ML22301A153
| ML22301A153 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 11/09/2022 |
| From: | Nick Taylor NRC/RGN-IV/DORS/EB2 |
| To: | Sullivan J Entergy Operations |
| Taylor N | |
| References | |
| EA-22-099 IR 2022011 | |
| Download: ML22301A153 (28) | |
See also: IR 05000313/2022011
Text
November 09, 2022
Joseph Sullivan
Site Vice President
Entergy Operations, Inc.
N-TSB-58
1448 S.R. 333
Russellville, AR 72802-0967
SUBJECT: ARKANSAS NUCLEAR ONE - NOTICE OF VIOLATION; NRC INSPECTION
REPORT 05000313/2022011 AND 05000368/2022011
Dear Joseph Sullivan:
On October 25, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection
at Arkansas Nuclear One and discussed the results of this inspection with you and other
members of your staff. The results of this inspection are documented in the enclosed report,
Enclosure 2.
The enclosed report discusses a violation associated with a finding of very low safety
significance (Green). The NRC evaluated this violation in accordance with Section 2.3.2 of the
NRC Enforcement Policy, which can be found on the NRC website at http://www.nrc.gov/about-
nrc/regulatory/enforcement/enforce-pol.html. The violation met the criteria for treatment as a
non-cited violation; however, because the violation is associated with Entergys failure to
manage longstanding age-related degrading conditions in your buried service water supply
piping and given that subsequent follow-up inspection to ensure compliance with your renewed
operating license will be needed, the NRC determined the issuance of a Notice of Violation
(Enclosure 1) is appropriate in this case.
You are required to respond to this letter and should follow the instructions specified in the
Notice of Violation when preparing your response. If you have additional information that you
believe the NRC should consider, you may provide it in your response. The NRCs review of
your response will also determine whether further enforcement action is necessary to ensure
your compliance with regulatory requirements.
In addition, a violation of minor significance is documented in the enclosed report.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a
response within 30 days of the date of this inspection report, with the basis for your
disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk,
Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the
NRC Resident Inspector at Arkansas Nuclear One.
J. Sullivan
2
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice and Procedure, a copy of
this letter, its enclosures, and your response will be made available electronically for public
inspection in the NRC Public Document Room or in the NRCs Agencywide Documents
Access and Management System (ADAMS), accessible from the NRC website at
http://www.nrc.gov/reading-rm/adams.html. To the extent possible, any response should not
include any personal privacy or proprietary information so that it can be made available to the
public without redaction.
Sincerely,
Nicholas H. Taylor
Engineering Branch 2
Division of Operating Reactor Safety
Docket Nos. 05000313, 05000368
Enclosures:
2. Inspection Report 05000313/2022011
and 05000368/2022011 w/Attachment
cc w/ encl: Distribution via LISTSERV
Signed by Taylor, Nicholas
on 11/09/22
SUNSI Review:
ADAMS:
Non-Publicly Available Non-Sensitive
Keyword:
By: GAP
Yes No
Publicly Available
Sensitive
OFFICE
SRI:EB2
SRI:EB2
SRI:EB2
RI:EB2
C:PBD
ES:ACES
NAME
GPick
CSmith
JDrake
JMejia
JDixon
ARoberts
SIGNATURE
/RA/ E
/RA/ E
/RA/ E
/RA/ E
/RA/ E
/RA/ E
DATE
10/28/22
10/31/22
10/29/22
10/31/22
10/31/22
10/28/22
OFFICE
TL:ACES
DD:DORS
D:DORS
C:EB2
NAME
JGroom
DJones
SKirkwood
MHay
R.Lantz
N.Taylor
SIGNATURE
/RA/ E
/RA/ E
/RA/E
/RA/ E
/RA/ E
DATE
10/28/22
11/08/22
11/07/22
11/09/22
10/31/22
11/01/22
Enclosure
Entergy Operations, Inc.
Docket Nos. 50-313, 50-368
Arkansas Nuclear One, Units 1 and 2
During an NRC inspection conducted from June 13 through October 25, 2022, a violation of
NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation
is listed below:
10 CFR Part 50, Appendix B, Criterion III, requires, in part, that measures shall be
established for verifying or checking the adequacy of design, such as by the performance of
design reviews, using alternate or simplified calculational methods, or by the performance of
a suitable testing program.
Unit 1 UFSAR, section 16.2.19, Service Water Integrity states, in part, that thickness
mapping and visual inspections manage the aging effects of loss of material from the
service water components.
Unit 2 UFSAR, section 18.1.25, Service Water Integrity Program [SWIP] states, in part,
that the program relies on implementation of the recommendations of NRC Generic
Letter 89-13, Service Water System Problems Affecting Safety-Related Equipment, to
ensure that the effects of aging on the service water system will be managed. The licensees
response to Generic Letter 89-13, dated January 26, 1990 (ML20006B723), Attachment 3
Program Document for SWIP Long-term Program Plans, section titled Non-Destructive
Examination, Step 2 states, in part, that mapping of piping thickness at selected locations
with computerized ultrasonic equipment is periodically performed and trended.
Contrary to the above, from April 12, 2001, for Unit 1 and from April 7, 2005, for Unit 2, to
September 29, 2022, the licensee failed to establish measures for verifying or checking the
adequacy of design by the performance of a suitable testing program for the service water
system. Specifically, when managing the effects of aging, the licensee had not performed
thickness measurements of its buried in-scope emergency cooling pond supply piping to
provide reasonable assurance that the service water system remained capable of
performing its design function.
This violation is associated with a Green Significance Determination Process finding.
Pursuant to the provisions of 10 CFR 2.201, Entergy Operations, Inc., is hereby required to
submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001, with a copy to the Regional
Administrator, U.S. Nuclear Regulatory Commission, Region IV, 1600 E. Lamar Blvd., Arlington,
TX 76011-4511, and a copy to the NRC resident inspector at Arkansas Nuclear One, and email
it to R4Enforcement@nrc.gov, within 30 days of the date of the letter transmitting this Notice of
Violation (Notice). This reply should be clearly marked as a Reply to a Notice of Violation;
EA-22-099 and should include for the violation: (1) the reason for the violation or, if contested,
the basis for disputing the violation or severity level, (2) the corrective steps that have been
taken and the results achieved, (3) the corrective steps that will be taken, and (4) the date when
full compliance will be achieved.
2
Your response may reference or include previous docketed correspondence if the
correspondence adequately addresses the required response. If an adequate reply is not
received within the time specified in this Notice, an order or a Demand for Information may be
issued as to why the license should not be modified, suspended, or revoked, or why such other
action as may be proper should not be taken. Where good cause is shown, consideration will
be given to extending the response time.
If you contest this enforcement action, you should also provide a copy of your response, with the
basis for your denial, to the Director, Office of Enforcement, United States Nuclear Regulatory
Commission, Washington, DC 20555-0001.
Because your response will be made available electronically for public inspection in the NRC
Public Document Room or from the NRCs Agencywide Documents Access and Management
System (ADAMS), accessible from the NRC website at http://www.nrc.gov/reading-
rm/adams.html, to the extent possible, it should not include any personal privacy or proprietary
information so that it can be made available to the public without redaction.
