rocks XX CONDITION OF COATING:

Severely Degraded: XX

- Metal exposed

- Poor adhesion PIPE MATERIAL:

Carbon Steel XX 4" A106 Gr. B Carbon Steel EXTERNAL CORROSION:

Severe XX LEAK SOURCE:

SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 2 of 68

Operation Key Info W 4A m11 08/18/2010 P, 14F This line was NOT LEAKING. This was an inspection to perform Guided Wave inspection of the buried portion.

LEAK LOCATION:

N/A NO LEAK Pictures (preferably digital) shall be taken of all buried pipe leaks.

Entire length of #12 - 4" diameter Auxiliary Feedwater piping was excavated after the Visual Inspection and Guided Wave inspection (performed as a planned 1R20 activity) identified that there was severe corrosion on the OD of the pipe. Notification 20456999 was written after seeing the condition of the pipe prior to and after the Guided Wave Collar was installed. It appears as if there was either very little coating applied in very sparse locations or not even installed at all on the pipe. UT measurements were recorded for the entire length of pipe, except for approximately 15 feet near the Outer Penetration. The external corrosion was machined off, with needle guns and wire wheels, to allow for a true look at the pipe exterior and to allow for UT recording. The pipe wall was pitted quite extensively. Notification 20456999 was written to document the pipe condition, and to allow work to begin on recoating / replacement as mandated. (See WO 60089561 for replacement/repair).

UT results showed in agreement with the G-wave results that were recorded prior to complete excavation (mid 0.200" wall, with a low for the line identified in the upper 0.100's). UT data maintained with Buried Pipe Program notebook and this Inspection Report hard copy. Also, see Tech Eval 70108698. An OE was created and issued to industry. It was noted that the coating on the SA & CA Lines that share the Aux Feedwater pipe supports had some areas that needed to be repaired (Notifications 20458761 & 20458925 document these). See picture at M:\ Shared \ Buried Piping

\ Salem Aux Feedwater. PERFORMED BY: R. S. Montgomery DATE: 04/17/10 xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx ER-AA-5400-1002 Revision 1 Page 1 of 6 ATTACHMENT 8 AS-FOUND BURIED PIPING VISUAL INSPECTION REPORT Line Number: S1-AF-1053-04-01-AF, AH -AN Work Order: 60084266 System: Auxiliary Feed Water Risk Ranking: 1400 - 1505 LOCATION: Salem Unit 1 - 4" AUXILIIARY FEEDWATER LINE NO. 14 TRAIN AS IT WRAPS AROUND UNIT 1 CONTAINMENT BUILDING SOUTH SIDE Backfill:

Contains Very Few Rocks XX CONDITION OF COATING:

Severely Degraded: XX

- Metal exposed

- Poor adhesion PIPE MATERIAL:

Carbon Steel XX 4" A106 Gr. B Carbon Steel SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 3 of 68

Operation Key Info A 0

08/18/2010 MP, Mr F EXTERNAL CORROSION:

Severe XX LEAK SOURCE:

This line was NOT LEAKING. This was an inspection to perform Guided Wave inspection of the buried portion.

LEAK LOCATION:

N/A_ NO LEAK Pictures (preferably digital) shall be taken of all buried pipe leaks.

Entire length of #14 - 4" diameter Auxiliary Feedwater piping was excavated after the Visual Inspection and Guided Wave inspection (performed as a planned 11R20 activity) identified that there was severe corrosion on the OD of the pipe. Notification 20456999 was written after seeing the condition of the pipe prior to and after the Guided Wave Collar was installed. It appears as if there was either very little coating applied in very sparse locations or not even installed at all on the pipe. UT measurements were recorded for the entire length of pipe, except for approximately 15 feet near the Outer Penetration. The external corrosion was machined off, with needle guns and wire wheels, to allow for a true look at the pipe exterior and to allow for UT recording. The pipe wall was pitted quite extensively. Notification 20456999 was written to document the pipe condition, and to allow work to begin on recoating / replacement as mandated. (See WO 60089561 for replacement/repair).

UT results showed in agreement with the G-wave results that were recorded prior to complete excavation (mid 0.200" wall, with a low for the line identified in the upper 0.100's). UT data maintained with Buried Pipe Program notebook and this Inspection Report hard copy. Also, see Tech Eval 70108698. An OE was created and issued to industry. It was noted that the coating on the SA & CA Lines that share the Aux Feedwater pipe supports had some areas that needed to be repaired (Notifications 20458761 & 20458925 document these). See picture at M:\ Shared \ Buried Piping

\ Salem Aux Feedwater.

