ML12276A478

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Entergy Pre-Filed Evidentiary Hearing Exhibit ENT000577, LO-IP3LO-2012-00134, Underground Piping & Tanks Inspection & Monitoring Program Self Assessment (Sept. 14, 2012)
ML12276A478
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 09/14/2012
From: Townley B
Entergy Nuclear Operations
To:
Atomic Safety and Licensing Board Panel
SECY RAS
References
RAS 23566, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01 LO-IP3LO-2012-00134
Download: ML12276A478 (27)
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Text

ENT000577 Submitted: October 2, 2012

--- .....--- Entergy INDIAN OINT ENERGY SNAPSHOT SELF-ASSESSMENT REPORT LO-IP3LO-2012-00134 Department: Engineering Till : Underground Piping & Tanks Inspection & Monitoring Program Self Assessment Prepared By:

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Joe M. Abis8mra. Corporate Center Chid Engineer

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INDIAN POINT ENERGY CENTER SNAPSHOT SELF-ASSESSMENT REPORT LO-IP3LO-2012-00134 Department: Engineering

Title:

Underground Piping & Tanks Inspection & Monitoring Program Self Assessment Prepared Reviewed By:

IPEe ENGINEERING SNAPSHOT SELF-ASSESSMENT REPORT UNDERGROUND PIPING & TANKS INSPECTION AND MONITORING PROGRAM LO-IP3LO-2012-00I34 June 19 - June 21, 2012 TABLE OF CONTENTS SECTION PAGE

1. SCOPE 3
2. OBJECTIVES 3
3. EVALUATION 5 3.1 Objective 2.1 5 3.2 Objective 2.2 7 3.3 Objective 2.3 8 3.4 Objective 2.4 8 3.5 Objective 2.5 9 3.6 Objective 2.6 9 3.7 Objective 2.7 11 3.8 Objective 2.8 12 3.9 Objective 2.9 13 3.10 Objective 2.10 13 3.11 Objective 2.11 21 3.12 Objective 2.12 21 3.13 Objective 2.13 21
4. CONCLUSIONS 22
5. REFERENCES 24
6. IPEC INDIVIDUALS INTERVIEWED 26
7. ASSESSMENT TEAM MEMBERS 26
8. COMMUNICATION PLAN 26

IPEC ENGINEERING SNAPSHOT SELF-ASSESSMENT REPORT UNDERGROUND PIPING & TANKS INSPECTION AND MONITORING PROGRAM LO-IP3LO-2012-00134 June 19 - June 21,2012

1. SCOPE The objective of this self-assessment is to assess the site's Underground Piping & Tanks (UPT) Inspection and Monitoring Program health, corrective action, inspections, mitigation, long range plans, operating experience, and related engineering/plant support. This assessment is in preparation for the upcoming NRC audit in accordance with TI 25151182 (ref 5.17).

For consistency with program procedures, this assessment will refer to Buried Piping and Tanks as piping and tanks that are below grade and in direct contact with the soil (i.e. directly buried) or concrete (e.g. a wall penetration or embedded in concrete).

For consistency with program procedures, this assessment will refer to Underground Piping and Tanks as piping and tanks that are below grade and that mayor may not be in direct contact with soil or concrete.

This includes piping and tanks that are directly buried and those that are embedded in concrete or located in underground concrete vaults, tunnels, or guard pipes.

2. OBJECTIVES The assessment will address the following specific key areas:

2.1 Assess whether the site has successfully completed (andlor will successfully complete) the commitments described in NEI 09-14 Rev. 1 Sections 3.3 A and B.

2.2 Evaluate adequacy of completed Training and Qualifications for the program owner and his/her back-up engineer. The UPT Program Engineer and his back-up engineer must have gained a general knowledge of CP, FAC and MIC.

2.3 Evaluate via interviews the adequacy and frequency of interface with other organization personnel and areas including:

  • Microbiologically Influenced Corrosion (MIC) Program Engineer
  • Cathodic Protection (CP) System Engineer
  • EPIX Reporting Engineer
  • Systems Engineers

'-<,,-,vue,,_ Renewal Responsible ,--,"!",HAv,",A

IPEe ENGINEERING SNAPSHOT SELF-ASSESSMENT REPORT UNDERGROUND PIPING & TANKS INSPECTION AND MONITORING PROGRAM LO-IP3LO-20I2-00I34 June 19 - June 21, 2012 2.4 Assess the general health of the UPT Inspection and Monitoring Program by reviewing program performance indicators, program notebook accuracy, database accuracy and control, risk ranking criteria utilized and risk ranking periodic updates. Ensure recommended fleet software (MapPro) is used.

2.5 Ensure the Program Health Report is comprehensive and is consistent with the Systems Health Reports.

2.6 Assess whether the site has confirmed the as-built location of underground piping and tanks at the plant. Ensure scoping methodology and scope is comprehensive and no underground components were omitted without justification. Review a sample of the as-built drawings that were assembled showing the route of underground pipes, including their locations relative to other underground structures and components and above ground buildings.

2.7 Assess the adequacy of the Cathodic Protection System. Ensure recent surveys have been conducted by NACE qualified personnel and will continue to be conducted on an annual basis. Review CP System health report as well as system Preventive Maintenance (PM) implementation and frequency.

Review the maintenance PM backlog associated with the CP System to ensure required PMs are not being routinely deferred. Review justification if installed CP system is ineffective or partially functional, and if no CP System is currently installed. Ensure CP system upgrade is scheduled and funded as needed.

2.8 Review inspection plan. Ensure plan supports NEI commitment dates. Review applied grouping methodology (including documented justification) and inspection schedule (including issued work orders) to assure that condition assessment is completed by 06/30/2013 for radiological buried piping in direct contact with soil and 06/30/2014 for radiological underground piping not in direct contact with the soil.

2.9 Review as a minimum one recent inspection of underground pipe or tank. Review utilized inspection technique, fitness for service evaluation, adequacy of planned re-inspection, adequacy of the coating inspection including inspector qualification, availability of photographic records, documentation of backfill type, etc. Ensure identified degraded conditions were documented in PCRS.

