ML12340A758

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Official Exhibit - ENT000581-00-BD01 - IP-RPT-11-LRD07, Review of the Buried Piping and Tanks Inspection Aging Management Program for License Renewal Implementation (June 2012)
ML12340A758
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 06/20/2012
From: Brian Lee
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 IP-RPT-11-LRD07
Download: ML12340A758 (30)
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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)

" ....t.1-RREGlI~J- ASLBP #: 07-858-03-LR-BD01 ENT000581 Y~¥\""

Docket #: 05000247 l 05000286 Submitted: October 2, 2012

< Exhibit #: ENT000581-00-BD01 Identified: 10/15/2012

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0 Admitted: 10/15/2012 Withdrawn:

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ATTACHMENT 9.1 VENDOR DOCUMENT REVIEW STATUS Sheet 1 of 1 ENTERGY NUCLEAR MANAGEMENT MANUAL Entergy EN-DC-149 VENDOR DOCUMENT REVIEW STATUS

[gI FOR ACCEPTANCE D FOR INFORMATION

[?SI IPEC D JAF D PLP D PNPS DVY D ANO D GGNS D RBS D W3 D NP Document No.: IP-RPT-11-LRD07 I Rev. No. 0 Document Title: Review of the Buried PiRing and Tanks InsRection Aging Management Program for License Renewal ImRlementation EC No.: EC37054 (NiAlor f':Ir'l I Purchase Order No.

STATUS NO:

1. [gI ACCEPTED, WORK MAY PROCEED
2. D ACCEPTED AS NOTED RESUBMITTAL NOT REQUIRED, WORK MAY PROCEED
3. D ACCEPTED AS NOTED RESUBMITT AL REQUIRED
4. D NOT ACCEPTED Acceptance does not constitute approval of design details, calculations, analyses, test methods, or materials developed or selected by the supplier and does not relieve the supplier from full compliance with contractual negotiations.

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'I Responsible Engineer Bob Lee Print Name

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Signa:ure

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i Da(e Engineering Supervisor Nelson Azevedo/ d A/~k'- nCl , / c: - ;;t &7 - I :J-...--

Print Name Signature Date EN ~ DC-149 REV 6

ATTACHMENT 9.2 VENDOR DOCUMENT COMMENT RESOLUTION SHEET Sheet 1 of 1 VENDOR DOCUMENT COMMENT RESOLUTION Document No: IP-RPT-11-LRD07 Rev. No: 0 EC No: EC37054 (N/A for NP)

Document Title: Review of the Buried Pi ram for License Renewal Implementation Reviewer: Bob Lee Print Name/ Signature Comment Page Section Comment: Disposition Resolution:

No: No: No: 1/0*

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'I " Included, °"Ow RE: Bob Lee . ~

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'2.pl1-EN-DC-149 REV 6

Engineering Report No. IP*RPT*11*LRD07 Rev 0 Page _1_ of 28

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~ Entergy ENTERGY NUCLEAR Engineering Report Cover Sheet EDgineeriDg Report Title:

Review of the Buried Piping and Tanks Inspection Aging Management Program for License Renewal Implementation Engineering Report Type:

New 0 Revision 0 Cancelled 0 Superseded 0 Superseded by:

AppJieable Site(s)

IP} 0 TP2 ~ IP3 18l JAF 0 PNPS 0 yyO WPO 0 ANOI 0 AN02 0 ECH 0 GGNS 0 RBS 0 WF3 0 PLP 0 ECNo. _ _ __

Report Origin: rgj Entergy 0 Vendor Vendor Document No.:,_ _ _ _ _ _ __

Quality-Related: 0 Yes Design Verified: _ _ _ _ _ _ _ _....;,c,._ _ _ _ _ _ __

Approved by: David J. Lach Date:

IPEC License Renewal Implementation Project IP-RPT-11-LRD07 Review of the Buried Piping and Tanks Inspection Aging Revision 0 Management Program for License Renewal Implementation Page 2 of 28 REVISION DESCRIPTION SHEET Revision Description Pages and/or Sections Revised Number 0 Initial Issue

IPEC License Renewal Implementation Project IP-RPT-11-LRD07 Review of the Buried Piping and Tanks Inspection Aging Revision 0 Management Program for License Renewal Implementation Page 3 of 28 TABLE OF CONTENTS 1.0 Program Description ..........................................................................................................4 2.0 Reference Documents .......................................................................................................6 3.0 Commitments and License Action Requests (LAR) ...........................................................8 4.0 Commitments/LAR Actions/Program Requirements and Program Status .......................10 5.0 Site Program Owner/Lead................................................................................................18 : License Renewal Buried Piping and Tanks Inspection Program Implementation Action Tracking ...........................................................................................................................19

IPEC License Renewal Implementation Project IP-RPT-11-LRD07 Review of the Buried Piping and Tanks Inspection Aging Revision 0 Management Program for License Renewal Implementation Page 4 of 28 1.0 Program Description This report documents review of the Buried Piping and Tanks Inspection Program that was credited for license renewal of IPEC Units 2 and 3 (Ref. 5, 6).This review is intended to identify specific requirements tied to the program as well as the status of the site documentation for purposes of ensuring the proper implementation of the program for the period of extended operation and completion of the commitments.

