NLS2010050, Response to Open Items from the Safety Evaluation Report and Request for Additional Information Related to the License Renewal

Response to Open Items from the Safety Evaluation Report and Request for Additional Information Related to the License Renewal

ML101310605
Person / Time
Site:	Cooper
Issue date:	05/04/2010
From:	O'Grady B Nebraska Public Power District (NPPD)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NLS2010050
Download: ML101310605 (15)

Text

N Nebraska Public Power District "Always there when you need us" 54.17 NLS2010050 May 4, 2010 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001

Subject:

Response to Open Items from the Safety Evaluation Report and Request for Additional Information Related to the License Renewal of Cooper Nuclear Station Cooper Nuclear Station, Docket No. 50-298, DPR-46

References:

1. Letter from Brian E. Holian, U.S. Nuclear Regulatory Commission, to Stewart B. Minahan, Nebraska Public Power District, dated April 6, 2010, "Safety Evaluation Report With Open Items Related to the License Renewal of Cooper Nuclear Station."

2. Letter from Tam Tran, U.S. Nuclear Regulatory Commission, to Stewart B. Minahan, Nebraska Public Power District, dated April 13, 2010, "Request for Additional Information for the Review of the Cooper Nuclear Station License Renewal Application (TAC No. MD9763)."

3. Letter from Stewart B. Minahan, Nebraska Public Power District, to U.S.

Nuclear Regulatory Commission, dated September 24, 2008, "License Renewal Application" (NLS2008071).

Dear Sir or Madam:

The purpose of this letter is for the Nebraska Public Power District to respond to one Open Item documented in the Nuclear Regulatory Commission's (NRC) Safety Evaluation Report related to the Cooper Nuclear Station License Renewal Application (LRA) (Reference 1). This response is provided in Attachment 1. This letter also responds to an NRC Request for Additional Information (Reference 2). This response is provided in Attachment 2. Certain conforming changes to the LRA (Reference 3) are provided in Attachment 3.

Should you have any questions regarding this submittal, please contact David Bremer, License Renewal Project Manager, at (402) 825-5673.

COOPER NUCLEAR STATION P.O. Box 98 / Brownville, NE 68321-0098 13(

Telephone: (402) 825-3811 / Fax: (402) 825-5211 www.nppd.com

NLS2010050 Page 2 of 2 I declare under pena ty of perjury that the foregoing is true and correct.

Executed on .

(Date)

Sincerely, Brian J. O'Gr y Vice President - Nuclear and Chief Nuclear Officer

/WV Attachments cc: Regional Administrator w/ attachments USNRC - Region IV Cooper Project.Manager w/ attachments USNRC - NRR Project Directorate IV-1 Senior Resident Inspector w/ attachments USNRC - CNS Nebraska Health and Human Services w/ attachments Department of Regulation and Licensure NPG Distribution w/ attachments CNS Records w/ attachments

NLS2010050 Page 1 of 2 Attachment 1 Response to Open Item from the Safety Evaluation Report Related to the License Renewal of Cooper Nuclear Station Cooper Nuclear Station, Docket No. 50-298, DPR-46 The Nuclear Regulatory Commission (NRC) Safety Evaluation Report (SER) related to the License Renewal of Cooper Nuclear Station (CNS) contains four Open Items and one Confirmatory Item. Two of the four Open Items and the Confirmatory Item were previously responded to in a letter dated April 28, 2010 (NLS2010044). The Nebraska Public Power District (NPPD) has discussed one of the two remaining Open Items with the NRC and believes the disposition below will provide satisfactory closure. The remaining Open Item will be the subject of a future correspondence. The Open Item is shown in italics, and the NPPD response is shown in block font.

