ML12307A439

Ltr 11/2/12 LaSalle Ti 2515/182 Request for Information

ML12307A439
Person / Time
Site:	LaSalle
Issue date:	11/02/2012
From:	Dave Hills NRC/RGN-III/DRS/EB1
To:	Pacilio M Exelon Generation Co, Exelon Nuclear
Atif Shaikh
References
TI 2515-182
Download: ML12307A439 (10)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE ROAD, SUITE 210 LISLE, IL 60532-4352 November 2, 2012 Mr. Michael J. Pacilio Senior Vice President, Exelon Generation Company, LLC President and Chief Nuclear Officer, Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

LASALLE COUNTY STATION, UNITS 1 AND 2 - NOTIFICATION OF NRC INSPECTION AND REQUEST FOR INFORMATION

Dear Mr. Pacilio:

On January 14, 2012, the U. S. Nuclear Regulatory Commission (NRC) will begin the Temporary Instruction (TI) Inspection, Review of Implementation of the Industry Initiative to Control Degradation of Underground Piping and Tanks, (TI 2515-182) at LaSalle County Station, Units 1 and 2. This on-site inspection is scheduled to be performed January 14 through 18, 2012.

In order to minimize the impact to your on-site resources, and to ensure a productive inspection for both sides, we have enclosed a list of documents pertinent to our inspection. The documents that are requested for this inspection include all relevant documents that will allow the inspector(s) to adequately complete Phase II of this inspection. It is important that all of these documents are up-to-date, and complete, in order to minimize the number of additional documents requested during the preparation and/or the on-site portions of the inspection.

We have discussed the schedule for these inspection activities with your staff and understand that our regulatory contact for this inspection will be Mr. Manu Sharma, of your organization. If there are any questions about this inspection or the material requested, please contact the lead inspector Mr. Atif Shaikh at (630) 829-9824.

This letter does not contain new or amended information collection requirements subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection requirements were approved by the Office of Management and Budget, Control Number 3150-0011. The NRC may not conduct or sponsor, and a person is not required to respond to, a request for information or an information collection requirement unless the requesting document displays a currently valid Office of Management and Budget control number.

M. Pacilio In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

David E. Hills, Chief Engineering Branch 1 Division of Reactor Safety Docket No. 50-373; 50-374 License No. NPF-1; NPF-18

Enclosure:

TEMPORARY INSTRUCTION (TI 2515-182) INSPECTION DOCUMENT REQUEST cc w/encl: Distribution via ListServ'

TEMPORARY INSTRUCTION 2515-182 INSPECTION DOCUMENT REQUEST Inspection Dates: January 14 - 18, 2012 Inspection Procedures: Temporary Instruction 2515-182, Review of Implementation of the Industry Initiative to Control Degradation of Underground Piping and Tanks Inspector: Atif Shaikh, DRS (630) 829-9824 Atif.Shaikh@nrc.gov A. Information Requested for the In-Office Preparation Week The following documents listed below are requested (electronic copy CD ROM if possible) by December 14, 2012, to facilitate the preparation for the on-site inspection week.

1. Organization list of site individuals responsible for the sites underground piping and tanks program.

2. Copy of Site Underground Piping and Tanks program.

3. Please review the attached Questions list and provide the response and/or document requests. The questions identified with the word Prep (highlighted in bold) are the items to be provided in advance of the inspection to support preparation for on-site week.

4. Schedule for completion of the following NEI 09-14 Revision 1 attributes:

Buried Piping

• Procedures and Oversight

• Risk-Ranking

• Inspection Plan

• Plan Implementation

• Asset Management Plan Underground Piping and Tanks

• Procedures and Oversight

• Prioritization

• Condition Assessment Plan

• Plan Implementation

• Asset Management Plan 1 Enclosure

TEMPORARY INSTRUCTION 2515-182 INSPECTION DOCUMENT REQUEST B. Information to be Provided On-Site to the Inspector Following the Entrance Meeting

1. Location maps of buried and underground piping and tanks identified by the inspector from the information requested for the preparation week.

2. Copy of EPRI document Recommendations for an Effective Program to Control the Degradation of Buried Pipe.

3. Self or third party assessments of the Underground Piping and Tanks Program (if any have been performed).

4. Please review the attached Questions list and provide response and/or document requests. The questions identified with the word On-site (highlighted in bold) are the items to be provided to the inspector on-site at the entrance meeting.

