ML14072A035

Notification of Inspection and Request for Information

ML14072A035
Person / Time
Site:	Sequoyah
Issue date:	03/10/2014
From:	Omar Lopez-Santiago NRC/RGN-II/DRS/EB3
To:	James Shea Tennessee Valley Authority
References
Download: ML14072A035 (9)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 March 10, 2014 Mr. Joseph W. Shea Vice President, Nuclear Licensing Tennessee Valley Authority 1101 Market Street, LP 3D-C Chattanooga, TN 37402-2801

SUBJECT:

SEQUOYAH NUCLEAR PLANT - NOTIFICATION OF INSPECTION AND REQUEST FOR INFORMATION

Dear Mr. Shea:

On April 2, 2014, the Nuclear Regulatory Commission (NRC) will begin inspection activities for the Sequoyah Nuclear Plant, Units 1, and 2, in accordance with Temporary Instruction (TI) 2515-182, Review of Implementation of the Industry Initiative to Control Degradation of Underground Piping and Tanks. This inspection is scheduled to be performed from April 2 - 4, 2014, and will address the inspection requirements for Phase 2 of this TI.

In order to minimize the impact to your on-site resources, and to ensure a productive inspection, we have enclosed a list of documents needed for the preparation and implementation of this inspection. The documents that are requested for this inspection include all relevant documents that will allow the inspector(s) to adequately complete Phase 2 of this 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. Don Sutton, of your organization. If there are any questions about this inspection or the material requested, please contact the lead inspector Brendan Collins at (404) 997-4420 or Brendan.Collins@nrc.gov.

In accordance with 10 CFR 2.390 of the NRCs 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 Agencywide

J. Shea 2 Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/ adams.html (the Public Electronic Reading Room).

Sincerely, RA Omar R. López-Santiago, Chief (Acting)

Engineering Branch 3 Division of Reactor Safety Docket Nos.: 50-327, 50-328 License Nos.: DPR-77, DPR-79

Enclosure:

Temporary Instruction (TI 2515-182)

Inspection Document Request TI-182 Phase II Questions Distribution via Listserv

__________ X SUNSI REVIEW COMPLETE X FORM 665 ATTACHED OFFICE RII:DRS RII:DRS SIGNATURE RA RA NAME B. Collins O. López-Santiago DATE 3/6 /2014 3/10/2014 E-MAIL COPY? YES NO YES NO TEMPORARY INSTRUCTION 2515-182 INSPECTION DOCUMENT REQUEST Inspection Dates: April 2 - 4, 2014 Inspection Procedures: TI 2515-182, Review of Implementation of the Industry Initiative to Control Degradation of Underground Piping and Tanks Inspector: Brendan Collins, Reactor Inspector Information Requested for the Preparation and Completion of the In-Office Inspection:

The following documents listed below are requested (electronic copy, if possible) by March 24, 2014, to facilitate the preparation for the on-site inspection week.

1. Contact information for plant staff responsible for the implementation of the underground piping and tanks program.

2. Copy of the documents governing the implementation of the sites underground piping and tanks program. For example, this includes administrative and implementing procedures for the program.

3. Please review the Attachment to this Enclosure, TI 2515-182, Review of Implementation of the Industry Initiative to Control Degradation of Underground Piping and Tanks, Phase 2 Questions, and provide response to all the questions, as applicable.

4. Schedule for completion of the following NEI 09-14, Guideline for the Management of Underground Piping and Tank Integrity, Revision 3, 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 Information to be provided On-Site to the Inspector following the Entrance Meeting:

1. Copy or ready access to the program drawings showing the location of buried and underground piping and tanks within the scope of the program.

2. Copy or ready access to the industry standards and guidelines associated with the program.

Enclosure

2

3. Self- or third-party assessments of the underground piping and tanks program (if any have been performed).

4. Response to additional information requested prior to the inspection based on the response to the TI 2515-182 questions in the Attachment.

5. For any of the NEI 09-14 (Revision 3) attributes identified below which have been completed prior to the NRCs onsite 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 Inspector Contact Information Mailing Address Brendan Collins US NRC- Region II Reactor Inspector Attn: Brendan Collins 404-997-4420 245 Peachtree Center Avenue, Suite 1200 Brendan.Collins@nrc.gov Atlanta, GA 30303

TI 2515-182 Review of Implementation of the Industry Initiative to Control Degradation of Underground Piping and Tanks Phase 2 Questions Questions Response Question Subpart Number Initiative Consistency 1 a Has the licensee taken any deviations to either of Yes / No the initiatives?

b If so, what deviations have been taken and what is (are) the basis for these deviations?