NRC Open Item: 013.0.3.2-1."(SER Section 3.0.3.2.6 - Containment Inservice Inspection Program)

In LRA Section B.]. 10, the applicantcredits its existing Containment ISI Programto be consistent, with enhancements, with GALL AMP XI.S1, "ASME Section XI, Subsection IWE, "in managing the loss of materialand crackingfor the primary containmentand its integral attachments. During its review of the program'soperating experience, the staff concluded that the applicanthas not demonstratedthat the effects of the torus degradationwill be adequately managed so that the intendedfunction will be maintainedfor the periodof extended operation in accordancewith 10 CFR 54.21(a)3. This issue remains unresolved as 013.0.3.2-1.

NPPD Response:

To provide additional assurance that the effects of aging on the torus will be adequately managed such that the torus will continue to perform its intended function throughout the period of extended operation (PEO), NPPD will recoat the wetted portion of the CNS torus within three years after entering the PEO. Furthermore, NPPD will remove sludge and inspect the wetted portion of the torus every refueling outage from now until the torus is recoated. NPPD will complete an analysis following each torus inspection that demonstrates that the projected pitting of the torus up to the time that the torus is recoated, will not result in reduction of torus wall thickness below minimum acceptable values.

NPPD plans to recoat the wetted portion of the torus since the wetted lower inner surface is susceptible to pitting. Pitting corrosion has not been identified during inspections of the torus surface above the water line. An inert nitrogen environment protects the upper portion of the torus inner surface from corrosion during normal operation.

NLS2010050 Page 2 of 2 Torus Condition in 2008 Since 1974, NPPD has documented 3800 coating repairs comprising 145 square feet or 1.1% of the torus surface area below the water line. No coating repairs have been necessary above the water line. Conservative NPPD projections show that unmitigated corrosion could continue up to and beyond 2020 without reducing torus wall thickness below minimum acceptable values.

Torus Condition Projected to Date of Recoating Conservative projections of wall thickness indicate that the torus shell will continue to meet the required minimum wall thickness up to and beyond 2020. NPPD does not mitigate corrosion occurring on an observation area in Bay 9 of the torus, thus allowing this area to be monitored as an indicator of worst case effects of corrosion. NPPD has collected data from 1991 to 2008 in the Bay 9 observation area, and establishes the corrosion rate used in torus life projections from this data.

The mean corrosion rate observed in the Bay 9 observation area is 1.28 mils/year as of 2008. To account for variations in measured data (and to achieve a 95% confidence interval), NPPD added two standard deviations to the mean, resulting in a corrosion rate of 2 mils/year. Based on this rate, pitting in the limiting area of the torus (the near penetration area) can continue unmitigated up to and potentially beyond 2020. During the period through 2020, pitting depth would not cross the threshold of 1/32" (31 mils) at which point multiple pits begin to interact and have a cumulative effect on the torus structural integrity. The threshold value of 31 mils entails additional conservatism in that the value is not a maximum allowable corrosion, but is a value that indicates a need for more detailed analysis that looks at the cumulative effect of multiple pits in an area.

In evaluating the proposed inspection frequency (increasing to at least once every refueling cycle from once every two refueling cycles), NPPD calculated the corrosion rate that would be required to exceed the 31 mil threshold in the near penetration area of the torus. Currently, over the course of two inspection periods of up to a total of four years, a corrosion rate of 7.5 mils/year would be required to exceed the 31 mil threshold. Over the course of a single inspection period of up to two years, a corrosion rate of 15 mils/year would be required to exceed the 31 mil threshold.

The value of 15 mils/year is 7.5 times the observed corrosion rate of 2 mils/year. Based on this evaluation an inspection frequency of at least once every two years provides adequate assurance that torus corrosion will remain within acceptable values.

NLS2010050 Attachment 2 Page 1 of 6 Attachment 2 Response to Request for Additional Information for the Review of the Cooper Nuclear Station License Renewal Application Cooper Nuclear Station, Docket No. 50-298, DPR-46 The Nuclear Regulatory Commission (NRC) Request for Additional Information (RAI) regarding the License Renewal Application (LRA) is shown in italics. The Nebraska Public Power District's (NPPD) response to the RAI is shown in block font.