2.10 Review the corrective action database for CRs associated with the program and initiated on or after 0110112009. Specifically, trends, repeating themes and the length of time required to accomplish corrective actions. Keywords such as "Underground" and "Buried" may be used for the search.

11 Assess whether the site displays senior level accountability for the UPT Inspection and Monitoring accountability by the necessary resources and

IPEC ENGINEERING SNAPSHOT SELF-ASSESSMENT REPORT UNDERGROUND PIPING & TANKS INSPECTION AND MONITORING PROGRAM LO-IP3LO-2012-00I34 June 19 - June 21, 2012

3. EVALUATION 3.1 Objective 2.1:

Assess whether the site has successfully completed (or will successfully complete) the commitments described in NEI 09-14 Rev. 1 Sections 3.3 A and B.

NEI Commitments:

Note: Unless explicitly stated the STATUS column entries apply to both Indian Point Units 2 & 3.

Buried Piping &Tanks Inspection & Monitoring Program (for the initial scope per the NSAIC Initiative 11/2009)

ACTION DIJEDATE STATUS Develop Procedures and Oversight 06/3012010 Complete Complete Risk Ranking of Buried Piping 12/3112010 Complete Develop Inspection Plan 06/3012011 Complete Begin Inspection Plan Implementation 06/3012012 Complete Complete Inspections and Assess Condition of Buried 06/3012013 Started Piping Containing Radioactive Material Obtain Asset Management Plan Approval 12/3112013 Not Started Underground Piping &Tanks Inspection & Monitoring Program (for the added sco e er the new NSAIC Initiative 09/2010)

ACTION DUE DATE STATUS 12/3112011 Corn lete 06/3012012 Corn lete 12/3112012 Corn lete Not Started (IP 2)

Begin Inspection Plan Implementation 06/3012013 Started (IP 3)

Complete Inspections and Assess Condition of

IPEe ENGINEERING SNAPSHOT SELF* ASSESSMENT REPORT UNDERGROUND PIPING & TANKS INSPECTION AND MONITORING PROGRAM LO-IP3LO-2012-00134 June 19 - June 21, 2012

  • Buried - Risk Ranking by 12/31110 o Risk ranking was performed in accordance with fleet program section CEP-BPT-0100 using a standard template (Attachment 9.4 of EN-DC-343 Rev 0). The ranking was documented in the response to LO-HQNLO-200S-0015 CA-17 on S/14/0S. This meets the NEI milestone date. All radioactive lines were initially ranked as High Priority. These radioactive lines were further ranked among each other via references 5.S and 5.20.
  • Buried - Inspection Plan by 6/30/11 o SEP-UIP-IPEC "Underground Components Inspection Plan" was reviewed, approved and issued on 512/11. This document was attached to the response to LO-HQNLO-200S-00015 CA-204 completed on 512/11. This document is archived and available in Reference Library (RefLib).

o A review of SEP-UIP-IPEC Rev. 0 (the current revision in eB) indicates that the list of lines is thorough and that many of the details associated with the lines are contained in the SEP.

However an integrated inspection schedule has not been added to the document to clearly summarize all inspections required to meet upcoming NEI milestones. Rev. 1 of the document is currently being developed by the program owner and Appendix G should be revised to clearly identify components scheduled for inspection to meet the requirements of NEI 09-14.

o Review of the Appendix B for the tank inspection document indicates a considerable number of tanks that sit on top of the ground are currently contained in the inspection plan. The NEI Task Force recently ruled that tanks that sit on top of the ground do not need to be within the Buried or Underground Pipe and Tanks scope. Additionally Appendix C of the SEP includes many sumps, which are also not mandated by NEI 09-14. Recommend that corporate engineering remove all sumps and all tanks that sit on top of the ground from the UPT scope.

Negative Observation:

LO-IP3LO-2012-00134 CA-3 SEP-UIP-IPEC needs to be updated to ensure NEI 09-14 inspection requirements are being met.

The document should be revised to include additional scope and ensure groupings are addressed in the tone of meeting the NEI 09-14 objectives.

Negative Observation:

LO-IP3LO-2012-00134 CA-4 Corporate Engineering to determine long-term plan

IPEe ENGINEERING SNAPSHOT SELF-ASSESSMENT REPORT UNDERGROUND PIPING & TANKS INSPECTION AND MONITORING PROGRAM LO-IP3LO-20I2-00134 June 19 - June 21, 2012 this milestone date. However, SEP-UIP-IPEC need to be revised to include this more up-to-date information.

  • Buried - Asset Management Plan by 12/31/13 o Not started.
  • Underground Non-Buried - Procedures and Oversight by 12/31/11 o EN-DC-343 rev 4, "Buried Piping and Tanks Inspection and Monitoring Program" was issued for use by the Entergy fleet on 05/1612011. This revision incorporates the requirements of NEI 09-14 Rev 1.

o CEP-BPT-0100 was replaced by CEP-UPT-OlOO on 10128/11. The new CEP addresses both underground and buried piping in accordance with rev 1 of NEI 09-14. This meets the NEI due date requirement.

  • Underground Non-Buried - Prioritization by 6/30/12 o The risk ranking for radioactive piping that fall into this category was completed via reference 5.20.
  • Underground Non-Buried - Plan Implementation shall start by 6/30/13 and condition assessment of radioactive piping complete by 6/30/14.

o Review of SEP-UIP-IPEC inspection plan does not identify any radioactive underground non-buried piping.

o The initiative inspection milestone of 6/30/13 has been met for IP3 with the completed inspection of safety-related service water piping located in a limited access concrete pipe tunnels (Mar. 2011).

o The initiative inspection milestone of 6/30/13 will be met for IP2 with the upcoming inspections of safety-related, non-radioactive EDG fuel oil piping in a limited access pipe chase (2Q2013).