The Buried Piping and Tanks Inspection Program is a new program that includes (a) preventive measures to mitigate corrosion and (b) inspections to manage the effects of corrosion on the pressure-retaining capability of buried carbon steel, gray cast iron, and stainless steel components. Preventive measures are in accordance with standard industry practice for maintaining external coatings and wrappings. Buried components are inspected when excavated during maintenance. If trending within the corrective action program identifies susceptible locations, the areas with a history of corrosion problems are evaluated for the need for additional inspection, alternate coating, or replacement.

IP2 will perform 20 direct visual inspections of buried piping during the 10 year period prior the PEO. IP2 will perform 14 direct visual inspections during each 10-year period of the PEO. Soil samples will be taken prior to the PEO and at least once every 10 years in the PEO. Soil will be tested at a minimum of two locations at least three feet below the surface near in-scope piping to determine representative soil conditions for each system. If test results indicate the soil is corrosive then the number of piping inspections will be increased to 20 during each 10-year period of the PEO.

IP3 will perform 14 direct visual inspections of buried piping during the 10 year period prior the PEO. IP3 will perform 16 direct visual inspections during each 10-year period of the PEO. Soil samples will be taken prior to the PEO and at least once every 10 years into the PEO. Soil will be tested at a minimum of two locations at least three feet below the surface near in-scope piping to determine representative soil conditions for each system. If test results indicate the soil is corrosive then the number of piping inspections will be increased to 22 during each 10-year period of the PEO.

This program will be implemented prior to the period of extended operation. This new program will be implemented consistent with the corresponding program described in NUREG-1801 Section XI.M34, Buried Piping and Tanks Inspection with the following modification.

The Buried Piping and Tanks Inspection Program will be modified based on operating experience to include a risk assessment of in-scope buried piping and tanks that includes consideration of the impacts of buried piping or tank leakage and of conditions affecting the risk for corrosion. The program will classify pipe segments and tanks as having a high, medium or low impact of leakage based on the safety class, the hazard posed by fluid contained in the piping and the impact of leakage on reliable plant operation. Corrosion risk will be determined through consideration of piping or tank material, soil resistivity, drainage, the presence of cathodic protection and the type of coating. Inspection priority and frequency for periodic inspections of the in-scope piping and tanks will be based on the results of the risk assessment.

Inspections will be performed using qualified inspection techniques with demonstrated effectiveness. Inspections will begin prior to the period of extended operation.

IPEC License Renewal Implementation Project IP-RPT-11-LRD07 Review of the Buried Piping and Tanks Inspection Aging Revision 0 Management Program for License Renewal Implementation Page 5 of 28 The attached pages document the review of the site Buried Piping and Tanks Inspection Program including related commitments, requirements, and procedures or other documents that implement the program. This review assesses readiness for entering the period of extended operation including assessment of license renewal commitments. Attachment 1 provides a tabular consolidation of these individual program requirements, commitments and recommended actions with additional details.

IPEC License Renewal Implementation Project IP-RPT-11-LRD07 Review of the Buried Piping and Tanks Inspection Aging Revision 0 Management Program for License Renewal Implementation Page 6 of 28 2.0 Reference Documents

1. IP-RPT-06-LRD02, Aging Management Program Evaluation - Class 1 Mechanical, Rev. 4, available on Merlin.
2. IP-RPT-06-LRD07, Aging Management Program Evaluation - Non-Class 1 Mechanical, Rev. 6, available on Merlin.
3. IP-RPT-06-LRD08, Aging Management Program Evaluation - Structural/Civil, Rev. 3, available on Merlin.
4. IP-RPT-06-LRD09, Aging Management Program Evaluation - Electrical, Rev. 4, available on Merlin.
5. Indian Point Energy Center, License Renewal Application, (program descriptions are in Appendix B), available on Merlin, and at http://www.nrc.gov/reading-rm/adams.html#web-based-adams and Begin Web-based ADAMS Search with Accession # ML071210523.
6. NUREG-1930, Safety Evaluation Report (SER) Related to the License Renewal of Indian Point Nuclear Generating Unit Nos. 2 and 3, published in November 2009, available on Merlin, and at http://www.nrc.gov/reading-rm/adams.html#web-based-adams and Begin Web-based ADAMS Search with Accession # ML093170671.
7. Safety Evaluation Report (SER) Related to the License Renewal of Indian Point Nuclear Generating Unit Nos. 2 and 3, SER Supplement 1, published in August 2011, available on Merlin, and at http://www.nrc.gov/reading-rm/adams.html#web-based-adams and Begin Web-based ADAMS Search with Accession # ML11242A215.
8. LO-LAR-2011-0174 IPEC LRA Commitment Corrective Actions.
9. Correspondence from Entergy to NRC, NL-11-101.
10. IP-RPT-06-AMM01, Aging Management Review of the Containment Spray Systems.
11. IP-RPT-06-AMM02, Aging Management Review of the Containment Isolation Support Systems.
12. IP-RPT-06-AMM03, Aging Management Review of the Safety Injection Systems.
13. IP-RPT-06-AMM04, Aging Management Review of the City Water System.
14. IP-RPT-06-AMM08, Aging Management Review of Plant Drains.
15. IP-RPT-06-AMM12, Aging Management Review of the Service Water Systems.
16. IP-RPT-06-AMM16, Aging Management Review of the Fire Protection - Water System.
17. IP-RPT-06-AMM18, Aging Management Review of the Security Generators.
18. IP-RPT-06-AMM21, Aging Management Review of the Fuel Oil Systems.