If personal privacy or proprietary information is necessary to provide an acceptable response,
then please provide a bracketed copy of your response that identifies the information that
should be protected and a redacted copy of your response that deletes such information. If you
request that such material is withheld from public disclosure, you must specifically identify the
portions of your response that you seek to have withheld and provide in detail the bases for your
claim (e.g., explain why the disclosure of information will create an unwarranted invasion of
personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for
withholding confidential commercial or financial information).
Dated this 9th day of November 2022
Enclosure 2
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Numbers:
05000313 and 05000368
License Numbers:
Report Numbers:
05000313/2022011 and 05000368/2022011
Enterprise Identifier:
I-2022-011-0039
Licensee:
Entergy Operations, Inc.
Facility:
Arkansas Nuclear One
Location:
Russellville, AR
Inspection Dates:
June 12 to June 17, 2022
Inspectors:
J. Mejia, Reactor Inspector
J. Drake, Senior Reactor Inspector
G. Pick, Senior Reactor Inspector
C. Smith, Senior Reactor Inspector
Accompanying
Personnel:
B. Allik, Materials Engineer, Corrosion and Steam Generator Branch,
Office of Nuclear Reactor Regulation
J. Gavula, Materials Engineer, Corrosion and Steam Generator Branch,
Office of Nuclear Reactor Regulation
Approved By:
Nicholas H. Taylor, Chief
Engineering Branch 2
Division of Operating Reactor Safety
2
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees
performance by conducting a NRC inspection at Arkansas Nuclear One, in accordance with the
Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for
overseeing the safe operation of commercial nuclear power reactors. Refer to
https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Failure to Perform Required Thickness Measurements as Required by Design to Manage the
Effects of Aging
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Mitigating
Systems
Green
VIO 05000313,05000368/2022011-01
Open
[H.5] - Work
Management
71003
The team identified a green finding and associated Notice of Violation because the licensee
failed to manage the effects of aging on their buried unit 1 and unit 2 service water supply
piping as required by regulatory requirements. Specifically, the licensee failed to measure
pipe wall thickness to assess the condition of the supply piping that provides cooling during a
design basis accident.
Additional Tracking Items
Type
Issue Number
Title
Report Section
Status
Condition of Emergency
Cooling Pond Buried Piping
71003
Closed
3
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in
effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with
their attached revision histories are located on the public website at http://www.nrc.gov/reading-
rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared
complete when the IP requirements most appropriate to the inspection activity were met
consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection
Program - Operations Phase. The inspectors reviewed selected procedures and records,
observed activities, and interviewed personnel to assess licensee performance and compliance
with Commission rules and regulations, license conditions, site procedures, and standards.
OTHER ACTIVITIES - TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
71003 - Post-Approval Site Inspection for License Renewal
Background
NRC inspectors completed a Phase IV inspection the week of April 11, 2022, as documented in
Inspection Report 05000313/2021013. This inspection occurred 8 years after unit 1 and 4 years
after unit 2 entered their periods of extended operation. The period of extended operation
included the additional 20 years beyond the original 40-year licensed term. The period of
extended operation for Arkansas Nuclear One, Unit 1 will end on May 20, 2034, and Unit 2 will
end on July 17, 2038. The inspection identified areas that required further review related to
managing aging effects for the buried service water piping return lines to the emergency cooling
pond and supply lines from the emergency cooling pond to the plant intake structure.
Unresolved Item (URI)05000313/2021013-02, Condition of Emergency Cooling Pond Buried
Piping described the concerns that affected both units. The emergency cooling pond provides
the backup ultimate heat sink supply in the event of a loss of Lake Dardanelle.
With the assistance of program experts in buried piping and service water programs from the
Office of Nuclear Reactor Regulation, the team evaluated the following items:
1.
The licensing requirements related to the buried piping, service water, and
microbiologically influenced corrosion programs
2.
Whether the licensee has properly implemented the interface requirements among the
buried piping, service water, and microbiologically influenced corrosion programs
3.
Whether the licensee has implemented their required external and internal inspections
and program requirements
4.
Action plans for inspecting the buried emergency cooling pond supply and return lines
5.
Plans for using carbon fiber reinforced polymer wrap, including interim actions to ensure
health of the lines until installation of the repair
Post-Approval Site Inspection for License Renewal (1 Sample)
Licensing Requirements (Item 1)
The team confirmed that the licensee described their buried piping aging
management programs in the unit 1 updated final safety analysis report (UFSAR),
section 16.1.1 and unit 2, UFSAR, section 18.1.4. The buried piping programs
focused on ensuring the integrity of the exterior coating on the buried piping and
4
maintaining the cathodic protection system. The licensee described their service
water integrity aging management programs in the unit 1 UFSAR, section 16.2.19
and unit 2 UFSAR, section 18.1.25. The service water integrity programs focused on
implementing commitments to Generic Letter 89-13, Service Water System
Problems Affecting Safety-Related Equipment, dated July 18, 1989. The activities
implemented by the service water integrity programs included flow balancing and
testing, heat exchanger inspections and testing, chemistry treatment, and pipe
condition monitoring.
The licensee established microbiologically influenced corrosion programs to monitor
the pipe interior conditions using periodic measurements of piping thickness. The
team noted that the licensee explicitly called out monitoring the coating on the interior
of the unit 1 return line to the emergency cooling pond. The team determined that the
licensee established procedure requirements to perform thickness monitoring using
their microbiologically influenced corrosion program to meet the Generic Letter 89-13,
Section III requirements, as prescribed by the unit 1 UFSAR, section 16.2.19 and
unit 2 UFSAR, section 18.1.25.
The implementing procedures for buried piping included the guidance in NEI 09-14,
Guideline for The Management of Underground Piping and Tank Integrity,
Revision 4. For unit 1 the team determined that the licensee had a requirement to
inspect the exterior coating of one in-scope buried pipe during the 20-year period of
extended operation, and for unit 2 the licensee had a requirement to plan and inspect
one in-scope buried pipe during the last 10 years of the period of extended operation
if no opportunistic inspection occurred during the first 10 years.
Program Implementation (Item 2 and Item 3)
Buried Piping and Underground Tanks
The buried piping program evaluated the effect of aging on the exterior of buried
piping by ensuring that the cathodic protection system remained available, and that
the licensee maintained external coatings in good condition. This program included
the fire water, diesel generator fuel oil, and service water systems. The buried service
water piping included for each unit: (1) the return piping from the plant to the
emergency cooling pond; (2) the supply piping from the emergency cooling pond to
the intake structure; (3) the supply loops from the intake structure to both units;
and (4) the return piping from each unit to the intake structure.
Procedure EN-DC-343, Underground Piping and Tanks Inspection and Monitoring
Program, described the requirements for managing the effects of aging of buried
piping including fitness-for-service examinations. Procedure CEP-UPT-0100,
Underground Piping and Tanks Inspection and Monitoring, provided details related
to the buried piping program at Entergy sites that included implementing NEI 09-14,
Revision 4. Procedure SEP-UIP-ANO-001, Underground Components Inspection
Plan Non-Rad and Rad Piping, described the site-specific ranking, inspection plans,
and historical evaluation activities for all buried piping within scope.
