ML12090A745
| ML12090A745 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 10/23/2008 |
| From: | Entergy Nuclear Operations |
| To: | Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| Shared Package | |
| ML12090A727 | List:
|
| References | |
| RAS 22156, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01 CR-IP2-2008-04754 | |
| Download: ML12090A745 (13) | |
Text
ENT000426 Submitted: March 30, 2012 Entergy CONDITION REPORT ICR-IP2-2008-047S4 Originator: Azevedo,Nelson F Originator Phone: 7346775 Originator Site Group: IP2 P&C Eng Codes Mgmt IP2 Operability Required: Y Supervisor Name: Burroni,Richard J Reportability Required: Y Discovered Date: 10/2312008 06:04 Initiated Date: 10123/200806: 13 Condition
Description:
Visual inspections of the underground piping exposed by the upper excavation between the CST and the Aux Feed Pump building revealed five areas where the coating had degraded. Subsequent UT inspections indicated that the piping remains at full thickness and therefore there has been no corrosion (other than minor surface corrosion) of the piping as a result of coating degradation in these five areas.
Immediate Action
Description:
Discussed the results with the appropriate stakeholders.
Suggested Action
Description:
Complete excavation of the lower hole, perform visuallUT inspection of the piping in the lower hole and repair any araes where the coating has degraded.
EQUIPMENT:
Tag Name Tag Suffix Name Component Code Process System Code PIPE COND TRENDING (For Reference Purposes Only):
Trend Type Trend Code REPORT WEIGHT 1 HEPFACTOR E EM ESPC INPO BINNING ER3 KEYWORDS KW-AGE MANAGEMENT KEYWORDS KW-NDE KEYWORDS KW -PIPE WALL KEYWORDS KW-MARGIN REVIEW KEYWORDS KW-CODES & STANDARDS
- PERIODIC REVIEW - INITIAL 05127/09 NA as CR closed this date
Entergy I CORRECTIVE ACTION ICR-IP2-2008-047S4 CANumber:
Site I* Group Name Assigned By: 1P2 CRG/CARB/OSRC 1P2 Harrison,Christine B Assigned To: 1P2 P&C Eng Codes Mgmt 1P2 Azevedo,Nelson F Subassigned To :
Originated By: Harrison,Christine B 101291200807:22:4 1 Performed By: Azevedo,Nelson F I 1118/2008 09:36:34 Subperformed By:
Approved By:
Closed By: Azevedo,Nelson F 111181200809:36:34 Current Due Date: 11/1912008 Initial Due Date: 1111912008 CA Type: DISP - CA Plant Constraint: #NONE CA
Description:
Please review and assign further corrective actions as required.
Response
The three CST pipes (aux feed pump supply, CST return and CST overflow) were exposed at two locations for approximately 10' each. An inspection in the upper hole identified five areas which required coating repair and one area in the lower hole which required coating repair. In addition, there were several areas in the overflow pipe in the lower hole which required coating repair. These repairs have been completed and the upper hole has been backfilled. The lower hole is ready for backfilling. UT thickness measurements were also performed on those areas where the base metal was exposed and these inspections confirmed that the pipe thickness remains at nominal thickness (i.e. within the manufacturers tolerance). All of these activities have been performed under WO 164495. CA 0002 has been issued to evaluate any future inspections and its associated technical basis.
Subresponse :
Closure Comments:
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Entergy I CORRECTIVE ACTION ICR-IP2-2008-047S4 CANumber: 2 Site Group Name Assigned By: IP2 P&C Eng Codes Mgmt IP2 Azevedo,Nelson F Assigned To: IP2 P&C Eng Codes Staff IP2 Lee,Robert C Subassigned To :
Originated By: Azevedo,Nelson F 1111412008 14:39:29 Performed By: Azevedo,Nelson F 12/111200812:1l:l5 Subperformed By:
Approved By:
Closed By: Azevedo,Nelson F 1211112008 12:11: 15 Current Due Date: 1211212008 Initial Due Date: 12/1212008 CA Type: ACTION Plant Constraint: #NONE CA
Description:
Determine if additional future inspections are required for these pipes. Provide the technical basis for the decision.