  • Underground Non-Buried - Asset Management Plan by 12/31/14.

o Not started 3.2 Objective 2.2:

IPEC ENGINEERING SNAPSHOT SELF-ASSESSMENT REPORT UNDERGROUND PIPING & TANKS INSPECTION AND MONITORING PROGRAM LO-IP3LO-2012-00134 June 19 - June 21, 2012 3.3 Objective 2.3:

Evaluate via interviews the adequacy and frequency of interface with other organization personnel and areas including:

Interviews were conducted with the following personnel:

  • F AC Program Engineer
  • MIC Program Engineer
  • CP System Engineer
  • E-FIN/Coatings Engineer
  • Ground Water Prevention Program Specialist
  • Spill Prevention Control and Countermeasure (SPCC) Program Owner.
  • Design Engineering Personnel
  • Project Management Organization Most interviewees demonstrated a good level of understanding for the UPT program, were able to define their level of responsibility and recognize the needed communication and engagement.

3.4 Objective 2.4:

Assess the general health of the Underground Piping and Tanks Inspection and Monitoring Program by reviewing program performance indicators, program notebook accuracy, database accuracy and control, risk ranking criteria utilized and risk ranking periodic updates. Ensure recommended fleet software (MapPro) is used.

  • The Program Health Report is currently graded WHITE for the 1st Quarter 2012. There are 3 GREEN performance areas: Personnel, Infrastmcture and Implementation; and 1 YELLOW performance area: Equipment Related Plant Performance. Equipment Related Plant Performance area is YELLOW pending completion of corrective actions associated with the Feb 2009 failure of the AFW Pump return line to the CST (open Cat A CR). The remaining actions are related to Cathodic Protection restoration, which is being addressed by Objective 2.7.
  • The Program Notebook is contained in electronic documents and a collection of three ringed binders containing programs scope and inspection reports. A review of the content found the notebook to be current and well maintained. Program Notebook its current form meets the requirement of EN-

IPEe ENGINEERING SNAPSHOT SELF-ASSESSMENT REPORT UNDERGROUND PIPING & TANKS INSPECTION AND MONITORING PROGRAM LO-IP3LO-2012-00134 June 19 - June 21, 2012 Positive Observation:

IPEC's acquisition of the MapPro software and risk ranking conversion to MapPro database is considered a positive observation Negative Observation:

LO-IP3LO-2012-0134, CA-5 Neither MapPro nor the risk ranking in the MapPro database could be electronically reviewed because the Program Owner has a software problem loading MapPro on his computer that has not been resolved.

3.5 Objective 2.5:

Ensure tbe Program Health Report is comprehensive and is consistent with the Systems Health Reports

  • In the area of PMs and Surveillance Tasks in the Underground Piping and Tanks (UPT) health report, the report states that installed cathodic protection (CP) systems are operational and functioning properly. However, a review of the CP System Health Report indicated there are a majority of protective potentials that do not meet the criteria needed for adequate protection. Some areas of the plant are reported as having 80% of the anodes needing replacement. SIPD 573 states that all of the IP3 CP system was removed in the mid 1980's and has not been replaced to date (see write-up on Objective 2.7 for more information on cathodic protection).

Based on the above, there are some inconsistencies with the reported health of the CP system as described in the UPT health report. The health of the Cathodic Protection System is discussed further under objective 2.7.

Negative Observation:

LO-IP3LO-2012-00134 CA-6 The Underground Piping & Tanks and Cathodic Protection System health reports are not consistent in reporting the current health of the Cathodic Protection System. Determine why the System Health Report for Cathodic Protection is Yellow and the Underground Pipe and Tank Health report shows CP as white.

IPEC ENGINEERING SNAPSHOT SELF-ASSESSMENT REPORT UNDERGROUND PIPING & TANKS INSPECTION AND MONITORING PROGRAM LO-IP3LO-2012-00134 June 19 - June 21,2012 2008-00015 CA-361 requested the action to confirm the program scope to include all underground (see item 1, below) radiological piping, tanks and sumps. These revisions included the following changes to the program scope and risk ranking:

1) Scope to include all radiological underground piping in direct contact with soil or concrete, or encased in an outer pipe in direct contact with soil, or in a pipe vault, chase or tunnel.
2) Piping that was not designed to contain radioactive fluids, but are known to contain low level radioactivity by reason of cross contamination were assigned a HIGH inspection priority.
3) Piping that contained Fuel Oil and Hydrogen Gas were ranked as a minimum, MEDIUM inspection priority. Safety-related EDG fuel oil piping was assigned HIGH inspection priority due to its safety related function, and was not affected by this revision.

Based on the associated reviews of the original risk ranking per EN-DC-343 and the subsequent review of the Risk Ranking performed under CA-361 and CA-346. An additional, subsequent review of the risk ranking was performed under LO-HQNLO-2008-0015, CA-264.

  • Additional assurance that all underground piping has been captured in the UPT program database is a risk ranking of IPEC underground piping that was performed by Structural Integrity Associates (SIA) utilizing the MapPro software. The development of an integrated IPEC site underground piping program scope was performed utilizing IPEC drawings, piping specifications and system descriptions, supplemented by onsite interviews with IPEC system engineers (ref. 5.23). These interviews were conducted on phased schedule (2 site visits by SL.t\) to ensure the individual system engineers were available and to allow for opportunities for interim and final reviews by IPEC staff.
  • To verify that the plant drawings reflected the as-built piping configuration, 2 excavations were reviewed:

IP2 SW piping, excavated and inspected under WO 279576 (Dec. 2011).

The footprint of this excavation uncovers 24-inch SW Lines 408 and 409,26 Circulating Water Pump 84-inch discharge piping to 23 main condenser, it's associated 30-inch riser to access point at grade, and a 2-inch station air line from the turbine building to the intake structure. The plant drawings for these piping sections (9321-F-2700 for service water, 9321-F-2011, 9321-F-I106 for circulating water, and 9321-F-2113 for station air) were reviewed against the photos attached to the inspection reports, confirming the piping configuration, elevations, orientations and locations to one UU'JLU'vL were

[PEe ENGINEERING SNAPSHOT SELF-ASSESSMENT REPORT UNDERGROUND PIPING & TANKS INSPECTION AND MONITORING PROGRAM LO-IP3LO-20I2-00134 June 19 - June 21, 2012 3.7 Objective 2.7:

Assess the adequacy of the Cathodic Protection System. Ensure recent surveys have been conducted by NACE qualified personnel and will continue to be conducted on an annual basis. Review Cathodic Protection System health report as well as system P~I implementation and frequency.