The asset management plan developed for procedure SEP-UIP-ANO-001 described
the history of inspections for in-scope buried piping. The licensee inspected the unit 1
return to the emergency cooling pond piping (HBD-13-18) prior to entering the period
5
of extended operation in August 2010. As part of this activity the licensee: (1) cleaned
and coated the interior of the piping, (2) evaluated the exterior condition of the pipe
including the coating, and (3) performed thickness measurements of the piping. Since
entering the period of extended operation, the licensee never inspected the exterior of
any of the return or supply lines to determine the condition of the external coating.
During review of procedure SEP-UIP-ANO-001, the team identified that the
classification tables misclassified some pipe segments. The team documented this
performance deficiency in the Results section.
The team identified that the licensee had mixed results with maintaining their cathodic
protection system. The licensee placed the site cathodic protection system on their
top ten equipment concerns list but removed it from the list once plans were
established to rehabilitate the system. The team documented the details in an
observation in the Results section.
Service Water Integrity Program
The service water integrity program ensured that the service water systems met the
requirements of Generic Letter 89-13 and managed the effects of aging on the interior
of the piping. Procedure EN-DC-184, NRC Generic Letter 89-13 Service Water
Program, included requirements to implement (1) chemical treatment and monitoring,
(2) system flushing and flow testing, (3) internal inspections and maintenance of
service water piping and piping components, (4) condition monitoring and
assessment, which included thickness measurements, and (5) heat exchanger
capability verification. Procedure SEP-SW-ANO-001, NRC Generic Letter 89-13
Service Water Program, prescribed the site-specific actions and credited the
microbiologically influenced corrosion program for wall thickness monitoring as part of
the piping component inspection and maintenance.
Procedure EN-DC-340, Microbiologically Influenced Corrosion (MIC) Program,
provided the requirements for assessing and evaluating piping integrity caused by
microbiologically influenced and other types of corrosion. The licensee had two
additional documents that described the site-specific requirements for managing the
effects of aging caused by internal pipe corrosion (1) Procedure SEP-MIC-ANO-001,
Microbiologically Influenced Corrosion (MIC) Program, and (2) Engineering
Report A-EP-2005-001, Microbiologically Influenced Corrosion (MIC) Program. The
team reviewed licensee activities since 2003 related to evaluating the interior
condition of the buried service water piping that returns water from the plant to the
emergency cooling pond and that supplies water from the emergency cooling pond to
the intake structure. The team documented key events in the timeline in an
attachment to this report. The licensee initiated Condition Report CR-ANO-C-2003-
00923 to track resolution of outstanding service water integrity program notebook
actions using their corrective action program.
The licensee initiated several condition reports that documented a failure of the
buried pipe program, the microbiologically influenced corrosion program, or both
programs. These condition reports had outstanding corrective actions, as described
below:
6
Condition Report ANO-C-2019-01633 documented that the emergency
cooling pond supply piping had not been monitored for degradation by either
the buried pipe or the microbiologically influenced corrosion programs. A
corrective action remained open to track the inspection of a buried section of
the unit 1 supply pipe.
Condition Report ANO-C-2021-00987 documented fitness-for-service
evaluations had not been performed on buried safety-related service water
emergency cooling pond supply pipes (HBD-12-36 and 2HBC-88-42) as
required by procedure EN-DC-343. A corrective action remained open to take
thickness measurements and complete a fitness-for-service evaluation of the
supply pipes.
Condition Reports ANO-1-2021-02429 and 2-2021-01204 documented that
the licensee had not established an examination frequency to evaluate the
wear and wear rate to support determining the service life of the piping as
required by Procedure EN-DC-340, Section 5.5. A corrective action in each
condition report tracked the need to take thickness measurements to
determine a wear rate and evaluate the condition of the piping.
Because the licensee never performed thickness measurements for the supply lines
nor performed fitness-for-service examinations of their buried piping, the team
determined that the licensee failed to manage the effects of aging and ensure that the
supply piping could meet all its design requirements. The team documented this
performance deficiency in the Results section.
The team noted that the licensee performed ultrasonic testing of the entire unit 1
return line in August 2010 prior to coating the line. The team also noted that the
licensee completed a partial visual inspection of the interior of the Unit 1 supply pipe
from the emergency cooling pond in April 2021 to assess the pipe condition and
measure the piping ovality in preparation for the carbon fiber reinforced polymer
wrap. Similarly, in October 2021 the licensee attempted to visually inspect the interior
of the unit 2 supply pipe to determine the pipe condition in preparation for the carbon
fiber reinforced polymer wrap. The licensee only inspected the first 621-feet of the
approximately 2300-foot supply pipe. Both inspections provided limited insights into
the condition of the interior of the piping.
The team determined that the licensee inspected the interior coating of the unit 1
return line to the emergency cooling pond in 2016 as part of their aging management
activities. Condition Report ANO-1-2016-04449 documented some instances of lost
coating but concluded that the piping remained protected. The licensee coated this
piping to increase the design basis flow characteristics. Condition Report ANO-C-
2019-01633, CA10 described that work order 534148 existed to Re-inspect to
ensure coating has stopped ID [internal diameter] corrosion and pipe is structurally
sound (inspection method - internal PIG) on the SW ECP [service water emergency
cooling pond] Return Line (HBD-13-18). This work included 100 percent UT
[ultrasonic testing] scan from the internal (both ID and OD [outer diameter]
measurements) of the return line piping. The team determined that the licensee
cancelled this work in spring 2021 (1R29) and scheduled a visual inspection to review
the condition of the internal coating in fall 2022 (1R30). Work Order 563639 tracks the
7
automatic crawler visual examination to assess the condition of the coating in the fall
of 2022.
Corrective Actions
The team reviewed the operability evaluations that the licensee documented in
Condition Reports CR-ANO-1-2021-0249, CR-ANO-2-2021-1204, and CR-ANO-C-
2021-03142. The team determined that the conclusions that the piping remained
structurally intact provided reasonable assurance of operability and documented
specific observations related to the operability determinations in the Results section.
Short Term Actions (Item 4)
The team determined that the licensee scheduled work activities during the upcoming
unit 1 fall outage (1R30) and the unit 2 spring outage (2R29) on the service water
supply lines from the emergency cooling pond to the intake. The planned work
activities included:
Excavating and removing a section of piping during the unit 1 outage in
accordance work order 581554. The planned manual ultrasonic testing of
18-inch-wide sections on each end of the removed piping and an 18-inch-wide
section in the middle to perform a fitness-for-service evaluation as prescribed
by procedure EN-DC-343. The licensee plans to conduct an automatic
ultrasonic examination on the piping in support of the planned long-term
corrective actions. The licensee will evaluate these examination results to
evaluate actions required to use carbon fiber reinforced polymer wrap to
rehabilitate the piping.
Excavating and removing a section of piping during the unit 2 outage in
accordance with work order 572224. The licensee had not finalized details of
their plans at the time of this inspection. Like unit 1, the licensee planned to
conduct ultrasonic examination of the piping to support thickness monitoring, a
fitness-for-service examination, and assess the piping condition to support the
long-term corrective actions.