NRC Request: RAIB.1.3-3

Background

The license renewal application(LRA) states that Aging Management Program (AMP) B. 1.3, Buried Pipingand Tanks Inspection Program,is a new program with no exceptions or enhancements and is consistent with the program elements in GALL AMP XI.M34. This AMP addresses buriedpiping, i.e., piping in direct contact with soil. The descriptionof the operating experience (OE) attributefor this AMP does not discuss specific OE at CNS orfrom the industry.

Instead, it states that 'plantoperating experiencefor this program will be gainedas it is implemented during the periodof extended operations,and will be factored into the programvia the confirmation and corrective action elements of the CNS 10 CFR 50 Appendix B quality assuranceprogram."

The LRA also states that AMP B.]. 14, External Surfaces MonitoringProgram,is an existing program with enhancement. This AMP is also creditedfor managingthe aging of the external surfaces ofpiping exposed to air.

Issue There have been a number of recent industry events involving leakagefrom buriedand undergroundpiping, where the causes have included coating damage during backfill ofpiping, failure offiberglasspiping,failure of buriedpiping in and aroundpipingpenetrations,and failure ofpiping in trenches. In light of this recent industry OE, the staff is concerned about the susceptibility of buriedand/or undergroundpiping that are within the scope of 10 CFR 54.4 and subject to aging managementfor license renewal. In reviewing the AMPs cited above, along with the applicable aging management review (AMR) items associatedwith them, the staff is not clear whether the components addressed by these AMPs would include both buried and undergroundpiping (pipingwhich is below grade and containedin a vault or other structure where it is exposed to air and where access is limited), and also ifsuch programswould be sufficient and effective in managing the aging effects of buriedand undergroundpiping.

NLS2010050 Page 2 of 6 Request Pleaseprovide the staff information regardinghow NPPD will incorporatethe recent industry OE into its aging management reviews andprograms in order to adequately and effectively manage the effects of aging, specificallyfor systems and components that are in scope for license renewal and include buried and undergroundpiping.

NPPD Response:

Background Information In response to industry operating experience with buried and underground piping, the Nuclear Energy Institute (NEI) promulgated an industry initiative on buried piping integrity adopted by the NEI Nuclear Strategic Issues Advisory Committee on November 18, 2009. NPPD is committed to the industry initiative on buried piping and is implementing a program to ensure the overall integrity of buried piping and underground piping. Components included in the industry initiative are all buried piping and piping components at Cooper Nuclear Station (CNS),

a subset of which is buried piping and piping components subject to aging management review for license renewal. The program will include the key elements of the NEI initiative:

" Establish procedures and oversight for a program.

" Perform risk ranking of buried and underground piping.

• Develop an inspection plan, which includes the following key attributes:

- Identification of piping segments to be inspected.

- Inspection techniques.

- An inspection schedule for buried piping segments based on risk ranking.

Under the timeline established for the NEI initiative, NPPD intends to complete the inspection plan by June 30, 2011, and commence inspections under the inspection plan no later than June 30, 2012.

In parallel with developing the program that implements the NEI initiative, NPPD is upgrading the CNS cathodic protection (CP) system beginning in 2010. Modifications will improve CP in several areas in order to comply with NACE (National Association of Corrosion Engineers)

Standards, and the new test stations will allow for more conclusive and accurate surveys. During the CP modifications, NPPD plans to perform opportunistic inspections of buried piping. The inspections will examine the condition of the protective coating and will also include ultrasonic wall thickness measurements at locations after the coating is removed from the piping surface.

NLS2010050 Page 3 of 6 CNS-Specific Operating Experience Buried piping at CNS was installed with protective coatings of a first coat of bitumastic primer, a second coat of bitumastic enamel, and one layer of asbestos coal tar saturated, felt. A final layer of vinyl covering was applied to buried components in certain systems. Construction documents specified backfill material of sand or sand and gravel with maximum particle size not to exceed one inch.