IPEC License Renewal Implementation Project IP-RPT-11-LRD07 Review of the Buried Piping and Tanks Inspection Aging Revision 0 Management Program for License Renewal Implementation Page 7 of 28

19. IP-RPT-06-AMM24, Aging Management Review of the Auxiliary Feedwater Systems.
20. Entergy Procedure EN-DC-343, Rev. 4, Underground Piping and Tanks Inspection and Monitoring Program
21. CEP-UPT-0100, Rev. 0, Underground Piping and Tanks Inspection and Monitoring.
22. SEP-UIP-IPEC, Rev. 0, Indian Point 2 & 3 Underground Components Inspection Plan.
23. Correspondence from Entergy to NRC, NL-11-032.
24. IP-RPT-06-AMM09, Aging Management Review of the Systems Required for IP2 AFW Pump Room Fire Event

IPEC License Renewal Implementation Project IP-RPT-11-LRD07 Review of the Buried Piping and Tanks Inspection Aging Revision 0 Management Program for License Renewal Implementation Page 8 of 28 3.0 Commitments and License Action Requests (LAR)

Commitments LO-LAR-2011-0174 CA 44 License Renewal Commitment # 3 Implement the Buried Piping and Tanks Inspection Program for IP2 and IP3 as described in LRA Section B.1.6.

This new program will be implemented consistent with the corresponding program described in NUREG-1801 Section XI.M34, Buried Piping and Tanks Inspection.

Include in the Buried Piping and Tanks Inspection Program described in LRA Section B.1.6 a risk assessment of in-scope buried piping and tanks that includes consideration of the impacts of buried piping or tank leakage and of conditions affecting the risk for corrosion.

Classify pipe segments and tanks as having a high, medium or low impact of leakage based on the safety class, the hazard posed by fluid contained in the piping and the impact of leakage on reliable plant operation.

Determine corrosion risk through consideration of piping or tank material, soil resistivity, drainage, the presence of cathodic protection and the type of coating.

Establish inspection priority and frequency for periodic inspections of the in-scope piping and tanks based on the results of the risk assessment.

Perform inspections using inspection techniques with demonstrated effectiveness License Action Requests LO-LAR-2011-0174 CA 44 Evaluate plant specific and appropriate industry operating experience and incorporate lessons learned in establishing appropriate monitoring and inspection frequencies to assess aging effects for the new aging management programs.

Maintain the Buried Piping and Tanks Inspection Program during the Period of Extended Operations as described in the LRA sections A.2.1.5, A.3.1.5, B.1.6 and the current NRC commitment list.

Program documents shall be revised or generated that ensures the program will be maintained during the PEO before closing this corrective action.

LO-LAR-2011-0174 CA 67 Revise Buried Piping program to address concerns discussed in NRC Phase 1 evaluation performed in March 2012.

License renewal commitments are included in LR submittal correspondence from Entergy to NRC NL-11-101 (Ref. 9). These commitments and additional actions are identified in LO-LAR-

IPEC License Renewal Implementation Project IP-RPT-11-LRD07 Review of the Buried Piping and Tanks Inspection Aging Revision 0 Management Program for License Renewal Implementation Page 9 of 28 2011-0174 (Ref. 8). Commitments are to be implemented prior to September 28, 2013 for Unit 2 and prior to December 12, 2015 for Unit 3. The Buried Piping and Tanks Inspection Program is a new IPEC program. Commitments for this program may also be found in NUREG-1930 Safety Evaluation Report, Section 3.0.3.1.2. (Ref. 6)

Source Documents x IPEC License Renewal Application, Appendix B, Section B.1.6 (Ref. 5) x IP-RPT-06-LRD07 Aging Management Program Evaluation - Non-Class 1 Mechanical, Section 3.3 (Ref. 2) x NUREG-1930, SER Related to the License Renewal of Indian Point Nuclear Generating Unit Nos. 2 and 3, published in November 2009 (Ref. 6)

IPEC License Renewal Implementation Project IP-RPT-11-LRD07 Review of the Buried Piping and Tanks Inspection Aging Revision 0 Management Program for License Renewal Implementation Page 10 of 28 4.0 Commitments/LAR Actions/Program Requirements and Program Status The Buried Piping and Tanks Inspection Program is a new IPEC program credited in the following aging management review report(s). (Ref. 2, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 24) x AMM01, Containment Spray Systems x AMM02, Containment Isolation Support Systems x AMM03, Safety Injection Systems x AMM04, City Water System x AMM08, Plant Drains x AMM12, Service Water Systems x AMM16, Fire Protection - Water System x AMM18, Security Generators x AMM21, Fuel Oil Systems x AMM24, Auxiliary Feedwater Systems x AMM09, Systems Required for IP2 AFW Pump Room Fire Event The following are program requirements from the source documents (that are not identified as a commitment) and their current status. Commitments follow the requirements.

1. Buried Piping and Tanks Inspection Program Requirements a) Periodic inspections are performed when the components are excavated for maintenance or for any other reason. The scope of the program covers buried components that are within the scope of license renewal for the plant.

