ML12339A556
| ML12339A556 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 12/08/2011 |
| From: | Richard Lee Entergy Nuclear Operations |
| To: | Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| References | |
| RAS 22157, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01 | |
| Download: ML12339A556 (8) | |
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)
ASLBP #: 07-858-03-LR-BD01 Docket #: 05000247 l 05000286 Exhibit #: ENT000444-00-BD01 Identified: 10/15/2012 Admitted: 10/15/2012 Withdrawn: ENT000444 Rejected: Stricken: Submitted : March 30, 2012 Other:
Entergy CONDITION REPORT ICR-IP2-2011-06250 Originator: Lee,Robert C Originator Phone: 6612 Originator Site Group: IP2 P&C Eng Codes Staff IP2 Operability Required: N Supervisor Name: Azevedo,Nelson F Reportability Required: N Discovered Date: 12/08/2011 13:40 Initiated Date: 12/08/20 I I 13:46 Condition
Description:
SW Lines 408 and 409 were excavated (Ref. EC 25313, WO # 279576) and the piping prepped for Vendor performance of guided wave ultrasonic inspection. The guided wave inspection of SW Line 409 identified an anomaly at a location on the pipe approximately 5 ft downstream of the transducer collar. This location is within the excavated area. Per Vendor, the anomaly may be an irregularity in the coating, pipe corrosion, or damage to the internal cement lining. The Vendor recommends coating removal and performing DT to confirm wall thickness at this location. The Guided Wave inspection was performed under the IPEC Buried Piping & Tank Program.
Immediate Action
Description:
Informed Engineering management.
Suggested Action
Description:
Remove coating at location of anomaly and perform DT to confirm adequate pipe wall.
Internal cement lining will be inspected in 2R20 under installation of mod EC 25313 .
EQUIPMENT:
Tag Name Tag Suffix Name Component Code Process System Code LINE409 EXlSR PIPE SW REFERENCE ITEMS:
Type Code Item Desc CR IP2-2011-06248 MOD Ee 25313 WON 00279576Y TRENDING (For Reference Purposes Only):
Trend Type Trend Code HEPFACTOR E REPORT WEIGHT 1 INPO BINNING MA l EI MAMG KEYWORDS KW-SERVICE WATER KEYWORDS KW-PIPE LINING
Entergy I CORRECTIVE ACTION ICR*IP2*2011*062S0 CANumber: 1 Sit~~ "] *" 1
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Assigned By: 1P2 Operations Watch Staff 1P2 Baker,1ohn R Assigned To: 1P2 P&C Eng Codes Mgmt 1P2 Azevedo,Nelson F Subassigned To :
Originated By: Baker,1ohn R 12/812011 15:09:38 Performed By: Azevedo,Nelson F 111912012 15:59:49 Subperformed By:
Approved By:
Closed By: Schoen,Peter S 11201201209:35 :04 Current Due Date: 0112012012 Initial Due Date: 01120/2012 CA Type: ACTION Plant Constraint: #NONE CA
Description:
Perform inspection of SW Line 409 at location specified in CR 1P2-2011-06250. Remove coating and perform UT's as necessary to confirm wall thickness. Based on results, perform an operability evaluation if required.
Response
The UT pipe inspections were completed on 1119112 and no issues were identified. The measured thicknesses were at nominal values. Since there were no unaccepatble thickness readings, an Operability Evaluation is not required. The inspection results are documented in inspection report No. 1P2-UT-12-002.