Response
Description:
Determine if additional future inspections are required for these pipes. Provide the technical basis for the decision.
Response
Completed assessments of these lines determined these lines to be of HIGH impact (2 lines are safety related), MEDIUM corrosion risk and HIGH inspection priority. The HIGH inspection priority results from the safety function performed by Lines 1505 and 1509. The pipe material , so il resistivity and site conditions factors result in these lines being of medium corrosion risk.
The 3 inspected lines were:
12" Line 1505 - AFP suction line 8" Line 1509 - Condensate supply to the CST 10" Overflow line (no line number assigned, corrugated metal pipe) to manhole #5 These pipes run underground in parallel with one another. As stated above, in accordance with the methodology provided by EN-DC-343 , for determining the inspection priority and re-inspection interval, Lines 1505 and 1509 are of High Priority.
Accordingly, with the initial inspection of these lines performed in OctoberlNovember 2008, re-inspection of of these lines is required within 8 years, or by September 20 16.
The visual inspection of these pipes at the lower excavation revealed that they were in generally good condition, with the coating intact and in acceptable condition. See the attached as-found inspection results by the coatings engineer, and post coating repair inspection reports . A minor coating repair was required at one location on 8" Line 1509, and the 10" overflow line required repair at the top portion of the pipe at the crests of the corrugations, possibly indicative of coating damage during the digging. Based on the results of these pipe visual inspections (at the upper and lower holes). and the coating repairs performed, there was no evidence of any significant pipe degradation that would warrant the re-inspection of these pipes at the same locations. Future inspection of these lines will be performed at different location(s) along their length. The scheduling of the future inspections will be controlled under the IPEC Buried Pipe Program. CA #3 has been created to track the scheduling of the future inspection of these lines, pending formal issue of the IPEC Buried Pipe Program document.
Subresponse :
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Entergy CORRECTIVE ACTION CR -IP2-2008-047 54 Closure Comments:
ttachments:
Resp Description CST Lower Excavation - As-Found Inspection
Page 1 of 1 Lee, Robert C
,---.--.- . --.---- .~.---- .. - -....- - - --
From: Guarnaccia, Stephen Sent: Wednesday, November 12, 20084:34 PM LOWER £xc,fVA ,(I oA/
To: Lee, Robert C Cc: Arcate, John; Drake, Richard S; Pineda, Juan J
Subject:
Unit 2 CST Piping Inspection
- Bob, I inspected the three eST pipes located in the excavation on the hill north of the Unit 2 ve.
The large diameter pipe's coating, although rather inconsistent in spots, is acceptable. The coating was found to have some reddish material attached to the lower left side that appeared to be corrosion byproducts. I removed a few small samples of the material and checked them with a magnet. They were not ferrous in nature therefore not corrosion products.
The smaller diameter pipe's coating was more uniform in its appearance and in generally good condition. There is one location on the upper top end that has a well defined crack in the coating running circumferentially from the 11 o'clock to the 1 o'clock position. The crack is approximately four or five inches in length with a small amount of corrosion products emanating from it. This area must be repaired in accordance with the same requirements as the previous repairs. In my opinion, judging from the small amount of corrosion products and the good appearance of the coating the pipe does not need to be exposed for a more detailed inspection in order to determine the amount of material lost.
The corrugated pipe has a number of areas where the coating has been removed and they need to be repaired as previously instructed also.
I recommend that you take a look at the pipes yourself to verify my findings in order to resolve the issue.
I could not find your camera cable so I could not attach a picture at this time. Let's get together tomorrow morning after the tailgate and view the pictures.