PERFORMED BY: R. S. Montgomery DATE: 04/17/10 Note also that two change packages were processed incoporating repair/replacement actions associated with the as-found condition of the buried pipe to restore complete unrestricted function cp 80101381 equivalent replacement for Buried AF piping (mitred vs bent pipe) cp 80101382 relocation/reroute of AF piping in fuel transfer tube area to mechnaical penetration reference also nucr 70108698 SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 4 of 68

Operation Key Info 08/18/2010 Order: 70108698 (88) 1R20 AF Buried Pipe Insp Results Operation: 0030 SA - PROVIDE OE REPORT TO COORDINATOR Work center: S-EPB04 NNUC Status: TECO CNF MANC NMAT PPRT Number of People: 0 Scheduled Dates: Start: 04/07/2010 Finish: 04/07/2010 Planned Hours: 0.0 Actual Dates: Start: 04/07/2010 Finish:04/07/2010 Actual Hours: 0.000 Personnel Number:

Completion Confirmation Number: 8161981 Confirmation Text:

See long text See long text

- - - - Long Text Object Identification**************

Order 000070108698 Operation 0030 Confirmation 0008161981 Confirmation counter 00000001 Long text The purpose of this operation is to perform the following:

"PROVIDE OE REPORT TO COORDINATOR

1. Use the INPO OE report template below to write the report.

2. Upload the report into a confirmation in this operation.

3. Obtain your Manager's approval in the above operation confirmation.

4. Email electronic version of the manager approved report to Joe Arena Salem (x1353) within 20 days of the event. Deliver a manager signed Traveler (available on the Opererating Experience Website)and the final version hard copy to the Regulatory Assurance Manager."

The OE shown below has been updated with comments from the OE coordinator Joe Arena.

Abstract:

An inspection revealed general corrosion of the coated carbon steel underground Auxiliary Feedwater System piping.

SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 7 of 68

Operation Key Info A 0

08/18/2010 'W1 AV

Title:

Preliminary - Corrosion Found on Buried, Externally Coated, Carbon Steel Auxiliary Feedwater System Piping (Salem).

Event Date:

04/5/2010 Station Name/Unit Number:

Salem Unit 1 Significance:

Near miss.

Lessons Learned for the Industry:

Coated underground carbon steel piping is subject to external corrosion.

Applicability:

Buried Piping Program Engineers

Description:

On April 5, 2010 during the 1R20 refueling outage, a section of the Unit 1 Salem Station Auxiliary Feedwater System buried piping was excavated and inspected in accordance with the buried piping program. The corroded piping delivered the required amount of water to the steam generators at the start of the 1R20 outage. Guided wave inspections revealed general corrosion of the external surface of the coated carbon steel piping. Visual inspection of the piping revealed failure of the coating of the outer surface of the piping. Additional inspections and excavation are being executed to determine the extent of condition and corrective actions.

Consequences:

The corroded Auxiliary Feedwater piping was capable of performing its function. No Tech Spec entry was necessary because the inspection results were obtained when the reactor was in Mode 5.

Causes:

Degradation of outer pipe coating caused by long term exposure to ground water in surrounding soil enabled corrosion of carbon steel piping to occur.

Corrective Actions:

Additional excavations initiated to gather additional data A calculation of the required pipe wall thickness and future corrosion will be performed. A determination of pipe replacement will be based on the calculations.

Previous Industry OE:

1. 0E28063: Corrosion degradation of flanged connections in buried pipe at San Onofre Station.

2. OE10840: Leaking buried steam pipe at Palisades Station.

SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 8 of 68

Operation Key Info 08/18/2010 VW'

3. OE10250: Underground DRISCO pipe failure at Perry Unit 1 Station.

Equipment Information:

NSSS/A-E:

Westinghouse/PSEG Reactor Type: PWR Affected System: Auxiliary Feedwater System Component Manufacturer: N/A Component Model Number: N/A Component Part Number: N/A Information

Contact:

Name: Bob Montgomery

Title:

Buried Piping Program Engineer Telephone:

856-339-1781 E-mail: robert.montgomery@pseg.com Corrective Action Program Documents:

70108698 Attachments (Pictures, Root Cause, and so forth):

None Signature: ARTHUR N GARCIA Confirmation Text:

BOP Branch Manger Approval Signature: ROBERT A HENRIKSEN Description of Work:

SA - PROVIDE OE REPORT TO COORDINATOR

- - - - Long Text Object Identification**************

Order 000070108698 Operation 0030 Long text SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 9 of 68

Operation Key Info A 08/18/2010 VIM, AV This notification has been determined by the Management Screening Committee to require an Operating Experience Report.