Subresponse :
Closure Comments:
acceptable for closure
Entergy I CA DUE DATE EXTENSION ICR-IP2-2011-062S0 Corrective Action: CR-IP2-2011-062S0 CA-OOOOI Version: Approved: 1./
Requested Duedate: 12/2212011 Previous Duedate: 12/13120 II Requested By: Azevedo,Nelson F 12/12120 II Approved By: Baker,John R 12/12/2011 Request
Description:
Please extend the due date to 12122/11 to allow for sufficient time to prepare contingencies, plan the work package, obtain replacement parts, remove the coating and perform the UT inspection. This extension is acceptable because there is reasonable bases to conclude that the pipe remains structurally capable of carrying the required design loads (see write up below). There is no industrial or nuclear safety concern associated with this extension since the pipe remains structurally sound. Supervisory concurrence has been obtained for this extension Bases for adequate structural integrity:
The ongoing Guided Wave UT (GW -UT) inspections in support of the buried piping program identified one area of interest in SW line 409 in an area West of the Unit 2 turbine building. This area of interest could be a result of a coating anomaly and therefore insignificant or it could be a result of some pipe corrosion. The actual cause of the anomaly can not be established until the coating is removed and the area is inspected. However, even if the anomaly is assumed to be a result of pipe corrosion, the amount of corrosion at this location would not be expected to adversely impact the structural integrity (and therefore operability) of the pipe based on the following:
U ] Since the anomaly is not located at a weld (based on the GW-UT signal), past experience indicates that internal pipe corrosion is unlikely. The internal cement lining has proven to be an effective corrosion barrier in locations other than welds and downstream of throttled valves. Therefore, if corrosion is present, it is likely to be on the outside surface of the pipe.
- 2. 0 An inspection of the external protective coating did not identify any visible signs of corrosion under the coating.
Significant external corrosion would be expected to occur at locations with visible coating damage. Therefore, if corrosion is the cause of the anomaly is not expected to be significant.
- 3. [] There are currently no signs of through wall leakage at this location. Absence of leakage provides additional assurance that if corrosion is present, it is not expected to be extensive.
- 4. 0 Discuss ions with Design Civil Structural Engineering indicated that the affected section of pipe has significant inherent structural margin. The nominal pipe wall thickness is O.375? while the required thickness is 0.120? This means that corrosion could remove up to 680/0 of the nominal pipe wall thickness before the structural integrity of the pipe would be challenged.
Localized corrosion could be even deeper before the integrity of the pipe would be challenged.
In summary, the anomaly detected during the GW -UT inspection of the 409 SW pipe is not expected to challenge the structural integrity of the pipe even if it is assumed that the anomaly is a result of corrosion of the pipe material.
Approved
Description:
Approved
Entergy I CORRECTIVE ACTION ICR-IP2-2011-062S0 CANumber: 2 Site *
- 1 c* Group Name ...... ,
Assigned By: IP2 P&C Eng Codes Mgmt IP2 Tesoriero,Michael V Assigned To: IP2 P&C Eng Codes Mgmt IP2 Azevedo,Nelson F Subassigned To:
Originated By: Zzip2crg 121121201113:45 :04 Performed By: Azevedo,Nelson F 11312012 13:07 :30 Subperformed By:
Approved By:
Closed By: Azevedo,Nelson F 1I31201213:07:30 Current Due Date: 0110512012 Initial Due Date: 0110512012 CA Type: DISP - CA Plant Constraint: NONE CA
Description:
You have been assigned as the Responsible Manager for this Category "e", Non-Significant Condition Report by the CRG Address/correct the identified condition per EN-LJ-102. Perform disposition review, investigate as needed, and ensure actions are assigned as appl icable to correct the problem.
Response
The area of interest identified during the guided wave UT inspections has been exposed and a visual inspection has been performed of the area. This visual inspection did not identify any signs of corrosion on the outside surface of the pipe nor did it identify any signs that a weld exists at this location. Given these results, it is unlikely that the anomoly identified during the guided wave inspection is a result of pipe corrosion. However, a UT inspection is still scheduled to be performed under task 18 of WO 00279576 to confirm the results of the visual inspection. CA-OOOO 1 of this CR remains open to track completion of these UT inspections. Therefore, this CA can be close.