Steve G. x6609
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& /, LII../e /5 0 9 C*O N OffN5ATIi '5/,A PP,-Y /0 CST
CORRECTIVE ACTION CR -IP2* 2008-047 54 CA Number: 3 Site Group Name Assigned By: IP2 P&C Eng Codes Mgmt IP2 Azevedo,Nelson F Assigned To: IP2 P&C Eng Codes Staff IP2 Lee,Robert C ,
Subassigned To :
Originated By: Azevedo,Nelson F 121111200812:10:46 Performed By: Lee,Robert C 2/191200922:54:55 Subperformed By:
Approved By:
Closed By: Lee,Robert C 2/1912009 22:54:55 Current Due Date: 02/2412009 Initial Due Date: 0212412009 CA Type: ACTION Plant Constraint: #NONE CA
Description:
Track the scheduling of the future inspection of these lines, pending formal issue of the IPEC Buried Pipe Program document.
Response
In lieu of each of the Entergy sites issuing its own buried piping program document, it has been decided by the Buried Piping Peer Group that a fleet Central Engineering Program (CEP) Buried Piping Program Document will be generated, (Target date for issue is 4th QTR 2009). To manage and track all inspection activities, each site will use Iddeal Scheduleworks (or equivalent) software.
The details and results of the impact, corrosion risk assessments, inspection prioritization and schedules will be captured and maintained by Iddeal Scheduleworks .
For the buried condensate piping from the IP2 CST to the AFW Bldg that is the concern of this CA, as previously stated, these lines are categorized as being high priority for inspection. As such, the re-inspection will be performed 8 years from the intial inspection, or by end of 2016.
Capture of the IPEC buried pipe program activities, key program data and performance indicators into Iddeal is being tracked by LO-HQNLO-2008-00015 CA 65 .
Attached to this reponse is an EXCEL spreadsheet identifying the IP2 buried piping inspection schedule. The subject piping and their future inspection dates have been highlighted.
This CA may be closed to the aforementioned HQNLO CA.
Subresponse :
Closure Comments:
Attachments:
Resp Description IP2 Buried Piping Inspection Schedule
B~riedPieirlQProQram Initiaiinspection Sctleciu1e !ell1 plate ... Plant: IP2 Date: 1112012008
- insp .schOO year HIGH IMPACT PIPING 3 2008 Inso .oriorllv #-2flines Initialns d 2 2009 HIGH 22 5Y 12131/2013 6 2010 MEDIUM 3 8Y 12/30/2016 5 o r- 6 '*
2011 2012 LOW Total 25 lOY 1213012018
~
3 2013
[ ., g. ~~~} i Ie .
- i
'2
'ii 2016
- ' 2017
- 20is- t I
5
- 'l 2019 2020
~
3 2021
~
Novru;'
1 ;0 :!7d
~
1)i!p?sl>ft.iii~~b~f!(,~:~e~~lopm~rit()tti~levlllin;tialSc~ecflJ'El:for :8'~HIM~ACTpl"in90nly. . ..... ......... . ... .... , . ........... _.. .
J!"Ction~ fiiQ~ Prio<.ity (RE:[):by2013; ~OOi.u.m (YELLOW) - b~.2018 1 ..... .... . . . . .... . . .. . ... .. ._.... .. .
12li!nitial.lns.
3)(Subsequent inspection sche<Juleissubject to revisjon, pending results of initial i~spections. High Priority. (RED). - within 8 years ofinitialinspectitm; Medium Priority (YELLOW)
- within 10 years of intial inspection .
Initial Inspection Initial Subsequent Start Finish Impact Corrosion Inspection Section # Activity Name Inspection Interval Description System Inspection Inspection I 1iW'-2CWM-!
a!>-2CWM"-2.