Long Term Actions (Item 5)
The NRC staff reviewed the licensees May 2021 scoping study IG-PM-SCO-03-TEM-
ScoDocV7.0, Scope Document - ANO-1 & ANO-2 Buried ECP Supply Pipe Projects
Revision 1. The licensees staff described that in May 2022, the site approved a
partial reroute solution that will involve (1) laying replacement piping in new trenches
that has termination points near both the emergency cooling pond and the intake
structure; (2) abandoning the existing piping in place, and (3) coating the existing
piping at the emergency cooling pond and at the intake structure with carbon fiber
polymer wrap up to the tie-in points to the replacement piping. The replacement
piping will be installed in accordance with Code Case N-752, Risk-Informed
Categorization and Treatment for Repair/Replacement Activities in Class 2 and 3
SystemsSection XI, Division 1. The use of this code case was approved for ANO in
Letter Arkansas Nuclear One, Units 1 and 2 - Approval of Request for Alternative
from Certain Requirements of the American Society of Mechanical Engineers Boiler
and Pressure Vessel Code (EPID L-2020-LLR-0076) [ML21118B039].
8
The licensee further described that planned supply line repair and replacement would
begin in 2025 be completed in 2026 for Unit 2 and 2027 for Unit 1. The licensee also
described plans to epoxy coat the unit 2 return piping in 2031.
INSPECTION RESULTS
Failure to Perform Required Thickness Measurements as Required by Design to Manage the
Effects of Aging
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Mitigating
Systems
Green
VIO 05000313,05000368/2022011-01
Open
[H.5] - Work
Management
71003
The team identified a green finding and associated Notice of Violation because the licensee
failed to manage the effects of aging on the buried unit 1 and unit 2 service water supply
piping as required by regulatory requirements. Specifically, the licensee failed to measure
pipe wall thickness to assess the condition of the supply piping that provides cooling during a
design basis accident.
Description: The team reviewed licensee activities that managed the effects of aging related
to the buried service water piping that returned water from the plant to the emergency cooling
pond and the piping that supplied water from the emergency cooling pond to the service
water intake structure. Procedure EN-DC-340 detailed the requirements of the
microbiologically influenced corrosion program activities for in-scope piping and components
which included performing pipe wall thickness measurements for buried service water piping.
During review of the program implementation, the team identified that the licensee failed to
measure the supply piping wall thickness for either unit as required by their license basis, and
as such, the licensee failed to manage the effects of aging on the buried service water supply
lines from the emergency cooling pond.
The team reviewed the history related to corrosion of the service water return and supply
piping for the emergency cooling pond. From this review the team discerned that the licensee
maintained their design basis flows to the facility and to the emergency cooling pond. Further,
the licensee knew of the potential for piping leakage and the need to conduct repairs to retard
or stop the corrosion, as demonstrated by:
In 2003, the licensee placed the outstanding actions in the service water integrity
program notebook into their corrective action program. The actions included coating
the unit 1 and unit 2 return piping and ensuring that they met their design flow
requirements. The licensee ultimately chose to use pigging to clean the unit 2 piping
rather than coat the piping.
In 2013, the licensee had plans listed in their asset management plan to excavate and
inspect the unit 1 buried supply lines; however, the licensee cancelled these
inspections.
In 2016, the NRC identified that the licensee had not maintained specific
representative monitoring points in the microbiologically influenced corrosion program
9
and did not monitor pipe wall thickness frequently enough to prevent through-wall
leaks.
In 2020, the ANO-1 Emergency Cooling Pond (ECP) Supply Pipe Replacement
Project was deferred for 3 years (two outage cycles to 2023 and 2024) due to cost
variances.
In 2020, the licensee initiated actions to clean and ultrasonically inspect the unit 1
return line during the 1R29 outage; however, the licensee removed this activity from
the outage because of inadequate planning. The licensee changed the ultrasonic
inspection to a video crawler visual inspection in the fall 2022 (1R30) outage.
In 2021, the licensee again delayed their plans to repair/rehabilitate the unit 2
and unit 1 supply pipes from 2023 to 2026 and 2024 to 2027, respectively. The
licensee delayed implementation until they received approval to implement carbon
fiber reinforced polymer wrap and use of Code Case 752.
The team determined that, on April 12, 2001, after receipt of the license extension safety
evaluation report, the licensee described in section 16.2.19 of the unit 1 UFSAR that
thickness measurements of the service water piping would be performed as part of the
service water integrity program. On April 7, 2005, after receipt of the license extension safety
evaluation report, the licensee described in section 18.1.25 of the unit 2 UFSAR that they
would implement the requirements of Generic Letter 89-13. Generic Letter 89-13,
recommendation III, specified Ensure by establishing a routine inspection and maintenance
program for open-cycle service water system piping and components that corrosion, erosion,
protective coating failure, silting, and biofouling cannot degrade the performance of the
safety-related systems supplied by service water. Letter 0CAN019012, Response to
Generic Letter 89-13, Service Water System Problems Affecting Safety-Related Equipment,
Attachment 2, Ongoing Programs, Recommendation III.A, specified periodic thickness
mapping of service water piping using automated means of nondestructive examination.
Procedure SEP-MIC-ANO-001, Revision 3, Step 2.4, required, in part, that the
microbiologically influenced corrosion program owner shall take responsibility and ensure all
underground piping and tanks susceptible to microbiologically influenced corrosion are
included each outage. The team determined that the licensee changed Engineering
Report A-EP-2005-001 inspection instructions in a manner that eliminated any programmatic
guidance for taking thickness measurements for buried service water piping. Up through
Revision 4 of this report, the licensee included the number of monitoring points for numerous
in-scope line segments including the emergency cooling pond supply piping to the intake
structure. The team determined that Revision 5 inappropriately credited long-term planned
actions as the basis for no longer taking thickness measurements of the emergency cooling
pond supply piping. Specifically, the licensee revised Section 2.2.1.1 Buried Pipe, to specify,
These pipes are currently being addressed by long-range plan items that are in the planning
phase to replace and/or rehabilitate these pipes. Thus, no MIC Program activity is planned for
these pipes.
The team identified a performance deficiency because the licensee never performed
thickness measurements of the supply piping from their emergency cooling pond to the intake
structure to demonstrate that the piping would continue meet its design.
10
Corrective Actions: The licensee had several corrective action documents that tracked their
short term actions to determine the condition of the piping. The licensee completed a scoping
study that outlined replacing or rehabilitating segments of the buried piping.
Corrective Action References: C-2019-01633, C-2021-00987, 1-2021-02429, and 2-2021-
01204
Performance Assessment:
Performance Deficiency: The failure to perform thickness measurements as required by plant
procedures and as described in the license basis was a performance deficiency. Specifically,
the licensee failed to measure the thickness of the buried emergency cooling pond supply
piping for either unit.
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the Equipment Performance attribute of the Mitigating
Systems cornerstone and adversely affected the cornerstone objective to ensure the
availability, reliability, and capability of systems that respond to initiating events to prevent
undesirable consequences. Specifically, the licensee has never taken required thickness
measurements of buried emergency cooling pond supply piping in either unit to support the
conclusion that the supply piping remained capable of performing its design function.
Significance: The inspectors assessed the significance of the finding using IMC 0609
Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The
team determined that the finding screened to green because the deficiency potentially
affected the ability of the ultimate heat sink supply piping to deliver the required water during
an accident; however, no failure or event had occurred.
Cross-Cutting Aspect: H.5 - Work Management: The organization implements a process of
planning, controlling, and executing work activities such that nuclear safety is the overriding
priority. The work process includes the identification and management of risk commensurate
to the work and the need for coordination with different groups or job activities. Specifically,
the team determined that the licensee did not take advantage of opportunities to inspect the
piping when presented.