Status: Step 5.2 25 of CEP-UPT-0100 requires opportunistic inspections during site excavating activities. The appendices in SEP-UIP-IPEC specify the inspection strategy for components within the scope of the program including excavation activities (as applicable). The Buried Piping and Tanks Inspection Program provides for the inspection and monitoring of selected operational underground piping and tanks for external corrosion, including crevice, general corrosion, microbiologically influenced corrosion (MIC), pitting corrosion, and other age-related degradation.

Aging effects for the following tanks are managed by the program.

x IP2 Fuel Oil Storage Tanks (21/22/23 FOST) x GT1 Fuel Oil Storage North and South Storage Tanks (GT1-FOT-12 and -11) x IP2 Security Diesel Fuel Tank (SDFT) x IP3 Appendix R Fuel Oil Storage Tank (ARDG-FO-ST) x IP3 Security Propane Fuel Tanks (SPG-TK-001 and -002) x IP3 Fuel Oil Storage tanks (EDG-31/32/33-FO-STNK)

IPEC License Renewal Implementation Project IP-RPT-11-LRD07 Review of the Buried Piping and Tanks Inspection Aging Revision 0 Management Program for License Renewal Implementation Page 11 of 28 Aging effects for buried piping, piping elements, and piping components in the following systems are managed by the program.

x Containment Spray Systems (IP3 only) x Containment Isolation Support Systems x Safety Injection Systems (IP3 only) x City Water System x Plant Drains x Service Water Systems x Fire Protection - Water Systems x Security Propane Generator (IP3 only) x Fuel Oil Systems x Auxiliary Feedwater Systems x River Water System (IP1 only) x Circulating Water System (IP2 only)

Action: Revise Attachment 9.2 of EN-DC-343 to include the Containment Isolation Support System for IPEC Station, the River Water System (IP1 only), and the Circulating Water System (IP2 only).

(Ref. 20)

Implement the requirements of procedure SEP-UIP-IPEC for IPEC prior to and during the period of extended operation.

b) In accordance with industry practice, underground piping and tanks are coated during installation with a protective coating system, such as coal tar enamel with a fiberglass wrap and a kraft paper outer wrap, a polyolifin tape coating, or a fusion bonded epoxy coating to protect the piping from contacting the aggressive soil environment.

Status: In accordance with step 5.7 [2] of EN-DC-343 newly-installed buried components are installed with a protective coating system in accordance with site specifications. Portions of the in-scope buried auxiliary feedwater (CST supply and return to the AFW building) and city water piping are provided with cathodic protection.

Action: See item a) above. Also, annotate step 5.7 [2] of EN-DC-343 with reference to this commitment.

c) The program monitors parameters such as coating and wrapping integrity that are directly related to corrosion damage of the external surface of buried steel piping and tanks. Coatings and wrappings are inspected by visual techniques.

Status: Step 5.2.24 of CEP-UPT-0100 specifies visually examining the condition of coatings and wrappings.

Action: See item a) above. Annotate step 5.2.24 (last bullet) of CEP-UPT-0100 with reference to this commitment.

IPEC License Renewal Implementation Project IP-RPT-11-LRD07 Review of the Buried Piping and Tanks Inspection Aging Revision 0 Management Program for License Renewal Implementation Page 12 of 28 d) Inspections performed to confirm that coating and wrapping are intact are an effective method to ensure that corrosion of external surfaces has not occurred and the intended function is maintained. Buried piping and tanks are opportunistically inspected whenever they are excavated during maintenance. When opportunistic, the inspections are performed in areas with the highest likelihood of corrosion problems, and in areas with a history of corrosion problems, within the areas made accessible to support the maintenance activity.

Status: Step 5.2.24 of CEP-UPT-0100 specifies a combination of indirect inspections and direct examinations to provide reasonable assurance the intended function is maintained. Step 5.2 25 of CEP-UPT-0100 requires opportunistic inspections during site excavating activities. The appendices in SEP-UIP-IPEC specify the inspection strategy for components within the scope of the program including excavation activities (as applicable).

Inspections utilize corrosion risk assessment and impact assessment tables in CEP-UPT-0100 to prioritize components that have the highest risk ranking.

Action: See item a) above. Annotate step 5.2 25 of CEP-UPT-0100 with reference to this commitment.

e) Prior to entering the period of extended operation, the applicant is to verify that there is at least one opportunistic or focused inspection is performed within the past ten years. Upon entering the period of extended operation, the applicant is to perform a focused inspection within ten years, unless an opportunistic inspection occurred within this ten-year period. Any credited inspection should be performed in areas with the highest likelihood of corrosion problems, and in areas with a history of corrosion problems.

Status: The following inspections were specified in NRC correspondence (Ref. 23).

For the 10-year period prior to the PEO, the following table presents the planned inspections for buried piping subject to aging management review that is code safety-related (Code/SR) or has the potential to release materials detrimental to the environment (hazmat). Inspections by material and category are indicated.

Material Category IP2 Inspections IP3 Inspections Carbon steel Code/SR 13 14 Carbon steel Hazmat 13 5 Stainless steel Hazmat N/A 6 The following table provides the number of planned direct visual inspections prior to the PEO. For planned direct visual inspections, future excavations will expose a minimum of 10 linear feet of pipe, for full circumferential inspections.