CNS has experienced the following events concerning buried piping or components. These events were documented in the corrective action program at CNS.

" Fire protection system valve failure On December 25, 2008, a buried fire protection valve failed. The failure was due to an overstress condition on the valve. The valve material was cast iron, which has minimal tensile strength. The overstress condition was caused by construction activities in the area. During the replacement of the valve, an inspection was performed on the external coating of the adjacent piping. The coating was in good condition. This piping is within the scope of license renewal. (CR-CNS-2008-09489)

" Potable water piping On March 20, 2007, a PVC potable water line was damaged during excavation. The piping was broken during backhoe operation. This piping is not within the scope of license renewal. (CR-CNS-2007-01938)

" Lawn sprinkler piping On August 11, 2006, a leak was identified on the yard sprinkler system. The leak was directly below the sprinkler head connection on the underground PVC piping. This piping is not within the scope of license renewal. (CR-CNS-2006-05822)

• Well discharge piping On September 6, 2000, a leak was identified on the well water supply piping to water treatment. The degraded section of carbon steel piping was replaced with PVC piping.

This piping is not within the scope of license renewal. (PIR 4-11217)

• Service water strainer drain to river On May 9, 1996, a washed out area was identified under the service water pump room.

The washout was caused by a leak in the service water strainer backwash piping return to the river. The piping leak was the result of internal erosion or corrosion. This piping is not within the scope of license renewal. (RCR 96-0473)

NLS2010050 Page 4 of 6 In addition to the above events, NPPD inspected buried service water piping in 2008 and buried diesel generator fuel oil (DGDO) piping and tanks in 2005. The service water piping underwent internal visual and volumetric examinations (broadband electromagnetic). The DGDO piping underwent visual inspection of the external surface at the location of excavation and a volumetric (guided wave) inspection. A volumetric inspection (ultrasonic) was performed on representative areas of each of the two DGDO tanks. The areas included the top, bottom, sides, heads, and welds. The results of all inspections indicated the piping and tanks were in good condition.

NPPD has an operating experience review program at CNS that monitors industry-wide operating experience from a number of sources (e.g., INPO (Institute of Nuclear Power Operations) reports and NRC Information Notices). Each item is reviewed for, applicability to CNS. Applicable items are assigned to a responsible individual as a corrective action under the CNS corrective action program. This process assures proper evaluation of operating experience.

In addition, LRA Section B.0.3 indicates that each aging management program includes program elements for corrective actions and a confirmation process that are consistent with the recommendations of NUREG-1801, Revision 1. These program elements entail actions to preclude recurrence of deficiencies in CNS aging management programs that may be revealed through operating experience (both plant-specific and industry-wide). These program elements apply on an ongoing basis, providing a feedback mechanism based on operating experience that ensures continuing program effectiveness throughout the period of extended operation.

Impact on Aging Management Reviews and Aging Management Programs NPPD has considered recent industry operating experience related to buried and underground piping for its impact on aging management reviews and aging management programs. Results of this review are provided below.

Aging Management Reviews Given the concern for possible limited access to piping, NPPD has evaluated aging management review results to confirm an appropriate program has been credited to manage the effects of aging of buried and underground piping. NPPD confirmed that aging management review results are appropriate for buried piping. NPPD identified no CNS piping subject to aging management review for license renewal that are exposed to air in structures with limited access.

If underground piping is identified during detailed reviews associated with program implementation, adequacy of credited aging management programs will be confirmed.

Aging Management Program In the CNS LRA, NPPD proposed to implement the aging management program described in NUREG-1801, Revision 1,Section XI.M 34, Buried Piping and Tanks Inspection. The NUREG-1801 AMP entailed primarily opportunistic inspections intended to confirm acceptable condition of protective'coatings on buried components. The program required at least one inspection prior to the period of extended operation and at least one inspection during the first 10 years of the period of extended operation. Based on operating experience, the CNS Buried Piping and Tanks

NLS2010050 Page 5 of 6 Inspection Program described in the LRA will be modified to include periodic inspections of all systems with buried piping that is subject to aging management review for license renewal.