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion III, requires, in part, that measures
shall be established for verifying or checking the adequacy of design, such as by the
performance of design reviews, using alternate or simplified calculational methods, or by the
performance of a suitable testing program.
Unit 1 UFSAR, section 16.2.19, Service Water Integrity states, in part, that thickness
mapping and visual inspections manage the aging effects of loss of material from the service
water components.
Unit 2 UFSAR, section 18.1.25, Service Water Integrity Program [SWIP] states, in part, that
the program relies on implementation of the recommendations of NRC Generic Letter 89-13,
Service Water System Problems Affecting Safety-Related Equipment, to ensure that the
effects of aging on the service water system will be managed. The licensees response to
Generic Letter 89-13, dated January 26, 1990 (ML20006B723), Attachment 3 Program
Document for SWIP Long-term Program Plans, section titled Non-Destructive Examination
Step 2 states, in part, that mapping of piping thickness at selected locations with
11
computerized ultrasonic equipment is periodically performed and trended.
Contrary to the above, from April 12, 2001, for Unit 1 and from April 7, 2005, for Unit 2, to
September 29, 2022, the licensee failed to establish measures for verifying or checking the
adequacy of design by the performance of a suitable testing program for the service water
system. Specifically, when managing the effects of aging, the licensee never performed
thickness measurements of its buried in-scope emergency cooling pond supply piping to
provide reasonable assurance that the service water system remained capable of performing
its design function.
Enforcement Action: The violation met the criteria for treatment as a non-cited violation;
however, because the violation is associated with Entergys failure to manage longstanding
age-related degrading conditions in buried service water supply piping and given that
subsequent follow-up inspection is needed to ensure compliance with ANO's renewed
operating license, the NRC determined the issuance of a Notice of Violation is appropriate in
this case (Enforcement Manual Section 2.3.2).
The disposition of this finding and associated violation closes URI: 05000313/2021013-02.
Minor Violation
71003
Minor Violation: Procedure SEP-UIP-ANO, Underground Components Inspection Plan
Non-Rad and Rad Piping, Revision 7, Appendix C, Asset Management Plan, described
historical and current plans for managing buried piping such as coating the interior of the
emergency cooling pond return piping from the plant. During review of piping classifications
related to risk ranking the underground piping, the team identified that the licensee placed the
buried service water piping into a lower risk pipe grouping that affected the risk ranking of the
piping.
The team determined that the licensee failed to classify the safety-related service water
piping as described in procedure SEP-UIP-ANO, Underground Components Inspection Plan
Non-Rad and Rad Piping, Revision 6. The licensee identified the piping in their system as
nonradioactive nonsafety-related rather than nonradioactive safety-related, which affected the
ranking related to the relative risk of a piping failure.
Screening: The inspectors determined the performance deficiency was minor. The failure to
classify service water piping as nonradioactive safety-related was a performance deficiency
for failure properly implement the requirements in procedure SEP-UIP-ANO. Specifically, the
licensee misclassified the service water piping as nonradioactive nonsafety-related that
resulted in a lower risk ranking for selecting buried pipe segments to review. The team
determined that this performance deficiency was not more than minor because the licensee
treated the piping as safety-related despite the ranking and completed inspections of similar
material carbon steel pipes in the diesel fuel oil system.
Enforcement: Title 10 CFR Part 50, Appendix B, Criterion V, requires, in part, that activities
affecting quality shall be prescribed by documented procedures of a type appropriate to the
circumstances and shall be accomplished in accordance with these procedures.
Procedure SEP-UIP-ANO provides the guidance and requirements to manage the buried
piping based on risk ranking according, in part, to safety classification and the presence of
radioactive fluids. Contrary to the above, on January 31, 2022, the licensee failed to properly
classify the service water piping. Specifically, the licensee classified service water piping as
12
nonradioactive nonsafety-related, rather than nonradioactive safety-related. The licensee
documented this failure to properly classify the service water piping in condition report ANO-
1-2022-00171. This failure to comply with procedure SEP-UIP-ANO constitutes a minor
violation that is subject to enforcement action in accordance with the NRCs Enforcement
Policy.
Observation: Operability Evaluation Observations
71003
The team noted that procedure EN-OP-104, Operability Determination Process, described
that to determine if an ASME Class 2 or 3 system, structure, or component with a flaw is
OPERABLE then the degradation mechanism must be readily apparent. To be readily
apparent, the degradation mechanism is discernible from visual examination (as external
corrosion or wear) or there is substantial operating experience with the identified degradation
mechanism in the affected system, structure, or component. The team reviewed operability
evaluations related to condition reports ANO-1-2021-0249, ANO-2-2021-1204, and ANO-C-
2021-03142. All three operability evaluations assume that any degradation in the buried
portions of the supply and returns lines to the emergency cooling pond resulted from
microbiologically influenced corrosion, and based on extensive operating experience, had not
affected the structural integrity of the piping.
The licensee compared the minimum thickness values derived in CALC-19-E-0013-02,
Minimum Thickness Calculation for HBD-12-36", HBD-14-18", HBD-20-18", 2HBC-33-20,
2HBC-34-20, 2HBC-83 30, and 2HBC-88-42 Buried Pipe, Revision 0 with the pipe wall
thickness values derived in CALC-20-E-0001-30, Unit 2 Failure Effects Analysis for 2HBC-
83, Revision 0, and determined that the lowest measured thickness for the above ground
portion of 2HBC-83-30 did not challenge the largest calculated minimum wall thickness for
the buried portions of the system.
The team did not identify any specific issues with the conclusion related to structural integrity
but identified the following insights not addressed by the operability determinations:
1.
The licensee replaced significant amount of their treated, small-bore service water
piping (8 and under) because extensive internal corrosion caused low flow conditions
and pinhole leaks over the life of the plant. The team concluded that the buried,
untreated piping had a high likelihood of experiencing similar leakage. The team noted
that pinhole leaks in above ground piping would not alter the external surface
environment for the pipe; however, leakage through the buried coated pipe could trap
water against the pipe under the coating and create additional external corrosion.
Based on these differences, it was not clear to the team that the site has substantial
operating experience with the degradation mechanism in the associated buried piping
environment, such that the degradation mechanism can be considered readily
apparent as described in EN-OP-104.
2.
For the 30-inch unit 2 return line, the team did not identify where the licensee
addressed that the minimum wall thickness should be 0.200 inches for the specified
22-inch soil coverage depth to account for buckling shown in CALC-19-E-0013-02,
which provided the thinning limits. The calculation cautioned that the shallow-cover
regions were likely not subjected to surface loads but noted that the user of the
calculation must ultimately determine that the burial depth at the point of interest is
greater than 36 inches and that no surface loads are applicable. The operability
evaluations did not address this aspect of the calculation to determine the actual soil
13
coverage depth and to verify that the shallow portions of the pipe are not subject to
surface loads.
3.