IPEC License Renewal Implementation Project IP-RPT-11-LRD07 Review of the Buried Piping and Tanks Inspection Aging Revision 0 Management Program for License Renewal Implementation Page 13 of 28 Material Category IP2 Inspections IP3 Inspections Carbon steel Code/SR 9 8 Carbon steel Hazmat 11 3 Stainless steel Hazmat N/A 3 IPEC will perform direct visual inspections during each 10-year period of the PEO in accordance with the following table. The table lists inspections for different materials, for code/safety-related piping, and for piping with the potential to release materials detrimental to the environment (indicated as hazmat.)

Material Category IP2 Inspections IP3 Inspections Carbon steel Code/SR 6 6 Carbon steel Hazmat 8 8 Stainless steel Hazmat N/A 2 If sample results indicate the soil is corrosive, then the number of inspections for the carbon steel code/safety-related piping will be increased to eight, and the total number of inspections will be increased to 20 for IP2 and 22 for IP3 during each 10-year period of the PEO.

To provide additional assurance that the piping will remain capable of performing its intended function, soil will be sampled prior to the PEO to confirm that the soil conditions are not aggressive. The number of inspections during the PEO will be based on the results of the soil samples.

The soil samples will be taken prior to the period of extended operation and at least once every 10 years thereafter to confirm the initial sample results. Soil samples will be taken at a minimum of two locations at least three feet below the surface near in-scope piping to obtain representative soil conditions for each system. The parameters monitored will include soil moisture, pH, chlorides, sulfates, and resistivity. American Water Works Association (AWWA) Standard C105 Appendix A will be used to determine corrosiveness of the soil in addition to soil resistivity. If the soil resistivity is < 20,000 ohm-cm or the soil scores higher than 10 points using AWWA C105, the number of inspections will be increased to provide additional assurance that the piping can perform its design function during the PEO.

Action: Create work orders to perform direct visual inspections prior to the PEO and during each 10-year period of the PEO that implement the Buried Piping and Tanks Inspection Program for IP2 and IP3 in accordance with SEP-UIP-IPEC.

IPEC License Renewal Implementation Project IP-RPT-11-LRD07 Review of the Buried Piping and Tanks Inspection Aging Revision 0 Management Program for License Renewal Implementation Page 14 of 28 Create work orders to take soil samples prior to the period of extended operation and at least once every 10 years thereafter to confirm that the soil conditions are not aggressive. The parameters monitored include soil moisture, pH, chlorides, sulfates, and resistivity. Use American Water Works Association (AWWA) Standard C105 Appendix A to determine corrosiveness of the soil in addition to soil resistivity.

Update SEP-UIP-IPEC to include these additional inspections and soil sampling requirements and annotate procedure with reference to LO-LAR-2011-0174 CA 44.

f) Results of previous inspections are used to identify susceptible locations.

Status: Step 5.2.4 of CEP-UPT-0100 establishes the inspection priority and interval based on the results of the impact assessment and the corrosion risk assessment. Note 4 in Table 9-5 of CEP-UPT-0100 requires that once inspections are performed and conditions become known, a re-prioritization may maintain, decrease, or increase a component future inspection priority.

Action: Annotate Note 4 in Table 9-5of CEP-UPT-0100 with reference to this commitment.

g) Any coating and wrapping degradations are reported and evaluated according to site corrective actions procedures.

Status: Step 5.5.4 of CEP-UPT-0100 directs the initiation of a condition report when acceptance criteria are not satisfied. The corrective actions may include engineering evaluations, additional inspections, change of coating or replacement of corrosion susceptible components. Components that do not meet the acceptance criteria shall be subject to engineering disposition.

The disposition shall include an evaluation determining the required expansion of sampling scope.

Action: Annotate step 5.5.4 of CEP-UPT-0100 with reference to this commitment.

The following are commitments and their current status:

2. LO-LAR-2011-0174 CA 44 License Renewal Commitment # 3 a) Implement the Buried Piping and Tanks Inspection Program for IP2 and IP3 as described in LRA Section B.1.6.

Status: Not completed.

Action: See item 1e) above.

IPEC License Renewal Implementation Project IP-RPT-11-LRD07 Review of the Buried Piping and Tanks Inspection Aging Revision 0 Management Program for License Renewal Implementation Page 15 of 28 b) Include in the Buried Piping and Tanks Inspection Program described in LRA Section B.1.6 a risk assessment of in-scope buried piping and tanks that includes consideration of the impacts of buried piping or tank leakage and of conditions affecting the risk for corrosion.

Status: Step 5.2.4 of CEP-UPT-0100 requires the use of a corrosion risk assessment and impact assessment to establish the inspection priority and interval based on risk ranking. The corrosion risk assessment is organized into categories reflecting four factors (soil resistivity, soil drainage, piping/tank material type, and cathodic protection/coating) that impact the degree of corrosion risk due to design and environmental conditions. The impact assessment considers safety class, public risk, and economics to rank components. These assessments are incorporated into the inspection appendices in SEP-UIP-IPEC.

Action: Annotate step 5.2 4 of CEP-UPT-0100 with reference to this commitment.

c) Classify pipe segments and tanks as having a high, medium or low impact of leakage based on the safety class, the hazard posed by fluid contained in the piping and the impact of leakage on reliable plant operation.

Status: See item 2b) above.

Action: See item 2b) above.

d) Determine corrosion risk through consideration of piping or tank material, soil resistivity, drainage, the presence of cathodic protection and the type of coating.