Review the maintenance PM backlog to ensure required PMs are not being routinely deferred.

Review justification if installed CP system is ineffective or partially functional, and if no Cathodic Protection System is currently installed. Ensure CP system upgrade is scheduled and funded as needed.

  • An October 2008 survey for the Cathodic Protection System (ref 5.1) has been conducted on-site by PCA Engineering Inc. (NACE qualified personnel) to determine the condition of the existing Cathodic Protection system, and provide recommendations for repairs andlor system upgrades.

Several of the structure-to-soil potential measurements obtained did not satisfy the NACE criteria (-850 mill volt potential). Corrective actions are to be taken including installing impressed current systems by EC 13314, EC 25391, and EC27604. These new Cathodic protection installations are also based on the results of 2009 guided wave inspection results.

  • An additional Cathodic Protection (CP) Area Potential Earth Current (APEC) indirect inspection of the buried piping was performed by Structural Integrity Associates, Inc. (SI) in November 2010 for both IP2 and IP3 (ref 5.2). The inspection identified that several areas are not receiving adequate protection and a targeted increase in Cathodic Protection current combined with anode replacements was recommended. The APEC survey states that only 16% of the inspected areas are receiving adequate CP to ensure corrosion control based on the 100 millivolt polarization.
  • Per the program owner, the IPEC site is built on rock, and therefore, installing a deep well anode type cathodic protection system is not feasible and would not be effective. For this reason, the feasibility of providing new cathodic protection for buried piping is assessed on a specific system by system basis. Further, some buried piping systems, such as the buried portions of the IP3 supply and return lines from the CST to the AFW Pumps may be configured in a rock trench, which may limit the effectiveness of a (new) cathodic protection system.
  • Indian Point has accomplished some additional guided wave inspections to help determine pipe health and has installed additional CP on City Water and the Condensate Storage Tank supply water

IPEC ENGINEERING SNAPSHOT SELF-ASSESSMENT REPORT UNDERGROUND PIPING & TANKS INSPECTION AND MONITORING PROGRAM LO-IP3LO-2012-00134 June 19 - June 21, 2012

  • The following CRs serve as examples of the past and current issues that have been identified with the Cathodic Protections system.

-CR-IP2-2009-01812 There is a continuing delay for an implementation of corrective actions, as outlined in the Top Ten Issue Plan for the Cathodic Protection (SYS-APL-06-003, Revision 6 dated 1112512008) and CR-IP2-2005-03902, to restore the Cathodic Protection System. (Closed, 7/812009)

- CR-IP2-2009-03193 IP2 Cathodic Protection project turned to "Yellow" status because of funding issues. (Closed, 9/112009)

- CR -IP2-2011-04902 There is a declining trend in potentials on the Unit 2 Dock Sheet Piling cathodic protection system. (Open; subsequently closed 7125/2012)

CR-IP2-2011-06517 The Unit 2 Cathodic Protection System (CPS) for the CST Supply and Return Piping (EC-25391) was designed with a power source that is not continuously energized.

(Open; subsequently closed 8/13/2012)

- CR-IP3-2012-01273 CST Piping Cathodic Protection System was not able to achieve satisfactory potentials. (Open)

CR-IP3-2012-01273 CST Piping Cathodic Protection System was not able to achieve satisfactory potentials. (Open)

The above CR's provide evidence that the currently installed cathodic protection systems are being monitored.

Area for Improvement CR-IP3-2012-05297 Indian Point should perform a comprehensive assessment of all buried piping systems cathodic protection requirements and identify what piping is required to be protected by CP and provide a long-term funding plan for installation. For piping that do not require CP, or for which a CP system may not effective in providing NACE recommended protection levels, technical justification should be

IPEC ENGINEERING SNAPSHOT SELF-ASSESSMENT REPORT UNDERGROUND PIPING & TANKS INSPECTION AND MONITORING PROGRAM LO-IP3LO-20/2-00134 June 19 - June 21, 2012 3.9 Objective 2.9:

Review as a minimum one recent inspection of underground pipe. Review utilized inspection technique, fitness for service evaluation, adequacy of planned re-inspection, adequacy of the coating inspection including inspector qualification, availability of photographic records, documentation of backfill type, etc. Ensure identified degraded conditions were documented in PCRS.

The inspection performed in December 2011 of two 24" service water lines was reviewed and everything was accomplished in accordance with site and corporate procedures. The lines were excavated due to a modification and the dig site was enlarged to ensure additional opportunistic inspections were accomplished. The lines were inspected by the program owner and by the site coating expert, who works in the EFIN department. The inspection folder was thorough and contained all of the required documents including good digital photo documentation. Many of the dig locations include soil sampling, which is a good practice. The results of this sampling should be factored back into the buried pipe model to see if the risk analysis should be updated.

Good Practice:

1. Independent on-site coating specialist involvement with the buried pipe inspections strengthens the program and helps ensure coatings are assessed properly.
2. Soils sampling is a good practice when accomplishing digs for piping inspections.

A review of the total number of inspections accomplished at IPEC found that the site is ahead of the fleet when accomplishing buried pipe inspections. The site is digging up various locations to directly inspect and accomplish guided wave inspections to supplement the inspection. The site appears to be near completion on some of the NEI inspection objectives.

Positive Observation:

The number of inspections accomplished at IPEC is larger that that of the rest of the fleet. This helps ensure the NEI 09-14 inspection requirements will be met.

3.10 Objective 2.10:

Review the corrective action database for CRs associated with the program and initiated on or after 01101/2009. Specifically, trends, repeating themes and the length of time required to accomplish corrective actions. Keywords such as "Underground" and "Buried" will be used for the search.