CALC-19-E-0013-02 states that the ASME Code Case N-806, Analytical Evaluation
of Metal Loss in Class 2 and 3 Metallic Piping Buried in a Back-Filled Trench,
provided guidelines for the design of buried steel piping and served as the technical
basis and methodology for assessing the design of buried piping according to a
calculable required uniform minimum wall thickness. The team noted that the NRC
had not approved this code case for use as described in Regulatory Guide 1.193,
ASME Code Cases Not Approved for Use. Although the licensee determined that
they could have minimum wall thickness values of less than 0.1 inches in several of
their buried pipes, the team noted that these values did not meet the minimum
allowed thickness as specified in ASME Code Case N-806. Based on the questions,
the licensee reperformed their calculation and determined that the minimum wall
thickness in CALC-19-E-0013-02 will need to increase by 25 percent. The licensee
documented the change in the calculation in Condition Report ANO C-2022-02699.
Observation: Condition of Cathodic Protection System
71003
The team evaluated the condition of the cathodic protection system because a functioning
cathodic protection system effectively protects piping from external corrosion. Although not
required as part of the license extension, the NRC evaluated the protection afforded by
cathodic protection systems and the licensee credited the protection provided by their
cathodic protection system. Letter 1CNA090004, License Renewal Application RAIs,
dated September 12, 2000, response to Request for Additional Information 3.3.4.3.2-7.c(1),
described that the buried piping inspection program will be effective because coating,
wrapping, and cathodic protection have been demonstrated in this and many other industries
to be effective at mitigating corrosion by inhibiting environmental effects.
Procedure CEP-UPT-0100, Underground Piping and Tanks Inspection and Monitoring,
Revision 6, Section 5.6, specified preventive maintenance requirements for installed cathodic
protection systems. Based on the teams review of the 2020 and 2021 annual surveys, the
licensee had the system functioning at 50 percent of capability based on the -850 mV relative
to a copper/copper sulfate reference electrode, instant-off, acceptance criterion for their
buried piping. In addition, based on its review of the 2022 annual survey, the team noted the
following: (a) the effectiveness of the cathodic protection system had dropped to 42 percent;
and (b) many anodes at the site will reach the end of their service life within 5 years. The
team determined that the licensee recently removed the cathodic protection system from their
Top Ten Equipment Reliability concerns list after engineering established plans to restore the
system to optimal design conditions to protect the buried piping. The licensee started phase 2
of a three-phase plan to identify the upgrades and replacements needed to restore the
system. The licensee expects to complete phase 2 in 2022-2023. Phase 3 will implement any
system upgrades and replacements needed to ensure the system functioned as designed by
2024-2025. The licensee will replace depleted anodes and install new rectifiers as part of the
system upgrades. The licensee tracked these corrective actions in condition report ANO-C-
2019-01013.
14
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On October 25, 2022, the inspectors presented the NRC inspection results to Joseph
Sullivan, Site Vice President, and other members of the licensee staff.
15
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CALC-01-E-0012-
6
Evaluation of underground utilities from new wheel loads
during transport of Holtec DFS cask
0
CALC-13-D-2001-
12
Structural Evaluation of Haul Path at ANO
0
CALC-19-E-0013-
2
Minimum thickness calculation for buried pipes
0
Calculations
CALC-20-E-0001-
30
Unit 2 FEA for 2HBC-83
0
CR-ANO-1-
2011-00476, 2016-01133, 2016-01603, 2016-01793, 2016-
02087, 2016-04449, 2017-02152, 2019-00958, 2019-01507,
2019-01759, 2019-03104, 2019-03862, 2020-00427, 2020-
01675, 2020-01822, 2020-01855, 2021-00030, 2021-00492,
2021-01188, 2021-01263, 2021-01326, 2021-01841, 2021-
02129, 2021-02183, 2021-02429, 2021-02751, 2021-02815,
2021-02824, 2021-03018
CR-ANO-2-
2003-01339, 2003-01584, 2016-02365, 2016-02835, 2016-
02843, 2017-00968, 2017-03766, 2017-04493, 2019-00524,
2019-00741, 2019-00780, 2019-00964, 2019-00986, 2019-
01727, 2019-01812, 2019-02092, 2019-02313, 2019-02373,
2019-03029, 2020-00419, 2020-00509, 2020-01797, 2020-
02986, 2020-03628, 2020-03650, 2021-00739, 2021-01204,
2021-02199, 2021-02633, 2021-03502, 2021-03502, 2021-
03595
Corrective Action
Documents
CR-ANO-C-
2003-00923, 2004-00066, 2011-00476, 2011-00935, 2013-
02041, 2016-04023, 2019-00756, 2019-00756, 2019-01012,
2019-01015, 2019-01633, 2019-02458, 2019-03982, 2019-
04099, 2020-00373, 2020-01378, 2020-02404, 2020-03265,
2021-00987, 2021-02203, 2021-02633, 2021-02703, 2021-
02887, 2021-02893, 2021-03013, 2021-03110, 2021-03142,
2021-03176, 2021-03247, 2022-00137, 2022-00464, 2022-
00502, 2022-00804, 2022-00955
71003
Corrective Action
CR-ANO-1
2022-00171
16
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Documents
Resulting from
Inspection
CR-ANO-C-
2022-01673, 2022-01897
C-2064
Emergency Cooling Water Suction and Discharge Lines
9
Drawings
C-64
Emergency Cooling Water Suction and Discharge Lines 10"
Gas Line Relocation
7
Engineering
Changes
54483
Service Water Buried Piping Project Scoping Study
0
93-R-1011-01
Review of the Programs Credited in the License Renewal
Evaluations, Section 3.1 Buried Pipe Inspection
3
93-R-1011-01
Review of the Programs Credited in the License Renewal
Evaluations, Section 4.19 Service Water Integrity
3
A-EP-2005-001
ANO Microbiologically Influenced Corrosion (MIC) Program
0
A-EP-2005-001
ANO Microbiologically Influenced Corrosion (MIC) Program
4
A-EP-2005-001
ANO Microbiologically Influenced Corrosion (MIC) Program
5
CALC-ANO1-ME-
11-00002
Buried Pipe Inspection Program Review
0
CALC-ANO1-ME-
11-00004
Review of the Service Water Integrity Aging Management
Program for License Renewal Implementation
0
CALC-ANO2-ME-
15-00006
Review of the Buried Piping Inspection Program for License
Renewal Implementation
0
CALC-ANO2-ME-
15-00023
Review of the Service Water Integrity Program for License
Renewal Implementation
0
ER-ANO-2004-
0573-000
ANO Buried Piping Life Cycle Management Study for SW,
ACW, FW, CW and Fuel Oil Piping
7/2/2004
LA190752-R-001
Condition Assessment of Degraded Essential Service Water
Pipe Segment, Line HBD-20-18
0
LA200162-R-001
Fire Protection System Piping Condition Assessment and
MIC Sampling
0
LA211525-LR-
001
Independent Third Party Review (ITPR) of Engineering
Evaluation supporting Operability for Emergency Cooling
Pond (ECP) Service Water Piping - Arkansas Nuclear One
7/30/2021
R06045-0029-006
Arkansas Nuclear One Buried Piping Soil Sampling Report
5/30/2014
Miscellaneous
Visual Inspection Service for 36 Pipe at Arkansas Nuclear
5/18/2021
17
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
One Plant Unit 1
Visual Inspection Service for 42 Pipe at Arkansas Nuclear
One Plant Unit 2
11/8/2021
Case N-752
Risk-Informed Categorization and Treatment for
Repair/Replacement Activities in Class 2 and 3 Systems
Section XI, Division 1
7/23/2019
Case-N-806-1
Analytical Evaluation of Metal Loss in Class 2 and 3 Metallic
Piping Buried in a Back-Filled Trench Section XI, Division 1
12/15/2015
EN-20-RR-001
Arkansas Nuclear One, Units 1 and 2 - Approval of Request
for Alternate from Certain Requirements of the American
Society of Mechanical Engineers Boiler and Pressure Vessel
Code
1
IG-PM-SCO-03-
TEM-ScoDocV7.0
Scope Document - ANO-1 & ANO-2 Buried ECP Supply
Pipe Projects
5/2/2022
Letter
CAN019012
Response to Generic Letter 89-13, Service Water System
Problems Affecting Safety-Related Equipment
1/26/1990
LR-LAR-2008-
00048
Implement the Buried Piping and Tanks Inspection Program
as described in LRA Section B.1.1
2/27/2008
Guideline for the Management of Underground Piping and
Tank Integrity
4
R06045-0029-006
Buried Piping Soil Sampling Report
5/30/2014
Report 15422-
FOR-01-1
2022 Annual Survey Cathodic Protection Systems Entergy
Arkansas Nuclear One
5/2022
Report
1901127.01
2020 Annual Survey Report (Cathodic Protection)
9/3/2020
Report
2100141.021
2021 Annual Survey Report (Cathodic Protection)
9/4/2021
Report No.