5. For any of the NEI 09-14 Revision 1 attributes identified below which have been completed prior to the NRCs on-site inspection, provide written records that demonstrate that the program attribute is complete.

Buried Piping

• Procedures and Oversight

• Risk-Ranking

• Inspection Plan

• Plan Implementation

• Asset Management Plan Underground Piping and Tanks

• Procedures and Oversight

• Prioritization

• Condition Assessment Plan

• Plan Implementation

• Asset Management Plan The inspector may select specific items from the information requested for the preparation week and request follow-up documents during the on-site inspection week.

2 Enclosure

TEMPORARY INSTRUCTION 2515-182 REQUEST FOR DOCUMENTS Questions Response Prep week/ Initiative Consistency On-site week Prep Has the licensee taken any deviations to Yes/No either of the initiatives?

On-site If so, what deviations have been taken Provide documentation of deviations and any and what is (are) the basis for these associated corrective action reports.

deviations?

Prep Does the licensee have an on-site buried Yes/No piping program manager (owner) and, potentially, a staff?

On-site How many buried piping program owners Provide documentation identifying individuals have there been since January 1, 2010? responsible for the site buried piping program since January 1, 2010.

On-site How many other site programs are List all site programs that are under the direct assigned to the buried piping program responsibility of the sites buried piping owner? program owner.

On-site Does the licensee have requirements to Yes/No capture program performance, such as system health reports and performance Provide copies of most recent systems health indicators? reports if applicable Prep Are these requirements periodic or event Periodic/Event Driven/None driven?

On-site Are there examples where these Yes/No requirements have been successfully used to upgrade piping systems or to Provide documentation related to examples if avert piping or tank leaks? applicable Prep Does the licensee have a program or Yes/No procedure to confirm the as-built location of buried and underground piping and tanks at the plant?

Prep Has the licensee used this program? Yes/No Prep Was the program effective in identifying Yes/No the location of buried pipe?

3 Enclosure

TEMPORARY INSTRUCTION 2515-182 REQUEST FOR DOCUMENTS Questions Response Prep/On-site For a sample of buried pipe and Yes/No Sample size examined _____

underground piping and tanks (sample size at least 1 high and 1 low risk/priority Prep: Provide copy of sites risk ranking pipe or tank), did the risk ranking and/or documents including documents pertaining to prioritization process utilized by the the actual risk rankings and methodology licensee produce results in accordance used.

with the initiative guidelines, i.e., which emphasize the importance of components Prep: Provide documents/drawings and/or list which have a high likelihood and which identifies the risk ranking for each pipe consequence of failure and deemphasize segment or tank in each system within the the importance of components which scope of these programs.

have a low likelihood and consequence of failure? On-site: Provide the documents which record/describe how the risk methodology was applied to determine the risk of pipe segments or tanks as selected by the inspector during the preparation week.

Prep As part of its risk ranking process did the Yes/No licensee estimate/determine the total length of buried/underground piping included in the initiatives?

Prep As part of its risk ranking process did the Yes/No licensee estimate/determine the total length of high risk buried/underground piping included in the initiatives?

Preventive Actions/System Maintenance 4 Enclosure

TEMPORARY INSTRUCTION 2515-182 REQUEST FOR DOCUMENTS Questions Response Prep For buried steel, copper, or aluminum Yes/No/Not Applicable (no buried steel, copper, or piping or tanks which are not cathodically aluminum piping which is not cathodically protected, has the licensee developed a protected) technical basis for concluding that structural (e.g., ASME Code minimum wall, if applicable) and leaktight integrity of buried piping can be maintained?

On-site Is the technical basis provided as Yes/No justification by the licensee consistent with the initiative (including its reference Provide documented technical basis including documents) or industry standards (e.g., referencing documents.

NACE SP0169)

Prep For uncoated steel piping, has the Yes/No/Not Applicable (no uncoated buried steel licensee developed a technical basis for pipe) concluding that structural (e.g., ASME Code minimum wall, if applicable) and leaktight integrity of buried piping can be maintained?

On-site Is the technical basis provided as Yes/No justification by the licensee consistent with the initiative (including its reference Provide documented technical basis including documents) or industry standards (e.g., referencing documents.