The CNS program will include a risk assessment of in-scope buried piping and tanks that includes consideration of the impacts of buried piping or tank leakage and the risk for corrosion.

The program will classify pipe segments and tanks as having a high, medium or low impact of leakage based on items such as the safety class, the hazard posed by fluid contained in the piping, and the impact of leakage on plant operation. The high impact category includes safety-related piping segments, piping segments carrying radioactive materials and piping segments whose failure could cause a plant shutdown. Corrosion risk will be determined through consideration of items such as piping or tank material, soil resistivity, drainage, the condition of cathodic protection, and the type of coating. Conservative values for soil resistivity are used in the absence of measured parameters. CP is considered in conjunction with the condition of the coating in determining risk of corrosion. The ranking of impact and corrosion risk are combined to get an overall risk ranking for the piping segment. Inspection priority for initial inspection and frequency for periodic inspections of the in-scope piping and tanks will be based on the results of the risk assessment.

Prior to the period of extended operation, NPPD will inspect all high-risk buried tanks and at least one high-risk buried piping segment in each system within the scope of license renewal that has high-risk buried piping. This includes, but is not limited to, safety-related systems, which are service water, diesel generator fuel oil, high pressure coolant injection, and standby gas treatment systems. In addition, irrespective of risk ranking, NPPD will inspect at least one segment of buried piping in each of three in-scope systems, service water, fire protection, and condensate makeup. These additional inspections will examine the condition of the protective coating and will also include ultrasonic wall thickness measurements after the coating is removed from the piping surface.

NPPD will employ inspection methods with demonstrated effectiveness for detecting aging effects during the period of extended operation. The Electric Power Research Institute (EPRI) is evaluating a number of techniques for application to the commercial nuclear power industry, e.g., guided wave ultrasonic technology. NPPD will employ direct visual inspection or an inspection method that has been demonstrated effective by EPRI to address degradation of buried components.

Commitment NPPD will enhance the Buried Piping and Tanks Inspection Program described in LRA Section B. 1.3 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 piping segments and tanks will be classified as having a high, medium or low impact of leakage based on items such as the safety class, the hazard posed by fluid contained in the piping, and the impact of leakage on plant operation. The corrosion risk will be determined through consideration of items such as piping or tank material, soil resistivity, drainage, the presence of cathodic protection, and the type of coating. The inspection priority and frequency

NLS2010050 Page 6 of 6 for periodic inspections of the in-scope piping and tanks will be established based on the results of the risk assessment. Inspections will be performed using inspection techniques with demonstrated effectiveness. Prior to the period of extended operation, NPPD will inspect all high-risk buried tanks and at least one high-risk buried piping segment in each system within the scope of license renewal that has high-risk buried piping. This includes, but is not limited to, safety-related systems, which are service water, diesel generator fuel oil, high pressure coolant injection, and standby gas treatment systems. In addition, irrespective of risk ranking, NPPD will inspect at least one segment of buried piping in each of three in-scope systems, service water, fire protection, and condensate makeup.

NLS2010050 Page 1 of 3 Attachment 3 Changes to the License Renewal Application Cooper Nuclear Station, Docket No. 50-298, DPR-46 This attachment provides changes to the License Renewal Application (LRA) that conform to the positions taken in Attachment 2. The changes are presented in underline/strikeout format.

I1. LRA Appendix A, Section A. 1.1.3 is revised to read':

"The Buried Piping and Tanks Inspection Program is a new program that will include (a) preventive measures to mitigate corrosion and (b) inspections to manage the effects of corrosion on the pressure-retaining capability of buried carbon steel and gray cast iron components. Preventive measures will be in accordance with standard industry practice for maintaining external coatings and wrappings. Buried components will be 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.