IPEC ENGINEERING SNAPSHOT SELF-ASSESSMENT REPORT UNDERGROUND PIPING & TANKS INSPECTION AND MONITORING PROGRAM LO-IP3LO-2012-00134 June 19 - June 21, 2012 CR # &

SUMMARY

RESOLUTION CR -IP2-2009-04751 Closed on 512712010, based on following:

The initial Program Indicator for the IPEC (1) Assigned Backup for IPEC Buried Piping &

Buried P~ing & Tank Program was issued Tank Program completed Qual card, FTK-ESPP-for the 3r Qtr 2009, and the overall 000121, "Buried Piping & Tank Program Owner".

program color is YELLOW. (2) Piping leak (CR-IP2-2009-00666, Cat A)

Discovered on 1111612009. passing thru IP2 cycle of operation. This is a required action to clear RED monitored parameter under Buried Piping Program Performance Indicator, and returned the Program health to WHITE.

CR -IP2-2010-0003 9 Closed on 412012012. SW cooled HX copper alloy Service water cooled copper alloy heat tubes were pulled and evaluated. Metallurgic exchangers and safety related underground laboratory reports were analyzed by P&C large bore service water system piping are engineering and chemistry departments. SIPD #'s degrading because of corrosion. added to Service Water System Long Range Plan.

Discovered on 1I04120lO. HX replacement approved.

CR- IP2-20 11-05392 Closed on 212912012. Piping is being monitored Leak on 2" line found in 63' pipe chase. within the underground and buried piping program.

There are several print discrepancies. Drawings were revised to show correct piping Discovered on 10127/2011. arrangement.

Note: this piping is part of the IPI Integrated Liquid Waste Handling System, which is an active IPI s stem, su ortin IP2 waste rocessin .

CR -IP2-2011-06248 Closed on 12/1412011. Review of this CR included As-Found visual inspections of the OD in review of CR-IP2-2011-06250.

coating on excavated SW Lines 408 & 409 piping were performed under the IPEC Buried Piping Program. Various locations where the coating system had failed or possibly mis-applied were found.

Discovered on 12/0812011.

CR-IP2-2011-06250 Closed on 112712012. The UT pipe inspections

IPEC ENGINEERING SNAPSHOT SELF* ASSESSMENT REPORT UNDERGROUND PIPING & TANKS INSPECTION AND MONITORING PROGRAM LO*IP3LO*2012*00134 June 19 - June 21, 2012 CR # & SUMlVIARY RESOLUTION CR-IP2-2012-00401 Open. CA-6 is tracking revision to SEP-UIP-IPEC.

During the preparation of rebuttal testimony for the IPEC license renewal contention on buried piping it was discovered that information provided to the NRC as part of the IPEC license renewal application review contains an error.

Discovered on 11212012 CR-IP2-2012-03094 Closed on 512112012 to CR-IP2-2012-00401 A potential discrepancy was found during the review of NRC testimony for the NYS-5 contention on buried piping that the testimony prepared by Entergy for the same contention did not include the circulating water system on IP2 as being in the scope of Buried Piping and Tanks Inspection program for license renewal.

Discovered on 4/3012012 CR -IP3-2009-01269 Closed on 411412009. 3PT -V032T was performed following a request from the NRC SAT under WO # 00167914-01 on 3/31/09.

Resident Inspector as to the scheduled date for 3PT-V32T, Underground Condensate Piping Pressure decay test, it was determined that the test originally scheduled under WO 51560204 for 3R15 was now in 3R16 under WO 167914.

Discovered on 312512009 CR-IP3-2009-01530 Closed on 41212009. The trend code KW-Outage The underground inspection of 24" line 408 lessons learned was applied to the CR under work order 00133291-01 has experienced considerable delays due to training and safety issues.

Discovered on 4/1/2009.

IPEe ENGINEERING SNAPSHOT SELF-ASSESSMENT REPORT UNDERGROUND PIPING & TANKS INSPECTION AND MONITORING PROGRAM LO-IP3LO-2012-00134 June 19 - June 21, 2012 CR # &

SUMMARY

RESOLUTION CR-IP3 -2009-01547 Closed on 4/2/2009. Closed to related CR IP3-A remote robotic crawler inspection 2009-01538. Engineering judgment is that this identified a piping connection of could have been a hydrostatic test connection indeterminate size in this line that is not used during original plant construction before the shown on plant design drawings (9321-F- piping trench containing 10"- Line #1099 was filled 27223, 9321-F-22363, and 9321-F-22573 lll.

Sh. 1). Discovered on 41112009 CR-IP3-2009-0 1551 Closed on 4/2/2009. Closed to related CR IP3-A remote robotic crawler inspection was 2009-01538. The conditions found via the visual performed of U3 underground Service robotic crawler inspections have been established Water Line 10"-#1099 under WO over the course of plant operation and are 00133288-01 in 3R15. The inspection acceptable as-is.

identified small debris and concrete pieces in various locations on the bottom of the ipin . Discovered on 4/1/2009 CR-IP3-2009-01552 Closed on 4/2/2009. Closed to related CR IP3-A remote robotic crawler inspection was 2009-01538. UT was performed of this location performed of U3 underground Service (weld # CB-49) during 3R15. The inspection results Water Line 10"-#1099 under WO were documented in NDE Report # IP3-UT 00133288-01 in 3R15. The inspection 049.

identified internal corrosion, possibly galvanic in nature, and some resulting minor ID flow restriction, at the flanged joint connecting 3 "-Line # 1224 (6% moly stainless steel) and lO"-Line #1099 (cement-lined carbon steel). Line 3"-#1224 is the 32 CCRAC supply line.

Discovered on 4/1/2009 CR-IP3-2009-02150 Closed on 5/1812009 and condition corrected.

The Site CAP Performance Index indicator CARB extended by site Vice President.

of "Number of CAT AlB Evaluations> 30 days" was red for March 2009 with a value of 1. This was as a result of the Root 2

IPEC ENGINEERING SNAPSHOT SELF-ASSESSMENT REPORT UNDERGROUND PIPING & TANKS INSPECTION AND MONITORING PROGRAM LO-IP3LO-20I2-00134 June 19 - June 21, 2012 CR # &

SUMMARY

RESOLUTION CR-IP3-2010-01829 Closed on 6129/2010 to track/trend.