Status: See item 2b) above.

Action: See item 2b) above.

e) Establish inspection priority and frequency for periodic inspections of the in-scope piping and tanks based on the results of the risk assessment.

Status: See item 2b) above.

Action: See item 2b) above.

f) Perform inspections using inspection techniques with demonstrated effectiveness.

Status: Section H of SEP-UIP-IPEC specifies the inspection strategies for components in the program and incorporates them into the inspection appendices in the procedure. Classic non-destructive examinations [NDE] (surface and volumetric) are performed

IPEC License Renewal Implementation Project IP-RPT-11-LRD07 Review of the Buried Piping and Tanks Inspection Aging Revision 0 Management Program for License Renewal Implementation Page 16 of 28 either by entering the segment (if sufficiently large) with the use of robots or pigs, by tools using electronic scanning techniques or by direct measurement of the segment surface following excavation. Indirect inspection tools consist of the guided wave technique which has value for inspecting piping near penetrations to buildings. See EPRI Report IR-2010-409 and CEP-UPT-0100 for further discussion on NDE methods.

Action: See item 1e) above.

The following are LAR actions and their current status:

3. LO-LAR-2011-0174 CA 44 a) Evaluate plant specific and appropriate industry operating experience and incorporate lessons learned in establishing appropriate monitoring and inspection frequencies to assess aging effects for the new aging management programs.

Status: Step 5.1.4 of CEP-UPT-0100 requires the program owner to maintain cognizance of industry issues/events, operating experience (OE), best practices, and NRC expectations. Step 5.2.11 of CEP-UPT-0100 requires that OE be included in the site database for the program. Section I of SEP-UIP-IPEC incorporates operating experience into the program.

Action: Documentation of the operating experience evaluated for this new program needs to be performed and available on site for NRC review prior to the period of extended operation. This action is captured in LO-LAR-2011-0174 CA 40.

b) Maintain the Buried Piping and Tanks Inspection Program during the Period of Extended Operations as described in the LRA sections A.2.1.5, A.3.1.5, B.1.6 and the current NRC commitment list. Program documents shall be revised or generated that ensures the program will be maintained during the PEO before closing this corrective action.

Status: Not completed.

Action: Requirement met through the implementation of SEP-UIP-IPEC and other requirements. No additional action other than those specified above required at this time. See items above with actions.

4. LO-LAR-2011-0174 CA 67 a) Revise Buried Piping Program to address concerns discussed in NRC Phase 1 evaluation performed in March 2012.

Status: See Item 1a) above.

IPEC License Renewal Implementation Project IP-RPT-11-LRD07 Review of the Buried Piping and Tanks Inspection Aging Revision 0 Management Program for License Renewal Implementation Page 17 of 28 Action: Requirement met through the implementation of SEP-UIP-IPEC and other requirements. No additional action other than those specified above required at this time.

IPEC License Renewal Implementation Project IP-RPT-11-LRD07 Review of the Buried Piping and Tanks Inspection Aging Revision 0 Management Program for License Renewal Implementation Page 18 of 28 5.0 Site Program Owner/Lead Bob Lee - IP2 and IP3 Nelson Azevedo (Supervisor)

Mike Tesoriero (Manager)

IPEC License Renewal Implementation Project IP-RPT-11-LRD07 Revision 0 Review of the Buried Piping and Tanks Inspection Aging Management Program for License Renewal Page 19 of 28 Implementation

.

Attachment 1: License Renewal Buried Piping and Tanks Inspection Program Implementation Action Tracking Commitments and Program Commitment / Program Requirement Affected Recommended Action(s) and Action Requirements Status Procedure(s) Completion Date Status/

(or other Date documentation) 1a) Periodic inspections are Step 5.2 25 of CEP-UPT-0100 requires EN-DC-343 Revise Attachment 9.2 of EN-performed when the components opportunistic inspections during site (Ref. 20) DC-343 to include the are excavated for maintenance or excavating activities. The appendices Containment Isolation Support for any other reason. The scope in SEP-UIP-IPEC specify the inspection System for IPEC Station, the of the program covers buried strategy for components within the River Water System (IP1 only),

components that are within the scope of the program including and the Circulating Water scope of license renewal for the excavation activities (as applicable). System (IP2 only).

plant. The Buried Piping and Tanks Inspection Implement the requirements of Program provides for the inspection and procedure SEP-UIP-IPEC for monitoring of selected operational IPEC prior to and during the underground piping and tanks for period of extended operation.

external corrosion, including crevice, general corrosion, microbiologically influenced corrosion (MIC), pitting IP2: September 28, 2013 corrosion, and other age-related IP3: December 12, 2015 degradation.

Aging effects for the following tanks are managed by the program.

  • IP2 Fuel Oil Storage Tanks (21/22/23 FOST)
  • GT1 Fuel Oil Storage North and South Storage Tanks (GT1-FOT-11,

-12)

  • IP2 Security Diesel Fuel Tank (SDFT)

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(or other Date documentation)

  • IP3 Appendix R Fuel Oil Storage Tank (ARDG-FO-ST)
  • IP3 Security Propane Fuel Tanks (SPG-TK-001, -002)
  • IP3 Fuel Oil Storage tanks (EDG-31/32/33-FO-STNK)

Aging effects for buried piping, piping elements, and piping components in the following systems are managed by the program.