Pipe inspection Pipe inspection Bl"-2EDGF~i Pipe inspection (inmal) 1/112010 1/112010 111(2010 (initial) 12/3112010 1213112010 1213112010 Assessment HIGH HIGH HIGH Risk MEDIUM MEDIUM MEDIUM Priority HIGH HIGH HIGH (vears) 5 5
5 (vears) 8 8
8 CW Supply Header* IS" cw to AFP Bldg
- 8" Line 1502 EOG FOST equalizing line City Water City'Water F'uelOil (by 2013) 2010 2010 2010 (by 2021) 2018 2018 2018 "n_"
~'2EDGF0-2 Pipe inspection 11112010 1213112010 HIGH MEDIUM HIGH 5 8 EDG FOST
- 4" lank fill Fuel ell 2010 2018 Service tlP-2SW-l Pipe inspection 11112011 1213112011 HIGH MEDIUM HIGH 5 8 Maio SW Header - 24" Line 408 Wate-r 2011 2019
~-
Main SW Header - 24" Une 4d£t" "",', .~,,,, '* geMce fjP-2SW-2 Pipe inspection 1/112011 12131/2011 HIGH MEDIUM HIGH 5 8 Water 2011 2019 Service IIp-2SW-3 Pipe inspection 1/112012 1213112012 HIGH MEDIUM HIGH 5 8 sw Branch to lAce HXs- 3" Line 1704 Water 2012 2020 H- Service 13P-2SW-4 Pipe inspection 1/1/2012 12131/2012 HIGH MEDIUM HIGH 5 8 SW 8fanctl to lAce HXs- 3" Line 1705 Water 2012 2020 Service BP-2SW-5 Pipe inspection 111/2011 1213112011 HIGH MEDIUM HIGH 5 8 Rel~ Oi I
- 24" u-405. -"" -2ll1.9
\) .--~.--.----
+
- lev Aux 4th Q1r 2008 *
~-2AFW-l Pipe Inspection 10/2008 A 11/2008 A HIGH MEDIUM HIGH 5 8 CST 10 AFWP Suction. 12" Un. 1505 Feedwaler COMPLETE 2016 Aux 4th Q1r 2008*
BP-2AFW-2 Pipe inspection 1012008 A 11/2008 A HIGH MEDIUM HIGH 5 8 (; CST Inlet* 8" Une 1509 Feedwater 2016 COMPLETE r---- Aux -
BP-2AFW-3 Pipe inspection 11112013 1213112013 HIGH MEDIUM HIGH 5 8 CST ~e.1iow . ~.\S'<1l'~ L. . _ __ ~OI3 . !-._ 202 1 (lP-2AFW-4 Pipe inspection 10!2008A 1f12OO8A. HIGH MEDIUM HIGH 5 8 (
CST Overflow
- 10" IC.M.P .)
Feed.WOU8f.-
Aux 4th atr 2006
- Feedwalll!_ ._ COMf'kE-T-li... 2016
,q.
Pipe Inspeclion 1/112009 1213112009 HIGH MEDIUM HIGH 5 8 r--- CWP dlsch to Condenser - 84~
Circulating 2009 2017 Water Circulat!ng Pipe inspection 1/1 12009 1213112009 HIGH MEDIUM HIGH 5 8 CWP discl1 to Condenser
- 84~
Water 2009 2017
Impact Corrosion Inspection Initial Inspection Initial Subsequent I Name inspection Interval Description System Inspection Inspection Assessment Risk Priority (years) (years) (by 2013) (by 2021) 1 Clrcutating
'~P*2CW*3 , Pipe inspection 11112010 121:5112010 HIGH MEDIUM HIGH 5 8 CWP disch to Condenser ~ 84" 2010 2018 Water CirCtJlating i~P*2CW4 : Pipe inspection t 1213112010 HIGH MEDIUM HIGH 5 8 CWP disch to Condenser
- 84" Water 2010 2018 Circulating Pipe inspection 11112011 1213112011 HIGH MEDIUM HIGH 5 8 CWP disch to Condenser - 84" Water 2011 2019 Circulating i Pipe inspection 1111201 1213112011 HIGH MEDIUM HIGH 5 8 CWP disch to Condenser Water 2011 2019 Instrument Pipe inspectioo 11112012 1213112012 HIGH LOW MEDIUM 8 10 lA Line to Intake Struct *1X:'"
Air 2012 2022 Instrument .
