ML12334A722

Official Exhibit - NYS000196-00-BD01 - Email, Harold Gray to Keith Hoffman and Robert Hardies, Cc Richard Conte and Timothy Lupold, Subject Line: FW: Buried Piping - Proposed NRC Action

ML12334A722
Person / Time
Site:	Indian Point
Issue date:	04/23/2010
From:	Darrell Roberts NRC Region 1
To:	Conte R, Gray H, Wilson P Atomic Safety and Licensing Board Panel, NRC Region 1
SECY RAS
References
RAS 21567, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01
Download: ML12334A722 (5)

Text

United States Nuclear Regulatory Commission Official Hearing Exhibit Entergy Nuclear Operations, Inc.

In the Matter of:

(Indian Point Nuclear Generating Units 2 and 3) NYS000196 c.\,..t.P.R REGU~)o ASLBP #: 07-858-03-LR-BD01 Submitted: December 16, 2011

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Docket #: 05000247 l 05000286

~ 0 Exhibit #: NYS000196-00-BD01 Identified: 10/15/2012

~ ~

'" ~ Admitted: 10/15/2012 Withdrawn:

~

'1"'/1- 0' f Rejected: Stricken:

~

• • • ** " Other:

Conte, Richard From: Roberts, Darrell ~

Sent: Friday, April 23, 201 () 5: 15 PM To: Conte, Richard; Gray, Harold; Wilson, Peter

Subject:

RE: Buried piping - Proposed NRC Action Please connect these thoughts and any others with the appropriate NRR/DCI staff - as Fred Brown is working with them in formulating a generic communication approach in the very near term.

Fred was focused on the "high-pressure discharge-buried piping" being a unique nuance that we had not been focused on before (Le., most buried piping of safety*:related systems has been associated with low-pressure suction sides of pumps). He and DCI may need to be enlightened as to any other aspects (such as those you list below) that may need to be addressed in the generic communication.

thx, DJR From: Conte, Richard Sent: Friday, April 23, PM To: Gray, Harold; Roberts, Darrell; Wilson, Peter

Subject:

RE: Buried piping - Proposed NRC Action interesting that while you and Fred Brown were discussing the need for generic communications, Harold implemented writing his ideas down this morning.

After IndianPoint, Oyster Creek, VY and now Salem, it is clear that the industry might not have a good understand for safety related applications:

what by design is buried; what is buried and not covered by ASME code e.g., 1 inch piping.

because it is buried, how do they assess external conditions.

if inaccessible what maintenance and testing is done periodically, through internal means if underground but not buried what kind of surveillance or PM is done in the vaults and pipe chases.

do they have a buried pipe program if they have not submitted a license renewal application ..

From: Gray, Harold Sent: Friday, April 23, AM To: Conte, Richard

Subject:

Buried piping - Proposed NRC Action The buried pipe degradation conditions at 0 Creek, Indian Point and Salem, while not having serious operability or safety consequences, collectively illustrate that Plants do not fully know what they have in the scope and condition of buried piping.

The proposal is for NRC to issue generic direction to the industry on buried piping as a Generic Letter, Bulletin or Information Notice with at least the following scope: .

OAG10001063_00001

Confirm that there is no buried Class 1 piping at the plant site.

Confirm that buried Service water pipe and components are currently within the scope and control as previously determined by evaluations and responses to GL 89-13 and its followups.

Determine the scope of other Class 2 and Class 3 safety or risk significant buried pipe.

For all buried pipe systems, other than service water components, confirm that the provisions of the ASME Code Section XI, IWA-5244 for buried pipe and components have been met. Additionally, confirm by sampling including excavation and testing that the coating of buried piping has been properly applied and is currently protecting the pipe from corrosion.

Harold Gray, 610-337-5325 2

OAGI0001063 00002

Conte, Richard From: Conte, Richard Sent: Friday, April 23, 2010 1:05 PM To: Gray, Harold; Roberts, Darrell; Wilson, Peter

Subject:

RE: Buried piping - Proposed NRC Action interesting that while you and Fred Brown were discussing the need for generic communications, Harold implemented writing his ideas down this morning.

After IndianPoint, Oyster Creek, 'VY and now Salem, it is clear that the industry might not have a good understand for safety related applications:

what by design is buried; what is buried and not covered by ASME code e.g., 1 inch piping.

because it is buried, how do they assess external conditions.

if inaccessible what maintenance and testing is done periodically, through internal means if underground but not buried what kind of surveillance or PM is done in the vaults and pipe chases.

do they have a buried pipe program if they have not submitted a license renewal application.

From: Gray, Harold Sent: Friday, April 23, 2010 9:52 AM To: Conte, Richard

Subject:

Buried piping - Proposed NRC Action The buried pipe degradation conditions at 0 Creek, Indian Point and Salem, while not having serious operability or safety consequences, collectively illustrate that Plants do not fully know what they have in the scope and condition of buried piping.

The proposal is for NRC to issue generic direction to the industry on buried piping as a Generic Letter, Bulletin or Information Notice with at least the following scope:

Confirm that there is no buried Class 1 piping at the plant site.

Confirm that buried Service water pipe and components are currently within the scope and control as previously determined by evaluations and responses to GL 89-13 and its followups.

Determine the scope of other Class 2 and Class 3 safety or risk significant buried pipe.

For all buried pipe systems, other than service water components, confirm that the provisions of the ASME .

Code Section XI, IWA-5244 for buried pipe and components have been met. Additionally, confirm by sampling including excavation and testing that the coating of buried piping has been properly applied and is currently protecting the pipe from corrosion.

1 OAGI0001063 00003

Harold Gray, 610-337-5325 2

Conte, Richard From: Gray, Harold Sent: Friday, April 23, 2010 11 :27 AM To: Hoffman,Keith; Hardies, Robert Cc: Conte, Richard; Lupoid, Timothy

Subject:

FW: Buried piping - Proposed NRC Action FYI, a plan.

You may already have something like this in the works, but as time moves on it seems more needed.

VY can be added to the list.

Harold Gray, 610-337-5325 From: Gray, Harold Sent: Friday, April 23, 2010 9:52 AM To: Conte, Richard .

Subject:

Buried piping - Proposed NRC Action The buried pipe degradation conditions at 0 Creek, Indian Point and Salem, while not having serious operability or safety consequences, collectively illustrate that Plants do not fully know what they have in the scope and condition of buried piping.

The proposal is for NRC to issue generic direction to the industry on buried piping as a Generic Letter, Bulletin or Information Notice with at least the following scope: .

Confirm that there is no buried Class 1 piping at the plant site.

Confirm that buried Service water pipe and components are currently within the scope and control*as previously determined by evaluations and responses to GL 89-13 and its followups.

Determine the scope of other Class 2 and Class 3 safety or risk significant buried pipe.

For all buried pipe systems, other than service water components, confirm that the provisions of the ASME Code Section XI, IWA-5244 for buried pipe and components have been met. Additionally, confirm by sampling including excavation and testing that the coating of buried piping has been properly applied and is currently p'rotecting the pipe from corrosion.

Harold Gray, 610-337-5325 1

OAGI0001063 00005