  • Containment Isolation Support Systems
  • Safety Injection Systems (IP3 only)
  • City Water System
  • Plant Drains
  • Fire Protection - Water Systems
  • Security Propane Generators (IP3 only)
  • Fuel Oil Systems
  • River Water System (IP1 only)

Not completed - procedure needs to be revised and program implemented.

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(or other Date documentation) 1b) In accordance with industry In accordance with step 5.7 [2] of EN- See item 1a) See item 1a) above. Also, practice, underground piping and DC-343 newly-installed buried above. annotate step 5.7 [2] of EN-DC-tanks are coated during components are installed with a 343 with reference to this installation with a protective protective coating system in accordance commitment.

coating system, such as coal tar with site specifications. Portions of the enamel with a fiberglass wrap in-scope buried auxiliary feedwater and a kraft paper outer wrap, a (CST supply and return to the AFW polyolifin tape coating, or a fusion building) and city water piping are bonded epoxy coating to protect provided with cathodic protection.

the piping from contacting the aggressive soil environment. Not completed - procedure needs to be annotated.

1c) The program monitors Step 5.2.24 of CEP-UPT-0100 specifies CEP-UPT-0100 See item 1a) above. Also, parameters such as coating and visually examining the condition of (Ref. 21) annotate step 5.2.24 (last wrapping integrity that are directly coatings and wrappings. bullet) of CEP-UPT-0100 with related to corrosion damage of reference to this commitment.

the external surface of buried Not completed - procedure needs to be steel piping and tanks. Coatings annotated.

and wrappings are inspected by visual techniques.

1d) Inspections performed to Step 5.2.24 of CEP-UPT-0100 specifies See item 1c) See item 1a) above. Also, confirm that coating and wrapping a combination of indirect inspections above. annotate step 5.2 25 of CEP-are intact are an effective method and direct examinations to provide UPT-0100 with reference to this to ensure that corrosion of reasonable assurance the intended commitment.

external surfaces has not function is maintained. Step 5.2 25 of occurred and the intended CEP-UPT-0100 requires opportunistic function is maintained. Buried inspections during site excavating piping and tanks are activities. The appendices in SEP-UIP-

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(or other Date documentation) opportunistically inspected IPEC specify the inspection strategy for whenever they are excavated components in the program including during maintenance. When excavation activities (as applicable).

opportunistic, the inspections are Inspections utilize corrosion risk performed in areas with the assessment and impact assessment highest likelihood of corrosion tables in CEP-UPT-0100 to prioritize problems, and in areas with a components that have the highest risk history of corrosion problems, ranking.

within the areas made accessible to support the maintenance Not completed - procedure needs to be activity. annotated.

1e) Prior to entering the period of For the 10-year period prior to the PEO, Work Orders, Create work orders to perform extended operation, the applicant the table under item 1e) in section 4.0 SEP-UIP-IPEC direct visual inspections prior to is to verify that there is at least of this report presents the planned (Ref. 22) the PEO and during each 10-one opportunistic or focused inspections for buried piping subject to year period of the PEO that inspection is performed within the aging management review that is code implement the Buried Piping past ten years. Upon entering safety-related (Code/SR) or has the and Tanks Inspection Program the period of extended operation, potential to release materials for IP2 and IP3 in accordance the applicant is to perform a detrimental to the environment with SEP-UIP-IPEC.

focused inspection within ten (hazmat). Inspections by material and Create work orders to take soil years, unless an opportunistic category are also indicated. samples prior to the period of inspection occurred within this extended operation and at least The table under item 1e) in section 4.0 ten-year period. Any credited once every 10 years thereafter of this report provides the number of inspection should be performed in to confirm that the soil planned direct visual inspections prior to areas with the highest likelihood conditions are not aggressive.

the PEO. For planned direct visual of corrosion problems, and in The parameters monitored inspections, future excavations will areas with a history of corrosion include soil moisture, pH, expose a minimum of 10 linear feet of problems. chlorides, sulfates, and

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(or other Date documentation) pipe, for full circumferential inspections. resistivity. Use American Water Works Association IPEC will perform direct visual (AWWA) Standard C105 inspections during each 10-year period Appendix A to determine of the PEO in accordance with the table corrosiveness of the soil in under item 1e) in section 4.0 of this addition to soil resistivity.

report. The table lists inspections for different materials, for code/safety- Update SEP-UIP-IPEC to related piping, and for piping with the include these additional potential to release materials inspections and soil sampling detrimental to the environment requirements and annotate (indicated as hazmat.) procedure with reference to LO-LAR-2011-0174 CA 44.

To provide additional assurance that the piping will remain capable of performing its intended function, soil will be sampled prior to the PEO to confirm that the soil conditions are not aggressive. The number of inspections during the PEO will be based on the results of the soil samples.

The soil samples will be taken prior to the period of extended operation and at least once every 10 years thereafter to confirm the initial sample results. Soil samples will be taken at a minimum of two locations at least three feet below the surface near in-scope piping to obtain representative soil conditions for

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(or other Date documentation) each system. The parameters monitored will include soil moisture, pH, chlorides, sulfates, and resistivity.