1000089
Area Potential Electric Current Survey
2/16/2012
Risk
Assessments
ANO-1-2017-0661, Revision 0
ANO-1-2017-0661, Revision 1
ANO-1-2018-0253, Revision 0
ANO-1-2018-0253, Revision 1
ANO-1-2018-0253, Revision 2
18
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
ANO-2-2017-0664, Revision 0
ANO-2-2017-0664, Revision 1
ANO-2-2017-0664, Revision 2
ANO-2-2020-0057, Revision 0
SPEC-6600-M-
400
Specification for External Surface Treatment of Underground
Metallic Pipe for the Arkansas Nuclear One Arkansas Power
and Light Company
4/1/1971
Specification
ANO-C-2301
Structural Backfill
4
Specification
SPEC-C-301
Technical Specification for Structural Backfill Pipe Trench
Excavation, and Pipe Trench Backfill
1
1-BOP-UT-21-
031
Oily Water Buried Pipe 6 Baseline Inspection
9/8/2021
1-BOP-UT-21-
032
Oily Water Buried Pipe: Buried 6 Pipe Outside of Oily Water
Separator
9/9/2021
2-BOP-UT-15-
050
Service Water Return Spool #8 (MC 2.C.3.1)
9/2/2015
2-BOP-UT-17-
006
2/1/2017
2-BOP-UT-17-01
O
ECP 30 in. Return Piping (MIC 2.C.3.2)
2/9/2017
Return_AUT 001
2R27 ECP SW Return (2HBC-83-30")
12/12/2019
BOP-UT-09-046
ECP 30 in. Return Piping (MIC 2.C.3.2)
8/11/2009
NDE Reports
Reports
NDE Reports
NDE Reports
NDE Reports
NDE Reports
NDE Reports
ISI-UT-08-024
Spool #1 (At tee to 2HBC-51-81")
2/27/2008
Operability
Evaluations
CR-ANO-1-2021-
02429
Per the requirements of EN-DC-340, Microbiologically
Influenced Corrosion (MIC) Monitoring Program, the
examination frequency has not been determined for the Unit
1 Emergency Cooling Pond Supply and Return
Lines.
ECH-EP-12-
00001
Guidelines for Management of Reasonable Assurance of
Integrity for Above and Underground SSCs Containing
Radioactive Material
0
Engineering Reports
8
19
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
NRC Generic Letter 89-13 Service Water Program
6
Microbiologically Influenced Corrosion (MIC) Monitoring
Program
5
Underground Piping and Tanks Inspection and Monitoring
Program
13
EN-EP-S-002-
MULTI
Underground Piping and Tanks General Visual Inspection
5
Nuclear Risk Management Process
3
Operability Determination Process
17
SEP-MIC-ANO-
001
Microbiologically Influenced Corrosion (MIC) Program
3
SEP-SW-ANO-
001
NRC Generic Letter 89-13 Service Water Program
1
Self-Assessment on the Buried Pipe and Tank Program
9/30/2020
LO-ALO-2015-
0080
NRC Generic Letter 89-13 Service Water Program
Assessment
12/17/2015
LO-ALO-2015-
0095
Microbiologically Induced Corrosion (MIC) Monitoring
Program Assessment
9/18/2015
LO-ALO-2015-
0097
Underground Piping and Tank Inspection Program
12/18/2015
LO-ALO-2016-
0016
Underground Piping & Tanks Inspection and Monitoring
Program Snapshot Assessment
0
LO-ALO-2016-
0078
Confirmatory Action Letter Key Improvement Action 6:
Service Water System Operational Performance Inspection
12/2016
Self-Assessments
LO-ALO-2017-
0071
Pre-NRC Focused Self Assessment: Triennial Heat Sink
Assessment
0
Work Orders
WO- 478947, 507271, 507346, 549458, 556989, 559400, 559401,
563877, 567020, 567026, 572240,
Timeline of Important Buried Piping Corrective Action Documentation After Approval of Renewed License
Attachment
Date
Discussion
Reference
9/26/2003
Low service water flows in unit 2 to safety related loads resulted from corrosion on the
interior of the piping. Recovered some design margins and improved the flow conditions
by cleaning the emergency cooling pond return and supply piping through pigging. Long
term corrective actions proposed coating the interior of the piping and/or replacement.
Condition Report
ANO-2-2003-01339
10/27/2003
Conversion of outstanding service water integrity plan notebook actions to individual
actions in the corrective action program. Specific corrective actions included:
CA6 - tracked decision to clean the supply and return headers to the plant to meet flow
requirements; replacement of large bore piping to service water components in the plant;
determine the quantity and location to monitor piping thickness
CA10 - evaluate coating the unit 1 and 2 service water return piping to the emergency
cooling pond; identified that the coating on unit 1 had been successful and considered
coating the unit 2 return line. The licensee used pigging to clean the return line to restore
flows (refer to condition report 2-2003-01339).
Condition Report
ANO-C-2003-00923
1/16/2004
Service water integrity plan notebook specified mapping pipe wall thickness with
non-destructive examinations. The licensee identified the initial population from the
intake structure into the power block. The licensee had established these activities to
implement Generic Letter 89-13, recommendation III, and Unit 1 license renewal
commitments. The program did not have a defined a scope or implementation frequency
to manage the aging effects caused by corrosion/erosion occurring in the service water
system. Developed a program documented in engineering report A-EP-2005-001 that
discussed specific monitoring locations, piping systems and materials, ranking
methodology, and acceptance criteria.
Condition Report
ANO-C-2004-00066
3/12/2014
Procedure SEP-UIP-001, Underground Components Inspection Plan (Rad And Non-Rad
Lines), Revision 1 identified that the licensee had plans to inspect the unit 1 supply line in
accordance with work orders WO 292676 & 292678
Inspection Report 05000313/2014007
3/4/2015
A scoping study based on 2005 and 2012 Life Cycle Management Reports statistically
analyzed risks due to leaks in the buried service water and fire protection piping.