Pipe inspection 11112012 1213112012 HIGH LOW MEDIUM 8 10 IA Supply to AFP Bldg* 2" Ai( 2012 2022 IPipe inspection 11112012 1213i12012 HIGH LOW MEDIUM 8 10 IA Supply to VC
- 2" Instrument Air 2012 2022 Cont. Penet Pipe inspection 1: 11 HIGH MEDIUM HIGH 5 8 1~1/20> piping to penet ~ lW' 2013 2021 Press.
Waste Pipe inspection 12 1213112012 HIGH MEDIUM HIGH 5 8 RWST Overllow to WHT Pit 6" Uno 299 Disposal 20 12 2020 Waste Pipe inspection 11112013 12/3112013 MEDIUM 5 8 PWST Overflow to Une 299 3" 2013 2021
, -- , HIGH HIGH
- Disposal
Entergy CORRECTIVE ACTION CR-IP2-2008-04754 CA Number: 4 Site Group Name Assigned By: IP2 CAA Staff IP2 Reynolds,Joseph A Assigned To: IP2 P&C Eng Codes Mgmt IP2 Azevedo,Nelson F Subassigned To :
Originated By: lowitt,Roseann 21201200906:35 :34 Performed By: Azevedo,Nelson F 21271200906:56:02 Subperformed By:
Approved By:
Closed By: Reynolds,Joseph A 21271200907:45:26 Current Due Date: 03/04/2009 Initial Due Date: 03/0412009 CA Type: CR CLOSURE REVIEW Plant Constraint: #NONE CA
Description:
CAT -C, ALL CORRECTIVE ACTIONS ARE CLOSED FOR THIS CR, THEREFORE THIS CR MAYBE READY TO CLOSE. REVIEW CR AND APPROVE 1 DISAPPROVE CLOSURE IN ACCORDANCE WITH EN-LI-l 02, SECTION 5.9.
Response
This CR is not ready for closure. CA 005 has been issued for follow up evaluations.
Subresponse :
Closure Comments:
Per CAA review, noted the CR owner did NOT approve the closure of the CR, and assigned additional action. Therefore this CR removed from the closure process and this completed action closed.
Entergy CORRECTIVE ACTION CR -IP2-2008-04754 CA Number: 5 Site Group Name Assigned By: IP2 P&C Eng Codes Mgmt IP2 Azevedo,Nelson F Assigned To: IP2 P&C Eng Codes Staff IP2 Lee,Robert C Subassigned To:
Originated By: Azevedo,Nelson F 212712009 06:55 :05 Performed By: Azevedo,Nelson F 5127/200909: 17:22 Subperformed By:
Approved By:
Closed By: Azevedo,Nelson F 5/2712009 09: 17:22 Current Due Date: 05/3112009 Initial Due Date: 05/3112009 CA Type: ACTION Plant Constraint: #NONE CA
Description:
Given the results of the leak in the AFP building, determine if the scope and/or frequency of future buried condensate lines should be modified. This should cover both IP2 and IP3.
Response
The initial Impact and Corrsoion Risks assessments for the AFW underground piping were performed iaw fleet procedure EN-DC-343 "Buried Piping & Tank Inspection and Monitoring Program." Those assessment resulted in the categorization of Lines 1505 and 1509 as high inspection priority lines, with first inspection performed within 5 years (by EOY 2012), and subsequent re-inspection within 8 years thereafter (EOY 2020).
Responding to the ISE Panel recommendation to adopt a more agressive inspection schedule, and specifically to complete excavation and inspections by EOY 2008, the IP2 AFW lines 1505, 1509 and overflow line were excavated and inspected at 2 locations in Nov 2008. While there was some pipe coating degradation observed, there was no evidence of external corrosion. UT determination of the pipe wall thickness at the areas of degraded coating degradation showed that the pipe wall was at least greater than 87.5 % of the nominal pipe wall. These findings were consistent with the assessments which established the inspection priority for these lines.
The Failure analysis of the section of removed pipe from Line 1509 containing the through wall failure, and extent of condition review are documented under CR-IP2-2009-00666 CA # 4.