American Water Works Association (AWWA) Standard C105 Appendix A will be used to determine corrosiveness of the soil in addition to soil resistivity. If the soil resistivity is < 20,000 ohm-cm or the soil scores higher than 10 points using AWWA C105, the number of inspections will be increased to provide additional assurance that the piping can perform its design function during the PEO.

Not completed - work needs to be implemented and results documented.

Procedure needs to be annotated.

1f) Results of previous Step 5.2.4 of CEP-UPT-0100 See item 1c) Annotate Note 4 in Table 9-5of inspections are used to identify establishes the inspection priority and above. CEP-UPT-0100 with reference susceptible locations. interval based on the results of the to this commitment.

impact assessment and the corrosion risk assessment. Note 4 in Table 9-5 of CEP-UPT-0100 requires that once inspections are performed and conditions become known, a re-prioritization may maintain, decrease, or increase a component future inspection

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(or other Date documentation) priority.

Not completed - procedure needs to be annotated.

1g) Any coating and wrapping Step 5.5.4 of CEP-UPT-0100 directs the See item 1c) Annotate step 5.5.4 of CEP-degradations are reported and initiation of a condition report when above. UPT-0100 with reference to this evaluated according to site acceptance criteria are not satisfied. commitment corrective actions procedures. The corrective actions may include engineering evaluations, additional inspections, change of coating or replacement of corrosion susceptible components. Components that do not meet the acceptance criteria shall be subject to engineering disposition. The disposition shall include an evaluation determining the required expansion of sampling scope.

Not completed - procedure needs to be annotated.

2a) Implement the Buried Piping Not completed - work needs to be Work Orders See item 1e) above and Tanks Inspection Program implemented and results documented.

for IP2 and IP3 as described in LRA Section B.1.6.

2b) Include in the Buried Piping Step 5.2.4 of CEP-UPT-0100 requires See item 1c) Annotate step 5.2 4 of CEP-and Tanks Inspection Program the use of a corrosion risk assessment above. UPT-0100 with reference to this described in LRA Section B.1.6 a and impact assessment to establish the commitment.

risk assessment of in-scope inspection priority and interval based on buried piping and tanks that risk ranking. The corrosion risk

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(or other Date documentation) includes consideration of the assessment is organized into categories impacts of buried piping or tank reflecting four factors (soil resistivity, leakage and of conditions soil drainage, piping/tank material type, affecting the risk for corrosion. and cathodic protection/coating) that impact the degree of corrosion risk due to design and environmental conditions.

The impact assessment considers safety class, public risk, and economics to rank components. These assessments are incorporated into the inspection appendices in SEP-UIP-IPEC.

2c) Classify pipe segments and See item 2b) above. See item 1c) See item 2b) above.

tanks as having a high, medium above.

or low impact of leakage based on the safety class, the hazard posed by fluid contained in the piping and the impact of leakage on reliable plant operation.

2d) Determine corrosion risk See item 2b) above. See item 1c) See item 2b) above.

through consideration of piping or above.

tank material, soil resistivity, drainage, the presence of cathodic protection and the type of coating.

2e) Establish inspection priority See item 2b) above. See item 1c) See item 2b) above.

and frequency for periodic above.

inspections of the in-scope piping

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(or other Date documentation) and tanks based on the results of the risk assessment.

2f) Perform inspections using Section H of SEP-UIP-IPEC specifies See item 1e) See item 1e) above.

inspection techniques with the inspection strategies for above.

demonstrated effectiveness. components in the program and incorporates them into the inspection appendices in the procedure. Classic non-destructive examinations [NDE]

(surface and volumetric) are performed either by entering the segment (if sufficiently large) with the use of robots or pigs, by tools using electronic scanning techniques or by direct measurement of the segment surface following excavation. Indirect inspection tools consist of the guided wave technique which has value for inspecting piping near penetrations to buildings. See EPRI Report IR-2010-409 and CEP-UPT-0100 for further discussion on NDE methods.

3a) Evaluate plant specific and Step 5.1.4 of CEP-UPT-0100 requires See item 1c) Documentation of the operating appropriate industry operating the program owner to maintain above. experience evaluated for this experience and incorporate cognizance of industry issues/events, new program needs to be lessons learned in establishing operating experience (OE), best performed and available on site appropriate monitoring and practices, and NRC expectations. Step for NRC review prior to the inspection frequencies to assess 5.2.11 of CEP-UPT-0100 requires that period of extended operation.

aging effects for the new aging OE be included in the site database for This action is captured in LO-

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(or other Date documentation) management programs. the program.Section I of SEP-UIP- LAR-2011-0174 CA 40.

IPEC incorporates operating experience into the program.

3b) Maintain the Buried Piping Not completed - need to implement See item 1e) Requirement met through the and Tanks Inspection Program program and document results. above. implementation of SEP-UIP-during the Period of Extended IPEC and other requirements.

Operations as described in the No additional action other than LRA sections A.2.1.5, A.3.1.5, those specified above required B.1.6 and the current NRC at this time. See items above commitment list. Program with actions.

documents shall be revised or generated that ensures the program will be maintained during the PEO before closing this corrective action.

4a) Revise Buried Piping program Not completed - need to implement See item 1a) Requirement met through the to address concerns discussed in program and document results. above. implementation of SEP-UIP-NRC Phase 1 evaluation IPEC and other requirements.

performed in March 2012. No additional action other than those specified above required at this time.

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