NACE SP0169)?

Prep For licensees with cathodic protection Yes/No/Not Applicable (no cathodic protection systems, does the licensee have systems) procedures for the maintenance, monitoring, and surveys of this equipment?

On-site Are the licensee procedures consistent Yes/No with the initiative (including its reference documents) or industry standards (e.g., Provide copy of procedures if applicable.

NACE SP0169)?

5 Enclosure

TEMPORARY INSTRUCTION 2515-182 REQUEST FOR DOCUMENTS Questions Response On-site Is the cathodic protection system, Yes/No including the evaluation of test data, being operated and maintained by personnel Provide documentation of training or knowledgeable of, or trained in, such qualification records of personnel.

activities?

On-site Is there a program to ensure chase and Yes/No/N/A (No piping in chases or vaults) vault areas which contain piping or tanks subject to the underground piping and Provide copy of program.

tanks initiative are monitored for, or protected against, accumulation of leakage from these pipes or tanks?

Inspection Activities/Corrective Actions Prep Has the licensee prepared an inspection Yes/No plan for its buried piping and underground piping and tanks?

On-site Does the plan specify dates and locations Yes/No where inspections are planned?

Provide copy of inspection plan and associated implementation procedures.

Prep Have inspections, for which the planned Occurred as scheduled/Deferred dates have passed, occurred as scheduled or have a substantial number of inspections been deferred?

Prep Has the licensee experienced leaks Leaks Yes/No Degradation Yes/No and/or significant degradation in safety related piping or piping carrying licensed material since January 1, 2009?

Prep If leakage or significant degradation did Yes/No occur, did the licensee determine the cause of the leakage or degradation?

6 Enclosure

TEMPORARY INSTRUCTION 2515-182 REQUEST FOR DOCUMENTS Questions Response On-site Based on a review of a sample of root Yes/No/N/A (no leaks) cause analyses for leaks from buried piping or underground piping and tanks which are Provide root cause analyses of identified leaks if safety related or contain licensed material, applicable.

did the licensee's corrective action taken as a result of the incident include addressing the cause of the degradation?

On-site Did the corrective action include an Yes/No/N/A (no leaks) evaluation of extent of condition of the piping or tanks and possible expansion of Provide corrective action documents concerning scope of inspections? (Preference should leaks if applicable.

be given to high risk piping and significant leaks where more information is likely to be available).

Prep Based on a review of a sample of NDE Yes/No activities which were either directly observed or for which records were Provide list of scheduled NDE activities scheduled reviewed, were the inspections conducted during on-site week and list of NDE activities that using a predetermined set of have already been conducted.

licensee/contractor procedures?

On-site Were these procedures sufficiently Yes/No described and recorded such that the inspection could be reproduced at a later Provide copies of NDE procedures for the various date? NDE activities that have occurred or are scheduled to occur.

Prep Were the procedures appropriate to detect Yes/No the targeted degradation mechanism?

For quantitative inspections, were the Yes/No Prep procedures used adequate to collect quantitative information?

On-site Did the licensee disposition direct or indirect Yes/No NDE results in accordance with their Provide sample of direct and/or indirect NDE procedural requirements? results and the subsequent evaluations of these NDE results.

7 Enclosure

M. Pacilio In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

David E. Hills, Chief Engineering Branch 1 Division of Reactor Safety Docket No. 50-373; 50-374 License No. NPF-1; NPF-18

Enclosure:

TEMPORARY INSTRUCTION (TI 2515-182) INSPECTION DOCUMENT REQUEST cc w/encl: Distribution via ListServ' DISTRIBUTION:

Cayetano Santos RidsNrrDorlLpl3-2 Resource RidsNrrPMLaSalle RidsNrrDirsIrib Resource Chuck Casto Cynthia Pederson Steven Orth Jared Heck Allan Barker Christine Lipa Carole Ariano Linda Linn DRPIII DRSIII Tammy Tomczak DOCUMENT NAME: G:\DRSIII\DRS\Work in Progress\Ltr. 110212 LaSalle TI-182 Phase 2 RFI AAS.docx Publicly Available Non-Publicly Available Sensitive Non-Sensitive To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy OFFICE RIII RIII NAME AShaikh:ls DEHills DATE 11/02/12 11/02/12 OFFICIAL RECORD COPY