Test 3-PT-A029D "Underground Fuel Storage Tank Leak Test For TSC Diesel Generator" could not be performed today as scheduled.

Discovered on 6/2212010 CR -IP3-2010-01984 Closed on 1124/2011. Vendor made aware of A vendor was brought in to perform ARDG errors. IP-CALC-II-00003 (attached) was created fuel oil tank testing in accordance with 3- and processed under EC 26718.

PT-A029E. The paperwork obtained from the vendor today was incomplete, and appears to include one or more math errors.

Discovered on 7/612010 CR-IP3-2010-01985 Closed on 81212010. System engineering evaluated Because of the inability to sound the tank the issue and WO 00157666-02 was updated to directly, LIS-807 was used to determine the provide better guidance.

level of fuel oil in the tank during 3PT-A029E, UNDERGROUND FUEL STORAGE TANK LEAK TEST FOR APPENDIX R DIESEL.

Discovered on 7/612010 CR -IP3-2010-02680 Closed on 912212010. Closed to work order During performance of 3-PT-A029B, "32 00251332.

EDG underground tank test" functional test of LI-1134 revealed LI-1134, 32 EDG FOST level indicator reads about 200 gallons lower than actual level determined by sticking the tank Discovered on 9/912010 CR -IP2-2009-00666 Open. CARB review based on this CR required CST return line cracked and leaking. Cathodic Protection to be installed on the 12" CST Discovered on 2/1512009 line to the suction of the AFW pumps at both IP2 and IP3 and the SW supply line 408 by the ard at IP2.

IPEC ENGINEERING SNAPSHOT SELF-ASSESSMENT REPORT UNDERGROUND PIPING & TANKS INSPECTION AND MONITORING PROGRAM LO-IP3LO-2012-00134 June 19 - June 21, 2012 CR # &

SUMMARY

RESOLUTION CR-IP2-2009-01812 Closed on 7/812009. Scope of work was There is a continuing delay for an understood. Funding was requested in 2010 implementation of corrective actions, as budget.

outlined in the Top Ten Issue Plan for the Cathodic Protection (SYS-APL-06-003, Revision 6 dated 1112512008) and CR-IP2-2005-03902, to restore the Cathodic Protection System.

Discovered on 5/19/2009 CR-IP2-2009-03050 Closed on 8/31/2009. City water flow testing Work Order 00176884 performs this flow requirements have been established and a new test (required as a CA to CR-IP2-2008- testing document has been written and attached to 5499) by recording the flow at a beginning WO 00176884 tasks 4, 5 and 6.

point and an end point of the City Water line-essentially a flow balance. This test, however, does not have any explicit acknowledgement that the test results are satisfactory or unsatisfactory.

Discovered on 8/512009 CR-IP2-2009-03193 Closed on 9/1/2009. Funding was approved and The IP2 Cathodic Protection project has project was put back on track.

been turned to "Yellow" status Discovered on 8/13/2009 CR -IP2-2010-02996 Closed on 412212010. Closed to work order During System Engineering walkdown it 52243923 was found that the output for Unit 1 Dock Cathodic Protection Rectifier #11 is indicating zero amps Discovered on 4/2012010 CR-IP2-2010-04570 Closed on 7/1912010. Closed to actions taken During Cathodic Protection walkdown by (Minor Work Request completed).

System Engineering it was identified that the circuit breaker for Sheet Piling Rectifier

IPEC ENGINEERING SNAPSHOT SELF-ASSESSMENT REPORT UNDERGROUND PIPING & TANKS INSPECTION AND MONITORING PROGRAM LO-IP3LO-2012-00134 June 19 - June 21, 2012 CR # &

SUMMARY

RESOLUTION CR-IP2-2011-03185 Closed on 6/3012011. Closed to work order During System Engineering walkdown it 00282665.

was identified that the City Water Cathodic Protection Rectifier output is zero.

Discovered on 612812011 CR-IP2-2011-03606 Closed on 111912012. This action was closed to During System Engineering walkdown it WO 293242-01, to replace the failed circuit card was identified that the City Water Cathodic and install the additional enhanced surge Protection Rectifier has no output while in protection.

potential mode Discovered on 7/2112011 CR-IP2-2011-04902 Open. Over time anode strings are expected to The annual cathodic protection survey of degrade. WO 293976 scheduled to take anode the Unit 2 Dock Sheet Piling has shown a current measurements.

declining trend in north end waterside protective potentials Discovered on 10/312011 CR-IP2-2011-06517 Open. ECNs for the CPS modifications have been The Unit 2 Cathodic Protection System initiated as follows: ECN-33659 (EC-25391), ECN-(CPS) for the CST Supply and Return 33661 (EC-27604) and ECN-33807 (EC-28270).

Piping (EC-25391) was designed with a They will correct the legacy drawing errors and power source that is not continuously modify the CPS design to provide a continuously energized. energized power source.

Discovered on 12/2212011 CR -IP2-2012-01369 Closed on 3/612012. Component was covered and During System Engineering walkdown it CR was closed with actions taken.

was identified that the CST Cathodic Protection Rectifier is being filled with moisture Discovered on 3/5/2012 CR-IP2-2012-02691 Closed on 6/1412012. Drawings were updated per The drawings (254036, 253952 and ADM EC-37019 to reflect field found condition.

253953) for the Unit 1 Dock Cathodic P' lIOn not conditions Discovered on 4110/2012

IPEe ENGINEERING SNAPSHOT SELF-ASSESSMENT REPORT UNDERGROUND PIPING & TANKS INSPECTION AND MONITORING PROGRAM LO-IP3LO-20I2-00I34 June 19 - June 21, 2012 CR # &

SUMMARY

RESOLUTION CR-IP3-2012-01273 Open. The extent of cathodic protection on the During post modification testing (WO CST supply and return piping in the vicinity of the 286296-12) on the CST Piping Cathodic Auxiliary Feed Water (AFW) Building was limited Protection System (EC-27604) satisfactory by the installation parameters, i.e. the installation potentials/polarization were not able to be did not allow for installing anodes along the piping, achieved outside the direct area of the under the building floor. Based on the test results, anodes. installation of an additional anode under the Discovered on 4/30/2012 building floor is warranted. To keep the wiring runs to a minimum, this anode can be installed in the existing reference cell boring with the reference cell relocated to a new location. ECN-37501 has been initiated to implement this recommendation.