As part of extent of condition, additional guided wave inspection of Lines 1505 and 1509 will be performed by September 2009, as follows:
IP2 8" (Line 1509) Condensate Return Line in the excavated area in the FRY Room. (CR-IP2-2009-00666 CA #21)
IP2 12" (Line 1505) Condensate Supply Line in the excavated area in the FRY Room. (CR-IP2-2009-00666 CA #22 )
IP3 12" Condensate Supply Line outside the Auxiliary Feedwater Pump Building where it goes underground.
IP3 8" Condensate Return Line outside the Auxiliary Feedwater Pump Building where it exits the ground.
The results of the above additional inspections will be evaluated by PCE and used to adjust the (EN-DC-343 specified) 8 year interval for subsequent inspections, as appropriate.
bresponse:
Entergy Closure Comments:
1 CORRECTIVE ACTION ICR-IP2-2008-047S4
En CORRECTIVE ACTION CR-IP2-2008-047S4 CANumber: 6 Site Group Name Assigned By: IP2 CAA Mgmt IP2 Donnelly,John M Assigned To: IP2 P&C Eng Codes Mgmt IP2 Azevedo,Nelson F Subassigned To:
Originated By: Reynolds,Joseph A 5/1412009 1O:55:07 Performed By: Azevedo ,Nelson F 5127/2009 09: 19: 17 Subperformed By:
Approved By:
Closed By: Reynolds,Joseph A 51271200909:33:54 Current Due Date: 06/04/2009 Initial Due Date: 06/0412009 CA Type: CR CLOSURE REVIEW Plant Constraint: #NONE CA
Description:
Periodic Review CA Please note, this CAT C CR has been open approximately greater than 6 months and therefore requires a periodic review per attachment 9.8 of EN-U-l02. Ensure attachment 9.8 (attached) is completed. Review and complete the Long Term 9.9 form if appropriate. Both forms are required if the CR is classified as a Long Term CR.
In accordance with EN-U-I 02, Corrective Action Process, section 5.8 [5] (a) and/or (b) a periodic review of the CR is needed to assure the timeliness challenges for the issue resolution are understood, the impact to plant operations under the present plant conditions as well as the continued risk imposed by the action remaining open are acceptable, the repair priority is appropriate and the administrative CA processing expectations have been performed as expected thus far for the CR (i.e.
CARB approvals, Extensions approved by correct level of management, etc).
As the CR owner, please review the Condition Report lAW EN-U-l 02 section 5.8 [5] (a) (I) through (7) and document the resolution to the procedure discussion points. Attachment 9.8 to U-102 (a form) is available from the CA&A webpage to assist in the review.
IF your review determines the CR should also be reclassified as a Long Term CR, ensure the information requested in attachment 9.9 to U-102 (another form available via the CA&A webpage) is captured in the CA response. Reclassifying the CR as long term (if appropriate) lengthens the periodic review to annually.
For all cases, U-102 requires the Director or GMPO level position (or higher) that approved/acknowledged the acceptability of the periodic review conclusions to be documented.
Document the results of the periodic review in the response to this new CA. If used, attach the completed CR periodic review form (U-102 - attachment 9.8) to the response section of this CA.
Remember the Long Term classification only applies if the restriction to completing the task involves one of the following fo ur planUprocess restrictions. (1) A Modification or Design Change must be completed to resolve the action, (2) More than one training cycle is required to complete the action, (3) Outs ide Regulator Agency (NRC, etc) approval is required to complete the action, (4) a Forced Outage or Refueling Outage or FEG week of sufficient duration is required to establish plant conditions to complete the action.
Response
All CAs from this CR are now closed and no additional corrective actions are required at this time. Therefore, this evaluation is no longer required since this CR is now ready for closure.
Entergy CORRECTIVE ACTION CR -IP2-2008-047 54 Closure Comments:
Per CAA review, noted the CR owner recommended and approved the closure of the CR (this was verified via verbal communication with respondent by the CAA reviewer). Therefore this interim review action is no longer needed and was closed. CAA changed the CA type to closure review and updated the trend codes to reflect the status of the review. Then this completed action closed.
Attachments:
Ca Description Periodic review form I
I