1. Use the INPO OE report template below to write the report.

2. Upload the report into a confirmation in this operation.

3. Obtain your Manager's approval in the above operation confirmation.

4. Email electronic version of the manager approved report to Joe Arena Salem (x1353) within 20 days of the event. Deliver a manager signed Traveler (available on the Opererating Experience Website)and the final version hard copy to the Regulatory Assurance Manager.

NOTE:

The INPO Goal is to issue reports within 50 days of the event.

Any extension beyond 30 days could impact meeting this goal.

Abstract:

(text here)

Title:

(text here)

Event Date: (text here)

Station Name/Unit Number: (text here)

Significance/Importance: (text here)

Lessons Learned for the Industry: (text here)

Applicability: (text here)

Description:

(text here)

Consequences: (text here)

Causes:

(text here)

Corrective Actions:

(text here)

Previous Industry OE/CE:

(text here)

Equipment Information:

NSSS/A-E:

Reactor Type:

Affected System:

SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 10 of 68

Operation Key Info w 0

08/18/2010 MIM 11W As part of planned buried pipe inspections during the Salem Unit 1 refueling outage S1R20, guided wave inspection of the buried 4 inch Auxiliary Feedwater (AFW) piping that supplies the #12 and #14 steam generators identified localized wall thinning in several regions where more detailed examination was necessary. These piping regions were excavated and revealed significant external corrosion on the AFW buried piping. Straight beam ultrasonic measurements were then taken to determine the pipe wall thickness profile. The corrosion exceeded the design minimum wall criteria. This finally lead to excavating all the AFW buried pipe, which exposed general exterior corrosion and wall thinning affecting all of the buried AFW piping.

This evaluation reviews the impact in terms of past operability of the discovery of the non-conforming Salem Unit 1 AFW buried piping that was below design minimum wall thickness.

Background Information The buried AFW pipes that connect to the #12 and #14 main feedwater lines in the outer penetration area (OPA) travel approximately 30 feet underground along the edge of the containment building before entering the OPA at elevations 94' 8" (#12) and 96' 2" (#14).

The piping is 4-inch NPS, Schedule 80, A106 Gr B seamless carbon steel. It is classified as Nuclear 3, Seismic Category I. Per the Pipe Specification S-C-MPOO-MGS-0001, SPS 54E, the system design Pressure-Temperature limit is 1950 psi at 140 F. The nominal wall thickness is 0.337 inches +/- 12.5%.

Guided Wave inspections of the Salem Unit 1 AFW buried piping revealed regions of degraded pipe wall thinning. Follow-up excavations unearthed more piping showing heavy external uniform corrosion. The apparent cause of the corrosion was the improper application (or lack) of the specified pipe coatings, X-Tru-Coat, an adhered polyethylene protection system, and Bitumastic, which was specified per drawings and pipe specifications to be applied at the welded joints.

Careful visual inspections of the excavated piping revealed a lack of coating. The only remnant of coating found was a portion of coal tar which was approximately 9 inches in length and 7 inches'in circumference. This piece of coating was in the shape of the 4 inch AFW piping and conformed to that same profile.

Using the Guided Wave inspection results to target three specific areas (limiting measurements 12AF, 0.152 inch; 14AF, 0.160 inch; and 14AK, 0.166 inch wall) of buried AFW piping for excavation and examination, NDE Services initially performed confirmatory UT measurements on 378 grid areas. Approximately 76 percent of these UT measurements were non-conforming, having a minimum wall thickness less than the design minimum wall thickness of 0.278 inches. Based on these initial findings, the entire accessible portions of AFW buried pipe in Salem Unit 1 were excavated. A second set of UT measurements was then taken on a 1-inch by 1-inch grid for the full circumference of the pipe along the entire length of exposed AFW buried pipe (limiting measurement AF13T, 0.141 inch wall). The following numbers of UT readings were taken:

SAFETY: The Only C.H.O.I.C.E.

Commitment Help Oversight Involvement Communication Empowerment Page 43 of 68

Operation Key Info A 0

08/18/2010 MIR IW

14 AFW Line (Upper Pipe): 8,904 readings total. 1,194 are below 0.278"

12 AFW Line (Lower Pipe): 8,852 readings total. 192 readings are below 0.278" Finally a third sample set of UT measurements was taken of the bottoms of AFW buried pipe that rest on the construction aid supports (hangers),