Additional funding will need to be secured through the URT and MPRC. CA-2 and CA-3 have been initiated to track these activities.

CR-IP3-201O-02589 Closed on 9/29/2010. CA 01 Response is as follows A 44" long section of 18"diameter "Further investigation revealed that the pipe comlgated Storm Drain Pipe was damaged changed elevation as it moved towards the center of while excavating the Roadway to the east the excavated area which we believe was caused of the Unit3 Fuel Storage Building when the pipe was repaired some time in the past.

Discovered on 9/1/2010 The damaged pipe interior was inspected to ensure it was not blocked and repaired under Work Order#225113-08. We have discussed this event with all personnel performing excavations on this project to reinforce the requirements and risks associated with this work activity" CR-IP3-2012-01709 Open. UTs performed underWO 308665-19. Pipe During excavation of 31 Main Transformer to be repaired per EC 38186 under WO 308665-21.

moat area, an opportunistic visual Leak reported to INPO EPIX inspection identified a through wall pipe leak in I-inch city water line 1203.

Discovered on 6/4/2012 CR-IP3-2012-01739 Closed to WO 00317725. Leak not reported to INPO manner.

IPEC ENGINEERING SNAPSHOT SELF-ASSESSMENT REPORT UNDERGROUND PIPING & TANKS INSPECTION AND MONITORING PROGRAM LO-IP3LO-20I2-00134 June 19 - June 21, 2012 3.11 Objective 2.11:

Assess whether the site displays senior level accountability for the Underground Piping & Tanks Inspection and Monitoring Program, and actually demonstrates this accountability by allocating the necessary resources and funding.

  • Positive observation on ownership of the program by the program owner is displayed by the number of inspections that have been accomplished at IPEC. Management support of the program is evident through site allocation of appropriate funding for digs accomplished to date and some current and planned upgrades to the Cathodic Protection system.

3.12 Objective 2.12:

Review SIPD, AMP, Margin Management database and Top Ten Issues list as needed for issue identification and resolution status/progress.

  • IPEC currently has two SIPD entries for Buried Piping.

SIPD 557 is for IP2 Cathodic Protection restoration with $953,465 allocated to date.

SIPD 573 is for IP3 Cathodic Protection restorations with $547,268 allocated to date.

From discussions with the CP Project Manager, IPEC has $1.4 mil budgeted in the 2013 AMP for IP2 Service Water Cathodic protection restorations.

  • IPEC Cathodic Protection was removed from the Top Ten Technical Issues List on 12/15/2011
  • Funding for 2012 and 2013 excavations & inspections ($350K per year) to meet NEI inspection milestones will be from PCE O&M Projects budget.

3.13 Objective 2.13:

Review IP2 & IP3 resolution for relevant Operating Experience reports to ensure learnings from these OEs have been incorporated in the program. Confirm that the site has populated EPIX with events dated back to the beginning of 2009, and continues to report events in EPIX as they occur.

.. A review of Operating Experience has been conducted. The OE section in IKS states: "No industry issues impacted the Buried Pipe Program at IP2 & IP3.

IPEC ENGINEERING SNAPSHOT SELF-ASSESSMENT REPORT UNDERGROUND PIPING & TANKS INSPECTION AND MONITORING PROGRAM LO-IP3LO-2012-00134 June 19 - June 21, 2012

  • There are five leak events that have not yet been entered into the EPIX system; o CR-IP3-2012-1709 (6/412012), 1" hole identified in City Water Line 1203 o CR-IP3-2012-1739 (61712012), Hole identified in a 3" sewer line from the Unit 3 Control Building o CR-IP2-2012-2326 (312512012), Holes found in 21,24, and 25 circulating water tunnels which were repaired.

The above failures were self-identified by the UPT program owner prior to the start of the self-assessment. The city water and sewer line failures were identified in June 2012 during excavation of the IP3 31 and 32 main transformers' moat areas, immediately prior to the start of the self-assessment. The three failures in the circulating water tunnels had been identified during IP2 2R20 (March 2012) PM cleaning and inspection of the pipe tunnels. The program owner had not been informed of these failure events, which occurred in non-safety-related and non-radiological piping.

All of the above five (5) pipe failures were reported to EPIX by the end of June. For the 3 circulating water pipe tunnel failures, however, the reports were not made within the 90 day period following discovery (INPO expectation).

Negative Observation:

LO-IP3LO-2012-00134 CA-8 Holes found in 21,24, and 25 circulating water tunnels were documented in CR-IP2-2012-2326 in March 2012 and were not entered into the EPIX database within the 90 day period following discovery. This does not meet INPO expectations for reporting all buried piping failures upon discovery, whether they are due to ID or OD failure mechanism, safety or non-safety related, have radiological or non-radiological content.

4. CONCLUSIONS Adequate performance of the Underground Piping and Tanks Monitoring Program will be achieved once the AFI and observations below are addressed. Cathodic Protection system effective performance will be assured once appropriate cOlTective actions are implemented for the long standing operational issues. The assure the term ,nt,'n.,.,

IPEC ENGINEERING SNAPSHOT SELF-ASSESSMENT REPORT UNDERGROUND PIPING & TANKS INSPECTION AND MONITORING PROGRAM LO-IP3LO-20I2-00I34 June 19 - June 21, 2012 4.2 Negative Observations:

Negative Observation #1 LO-IP3LO-2012-00134 CA-3

  • SEP-UIP-IPEC needs to be updated to ensure NEI 09-14 inspection requirements are being met.

The document should be revised to include additional scope and ensure groupings are addressed in the tone of meeting the NEI 09-14 objectives.

Negative Observation #2 LO-IP3LO-2012-00134 CA-4

  • Corporate Engineering to determine long-term plan for sumps and tanks that sit on top of the ground. These are not included within the NEI 09-14 initiative; therefore do not fit into the Underground Pipe and Tank Programs.