2 a Does the licensee have an onsite buried piping Yes / No program manager (owner) and, potentially, a staff?

b How many buried piping program owners have there been since January 1, 2010?

c How many other site programs are assigned to the buried piping program owner?

3 a Does the licensee have requirements to capture Yes / No program performance, such as system health reports and performance indicators?

b Are these requirements periodic or event driven? Periodic /

Event Driven /

None c Are there examples where these requirements Yes / No have been successfully used to upgrade piping systems or to avert piping or tank leaks?

4 a Does the licensee have a program or procedure Yes / No to confirm the as-built location of buried and underground piping and tanks at the plant?

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

Attachment

2 5 For a sample of buried pipe and underground Yes / No piping and tanks (sample size at least 1 high and Sample size 1 low risk/priority pipe or tank), did the risk examined ranking and/or prioritization process utilized by _____

the licensee produce results in accordance with the initiative guidelines, i.e., which emphasize the importance of components which have a high likelihood and consequence of failure and deemphasize the importance of components which have a low likelihood and consequence of failure?

6 a 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?

b 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 1 a For uncoated steel piping, has the licensee Yes / No / Not developed a technical basis for concluding that Applicable (no structural (e.g. ASME Code minimum wall, if uncoated applicable) and leaktight integrity of buried piping buried steel can be maintained? pipe) b Is the technical basis provided as justification by Yes / No the licensee consistent with the initiative (including its reference documents) or industry standards (e.g. NACE SP0169) 2 a For buried steel, copper, or aluminum piping or Yes / No / Not tanks which are not cathodically protected, has Applicable (no the licensee developed a technical basis for buried steel, concluding that structural (e.g. ASME Code copper, or minimum wall, if applicable) and leaktight aluminum integrity of buried piping can be maintained? piping which is not cathodically protected) b Is the technical basis provided as justification by Yes / No the licensee consistent with the initiative (including its reference documents) or industry standards (e.g. NACE SP0169)

3 3 a For licensees with cathodic protection systems, Yes / No / Not does the licensee have procedures for the Applicable (no maintenance, monitoring and surveys of this cathodic equipment? protection systems) b Are the licensee procedures consistent with the Yes / No initiative (including its reference documents) or industry standards (e.g. NACE SP0169)?

c Is the cathodic protection system, including the Yes / No evaluation of test data, being operated and maintained by personnel knowledgeable of, or trained in, such activities 4 Is there a program to ensure chase and vault Yes / No / N/A areas which contain piping or tanks subject to the (No piping in underground piping and tanks initiative are chases or monitored for, or protected against, accumulation vaults) of leakage from these pipes or tanks?

Inspection Activities / Corrective Actions 1 a Has the licensee prepared an inspection plan for Yes / No its buried piping and underground piping and tanks?

b Does the plan specify dates and locations where Yes / No inspections are planned?

c Have inspections, for which the planned dates Occurred as have passed, occurred as scheduled or have a scheduled /

substantial number of inspections been deferred? Deferred 2 a Has the licensee experienced leaks and/or Leaks Yes / No significant degradation in safety related piping or Degradation piping carrying licensed material since January 1, Yes / No 2009?

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

4 c Based on a review of a sample of root cause Yes / No / N/A analyses for leaks from buried piping or (no leaks) underground piping and tanks which are safety related or contain licensed material, did the licensee's corrective action taken as a result of the incident include addressing the cause of the degradation?

d Did the corrective action include an evaluation of Yes / No / N/A extent of condition of the piping or tanks and (no leaks) possible expansion of scope of inspections?

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

3 a Based on a review of a sample of NDE activities Yes / No which were either directly observed or for which records were reviewed, were the inspections conducted using a predetermined set of licensee/contractor procedures?

b Were these procedures sufficiently described and Yes / No recorded such that the inspection could be reproduced at a later date?

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

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

4 Did the licensee disposition direct or indirect NDE Yes / No results in accordance with their procedural requirements?

5 Based on a sample of piping segments, is there Yes / No evidence that licensees are substantially meeting the pressure testing requirements of ASME Section XI IWA-5244?