Subresponse :
Closure Comments:
Entergy I CORRECTIVE ACTION ICR-IP2-2011-062S0 CANumber: 3 Site r_~
__ *. ~
~ .uu~p ________ ] ~ _ _ _ _Name Assigned By: IP2 P&C Eng Codes Mgmt IP2 Tesoriero,Michael V Assigned To: IP2 P&C Eng Codes Mgmt IP2 Azevedo,Nelson F Subassigned To :
Originated By: Zzip2crg 1211212011 13:46:25 Performed By: Azevedo,Nelson F 11312012 12:55: 19 Subperformed By:
Approved By:
Closed By: Azevedo,Nelson F 11312012 12:55:19 Current Due Date: 0110512012 Initial Due Date: 0110512012 CA Type: ACTION Plant Constraint: #NONE CA
Description:
Include CR-IP2-2011-06248 (Condition Description copied below) in your Category C Review assigned under this CR:
"An As-Found visual inspections of the OD coating on excavated SW Lines 408 & 409 piping were performed under the IPEC Buried Piping Program. The excavated area is at the existing access points on the 24-inch main header, at the west side of the IP2 Turbine Building (Ref. EC 25313, WO # 279576). Various locations where the coating system had failed or possibly mis-applied were found. There were no obvious signs of piping degradation at these locations, and therefore, there are no operability concerns. Coating repairs will be performed after the piping inspections are completed."
Response
The coating conditions described in CR-IP2-2011-06248 have been evaluated and it was determined that the coating needs repair prior to back filling. In addition, UT inspections of these pipes has indicated that the pipe thickness is acceptable for continue service. The coating repairs will be implemented under task 12 of WO 00279576.
Subresponse :
Closure Comments:
Entergy I CORRECTIVE ACTION ICR-IP2-2011-062S0 CANumber: 4 Sit~ - I i_ _ _ _ _ _ _ _ _ G_r_
ou-:p~_ _ _ _ _ ____' ____ N_a_m_e_ _--'
Assigned By: IP2 CAA Staff lP2 Firth,Edwin G Assigned To: IP2 P&C Eng Codes Mgmt IP2 Azevedo,Nelson F Subassigned To:
Originated By: 10witt,Roseann 11231201206:41:27 Performed By: Azevedo,Nelson F 1124/201211:15 :47 Subperformed By:
Approved By:
Closed By: Hans,Steven 11271201210:09:20 Current Due Date: 02/0112012 Initial Due Date: 02/0112012 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 / DISAPPROVE CLOSURE IN ACCORDANCE WITH EN-LI-102, SECTION 5.10.
Response
This CR is ready for closure since all required corrective actions have been completed.
Subresponse :
Closure Comments:
CAA review acknowledged the CR Document Owners closure readiness review and approved closure. The closure review determined that the actions have been performed or a satisfactory explanation provided, no additional actions are required.
Therefore, this CA can be closed at this time.
Entergy OPERABILITY ICR-IP2-2011-062S0 OperabilityVersion: 2 Operability Code: OPERABLE Immediate Report Code: NOT REPORT ABLE Performed By: Gates,Clifton 01/ 19120 12 20:50 Approved By: Buchal,Timothy J OIl 19/2012 21:05 Operability
Description:
No degraded or nonconforming condition exists per EN-OP-104 Revision 5 Attachment 9.1 Table 1. The UT pipe inspections were completed on 1/ 19112 and no issues were identified. The measured thicknesses were at nominal values. Since there were no unaccepatble thickness readings, SW Lines 408 and 409 that were excavated are OPERABLE. The inspection results are documented in inspection report No. IP2-UT-1 2-002.
Approval Comments:
Approved
Entergy ASSIGNMENTS CR-IP2-2011-06250 Version: 1 Significance Code: C Classification Code: CORRECT/ADDRESS Owner Site and Group: 1P2 P&C Eng Codes Mgmt 1P2 Performed By: Harrison,Christine B 1211212011 11:52 Assignment