Negative Observation #3 LO-IP3LO-2012-0134, CA-5

  • Neither MapPro nor the risk ranking in the MapPro database could be electronically reviewed because the Program Owner has a software problem loading MapPro on his computer that has not been resolved.

Negative Observation #4 LO-IP3LO-2012-00134 CA-6

  • The Underground Piping & Tanks and Cathodic Protection System health reports are not consistent in reporting the current health of the Cathodic Protection System. Determine why the System Health Report for Cathodic Protection is Yellow and the Underground Pipe and Tank Health report shows CP as white.

Negative Observation #5 LO-IP3LO-2012-00134 CA-7

  • CA-002 CR-IP2-2009-018 Funding was approved to perform from a lack of cathodic

IPEC ENGINEERING SNAPSHOT SELF-ASSESSMENT REPORT UNDERGROUND PIPING & TANKS INSPECTION AND MONITORING PROGRAM LO-IP3LO-2012-00134 June 19 - Juue 21, 2012 4.3 Positive Observations:

  • The number of inspections accomplished at IPEC is larger than that of the other sites in the fleet.

This helps ensure the NEI 09-14 inspection requirements will be met.

  • IPEC's acquisition of the MapPro software and risk ranking conversion to MapPro database is considered a positive observation.
  • Ownership of the program by the program owner is displayed by the number of inspections that have been accomplished at IPEC. Management support of the program is evident through site allocation of appropriate funding for digs accomplished to date and some current and planned upgrades to the Cathodic Protection system.
5. REFERENCES 5.1 Corrosion/Cathodic Protection Field Survey and Assessment of Underground Structures at Indian Point Energy Center Unit Nos. 2 and 3 during October 2008 - Engineering Report No IP-RPT 00011 Rev. 0 5.2 Indian Point Energy Center APEC Survey: November 1-lO, 20lO. Prepared by Structural Integrity Associates, Inc. Denver Colorado - Eng. Report No. IP-RPT-11-00045 Rev. 0 5.3 NUREG-1801, Generic Aging Lessons Learned (GALL) Report, Nuclear Regulatory Commission (NRC)
  • Revision 1, Section XLM34 "Buried Piping and Tanks Inspection", September 2005
  • Revision 2, Section XLM41 "Buried and Underground Piping and Tanks," December 20lO 5.4 NEI 07-07 Final, "Industry Ground Water Protection Initiative, Final Guidance Document, Nuclear Energy Institute (NEI)," August 2007 5.5 EPRI lO21175, "Recommendations for an Effective Program to Control the Degradation of Buried and Underground Piping and Tanks (1016456 Rev 1)", December 20lO.

INPO Operating OED 2007-09, Degradation Buried Piping, dated

IPEe ENGINEERING SNAPSHOT SELF-ASSESSMENT REPORT UNDERGROUND PIPING & TANKS INSPECT/ON AND MONITORING PROGRAM LO-IP3LO-20I2-00134 June 19 - June 21, 2012 5.11 EN-DC-343 Rev 5, "Underground Piping and Tanks Inspection and Monitoring Program" 5.12 EN-DC-329 Rev 4, "Engineering Programs Control and Oversight" 5.13 EN-DC-174 Rev 3, "Engineering Program Sections" 5.14 EPRI 1011905, "Cathodic Protection System Application and Maintenance Guide", December 2005.

5.15 Institute of Nuclear Plant Operations (INPO), "Cathodic Protection on Underground Piping, Operating Experience Digest", August 2005.

5.16 American Nuclear Insurers (ANI), Nuclear Liability Insurance Guideline 07-01, "Potential of Unmonitored and Unplanned Off-Site Releases of Radioactive Material", March 2007.

5.l7 NRC Temporary Instmctions TI 25151182, "Review of the Implementation of the Industry Initiative to Control Degradation of Underground Piping and Tanks".

5.18 EPRIINEI "Industry Guidance for the Development of Inspection Plans for Buried Piping", Final Draft Approved for Use, April 2011.

5.19 Engineering Project Report "Guidelines for Management of Reasonable Assurance of Integrity for Above and Underground SSCs Containing Radioactive Material", Rev 0, September 2010. Note this reference contains the following attachments:

  • Attachment A - ECH-EP-10-00001 (Reference 5.8)
  • Attachment B - "Fleet Guidance for the Determination of Reasonable Assurance for Stmctural and/or Leakage Integrity for High Risk Underground Piping," September 29,2010. Note that this Attachment is now superseded by reference 5.20.
  • Attachment C - EPRI IR-2010-409 (Reference 5.9) 5.20 Engineering Project Report "Radiological Material Leak Prevention to Groundwater of Above and Under Ground Stmctures, Systems and Components", Rev 1, September 2010 5.21 System Health Report for Cathodic Protection - 2011 annual report Health Piping Tanks 4th quarter 2011

IPEC ENGINEERING SNAPSHOT SELF-ASSESSMENT REPORT UNDERGROUND PIPING & TANKS INSPECTION AND MONITORING PROGR,4M LO-IP3LO-2012-00134 June 19 - June 21, 2012

6. IPEC INDIVIDUALS INTERVIEWED Ian Mew FAC Program Engineer Dennis Pennino MIC Program Engineer Virginia Conrad Project Manager Chris Ingrassia Cathodic Protection System Engineer John Doroski Ground Water Protection Specialist Dara Gray SPCC program owner Frank Bloise Design Engineer - Cathodic Protection Tom Beasley Service Water System Engineer Steve Guarnaccia E-FIN/Coatings Engineer
7. ASSESSMENT TEAM MEMBERS Team Member: Bob Townley GGNS - EP&C Engineering Team Member: Rocky Jones ANO - EP&C Engineering
8. COMMUNICATION PLAN The results of this snapshot self-assessment will be provided to the following individuals:

Mike Balduzzi Senior Vice President, Nuclear Technical Services Tim Mitchell Senior VP, Chief Operating Officer-Entergy Nuclear Operations Oscar Limpias Vice President, Engineering John Ventosa Site Vice President Larry Coyle General Manager - Plant Operations Mark Woodby Director - Engineering Abisamra Chief Engineer

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