Identified a high likelihood of developing leaks caused by pitting and the lack of
consistent cathodic protection. Service water piping replacements had occurred inside
the power block for the past 30 years.
Because of feasibility uncertainty related to a cured-in-place piping repair option that had
been considered, the licensee discontinued this option, and evaluated other options.
The unit 2 service water return to the emergency cooling pond piping was scheduled to
be relined in spring 2017 (2R25).
Engineering
Change 54483
2
Date
Discussion
Reference
Recommended long term corrective actions for the unit 1 and unit 2 supply pipes
included evaluating site chemical controls to assist with passivation, developing an
inspection plan to validate structural integrity, evaluating industry experience with internal
coating/lining repairs, developing detailed construction estimates for pipe replacement or
refurbishment, and upgrading the cathodic protection system to ensure system reliability.
2/26/2016
During review of the microbiologically influenced corrosion program implementation, NRC
identified that the licensee had not maintained specific representative monitoring points
in the microbiologically influenced corrosion program and did not monitor pipe wall
thickness frequently enough to prevent through-wall leaks. Specifically, the licensee had
not established a maximum time limit for monitoring points
Condition Reports
ANO-C-2016-00435,
ANO-C-2016-00524,
ANO-C-2016-00546
Noncited Violation
05000313;
5/2/2019
Described that the emergency cooling pond supply piping that allows water to gravity
flow to the intake structure had not been monitored for degradation either by the buried
pipe or the microbiologically influenced corrosion programs. Identified gaps included:
(1) coordinating between the program owners; (2) identifying planned inspections;
and (3) selecting buried piping sections for evaluation based on risk ranking.
CA 7 (2/27/2020) initiated to track ultrasonically scanning the Unit 1 return piping inside
and outside diameters in 1R29. Inspection plans cancelled because of a lack of
preparedness and contingency planning.
CA 12 (5/5/2021) tracking completion of visual inspection of the unit 1 supply in 1R30 for
HBD-13
CA 13 (11/12/2021) documented video crawler inspection of the unit 2 supply line in
2R28. Inspected the first 681 feet of approximately 2300 feet
CA 14 (11/12/2021) documented ultrasonic inspection of accessible portions of the unit 2
return in 2R28
CA 16 (11/11/2021) incorporated Condition Report ANO-C-2021-02703 related to a
noncited violation for failure to test of buried piping to ensure it could perform its safety
function
Condition Report
ANO-C-2019-01633
7/9/2019
Buried piping program health report changed to red related to cathodic protection
deficiencies. Procedure EN-DC-143 required that the licensee identify causes for any
deficiencies and implement corrective actions
Condition Report
ANO-C-2019-02458
2/6/2020
Assessed the cathodic protection system as red and placed it on the top ten equipment
reliability concerns list. The plant developed actions to improve the system reliability with
an expected completion in 2025
Condition Report
ANO-C-2019-03982
3
Date
Discussion
Reference
5/7/2020
The cathodic protection system area potential earth current survey recommended actions
to optimize the level of protection provided across the system until permanent corrective
actions implemented.
Condition Report
ANO-C-2020-01378
4/8/2021
Fitness-for-service evaluations had not been performed on buried service water
emergency cooling pond supply pipes (HBD-12-36 and 2HBC-88-42) as required by
procedure EN-DC-343. The licensee program had until 2025 to complete this procedure
requirement.
Condition Report
ANO-C-2021-00987
4/19/2021
During setup of a robotic crawler at the unit 1 supply pipe entrance, licensee identified a
significant amount of microbiologically influenced corrosion tubercles on the inside
surfaces. The licensee advanced the crawler to the first 90-degree elbow (approximately
50 feet) to assess the conditions and inside diameter of the piping to support the planned
carbon fiber reinforced polymer wrap in the spring 2027 (1R33)
Condition Report
ANO-1-2021-01188
4/21/2021
Three sections of pipe between the emergency cooling pond supply piping entrance and
642 feet into the piping had ponding of water suggesting possible ground water in
leakage. Inspection personnel stopped the inspection because they had concerns about
the equipment getting stuck.
Condition Report
ANO-1-2021-01326
5/5/2021
Significant corrosion observed on wedges and associated studs and nuts on the gate
guide knuckles at the entrance to the unit 1 supply pipe (HBD-12-36) when initiating
crawler inspections.
Condition Report
ANO-1-2021-01841
7/15/2021
Documented no examination frequency established to evaluate the wear and wear rate
to determine the remaining service life of the piping. The licensee concluded that internal
environment for the piping in the auxiliary building immediately prior to going
underground had similar water quality, flow, and temperatures; therefore, the wear and
rate from the aboveground piping matches that of buried piping. Piping determined to be
operable and structurally sound by comparison.
Condition Reports
ANO-1-2021-02429
and
ANO-2-2021-01204
9/23/2021
The licensee delayed work order 563877 from the spring 2021 (1R29) until the fall 2022
(1R30). This activity would have removed and replaced a 20-foot section of piping to
provide insights into the condition of the supply piping and allowed performing a
fitness-for-service evaluation.
Condition Report
ANO-1-2021-02824
10/16/2021
Ultrasonic evaluation of location 2HBC-83-2 on the service water return to the
emergency cooling pond documented a degradation on the line greater than assumed in
in plant calculations that would maintain integrity for another 10 months. A failure effects
analysis demonstrated sufficient margin so that the piping would maintain integrity until
2031 at the expected wear rate.
Condition Report
ANO-2-2021-02633
4
Date
Discussion
Reference
12/8/2021
From review of video crawler results for the inside of the unit 2 supply piping, the
licensee identified ponding of water about 98 feet downstream of the first elbow. This
inspection assessed the interior pipe conditions to support using carbon fiber reinforced
polymer wrap to rehabilitate the piping in spring 2026 (2R32). The licensee delayed plans
to excavate and assess this section of the piping until the next unit 2 outage to ensure
more complete contingency planning and preparations for completion in spring 2023
(2R29).
Condition Report
ANO-C-2021-03142
12/22/2021
Independent review confirmed that performance of volumetric inspections and fitness-for-
service evaluations were needed to support the repair/replacement implementation dates
(2026 through 2031) for the service water supply pipes.
The review (1) identified the need to revisit interim actions once the repair projects were
deferred; (2) confirmed that prior corrective actions were not timely nor comprehensive to
address pipe wall thinning / pitting concerns; and (3) determined a lack of clear
ownership and accountability of microbiologically influenced corrosion monitoring by the
station.
An Organizational & Programmatic review identified organizational problems with
execution of needed repairs for a problem known to exist since 2005 related to enterprise
risk and conflicting work group priorities. Specifically, the condition analysis identified:
(1) site engineering had been concerned with the supply and return piping since 2005
and (2) microbiologically influenced corrosion program owners had changed at least nine
times since 2010, which led to missed opportunities and a lack of an advocate to collect
data.
Condition Report
ANO-C-2021-03247
May 2022
Entergy approved long term corrective action to replace center sections of the unit 1
and unit 2 supply piping and connect to pipe rehabilitated with carbon fiber reinforced
polymer wrap from the termination points to the emergency cooling pond outlet and to
the service water intake structure.
Scope Document -
ANO-1 & ANO-2
Buried ECP Supply
Pipe Projects