Prior to entering the peraiod if extended operation, plant operating apcriend wnill be rieviewed to verify that an inspection occurred within the past ten years. if an inspetion did not ocethu, a fccused inspection will be perforetnd prior te the period of extend operation. A fteutsd inspeption will be perbfomed within the first ten years of the period of extended operation,inless an oppounistie inspetien focturis within this ten year period. A "focused inspection" is defined as an inspection per-formfed in areas witha history of corrosion problems and in areas with the highest likelihood ofncor rion pfeoblems.

The program will 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. Inspection priority and freqiuency for periodic inspections of the in-scope piping and tanks will be based on the results of the risk assessment. Periodic inspections will be implemented for the buried piping and tanks that are in scope and subject to aging management review for license renewal. Prior to the period of extended operation, NPPD will inspect all high-risk buried tanks and at least one high-risk buried piping segment in each system within the scope of license renewal that has high-risk buried piping.

This section reflects changes made in NLS2009040 in response to RAI B. 1.3-1 (ADAMS Accession Number ML091690050).

NLS2010050 Page 2 of 3 This program will be implemented consistent with the corresponding program described in NUREG-1801,Section XI.M34, Buried Piping and Tanks Inspection, prior to the period of extended operation."

Reference:

Response to RAI B. 1.3-3.

2. LRA Appendix B, Section B.1.3 is revised to read2 :

"Program Description The Buried Piping and Tanks Inspection Program is a new program that will include (a) preventive measures to mitigate corrosion and (b) inspections to manage the effects of corrosion on the pressure-retaining capability of buried carbon steel and gray cast iron components. Preventive measures will be in accordance with standard industry practice for maintaining external coatings and wrappings. Buried components will be 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.

Pfrei- to entering the period of extended operation, plant operating exper.ience will be eiewed to vegrifl that a espetion osesued within the past ten years. if an inspecthin did net occure, a ftosed inspection will be performed prior to the period of extendeo operation. A foused inspection will be perfosmed within the first ten years of the peri of extended operation, unless an oppofrenistieinspection octeus within this ten year period. A "fCocsed inspection" is defined as an inspection perafmed in afeas with a histoiy of c problems and in areas with the highest likelihood of aerosion rotion pr-eblems.

The program will 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 piping segments and tanks as having a high, medium or low imp~act of leakage based on items such as the safety class, the hazard posed by fluid contained in the piping, and the impact of leakage on plant operation. Corrosion risk will be determined through consideration of items such as 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. Periodic inspections will be implemented for the buried piping and tanks that are in scope and subject to aging management review for license renewal. Prior to the period of extended operation, NPPD will inspect all high-risk buried tanks and at least one high-risk buried piping segment in each system within the scope of license renewal that has high-risk buried piping.

2 This section reflects changes made in NLS2009040 in response to RAI B. 1.3-1 (ADAMS Accession Number ML091690050).

NLS2010050 Page 3 of 3 This program will be implemented prior to theperiod of extended operation."

Reference:

Response to RAI B. 1.3-3.

4 ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS© 4

ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS© Correspondence Number: NLS2010050 The following table identifies those actions committed to by Nebraska Public Power District (NPPD) in this document.: Any other actions discussed in the submittal represent intended or planned actions by NPPD. They are described for information only and are not regulatory commitments. Please notify the Licensing Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.

COMMITMENT COMMITTED DATE COMMITMENT NUMBER OR OUTAGE NPPD will recoat the wetted portion of the CNS NLS2010050-01 January 18, 2017 torus within three years after entering the PEO.

NPPD will remove sludge and inspect the wetted portion of the torus every refueling NLS2010050-02 January 18, 2017 outage from now until the torus is recoated.

NPPD will complete an analysis following each torus inspection that demonstrates that the projected pitting of the torus up to the time that the torus is recoated, will not result in reduction of torus wall thickness below minimum acceptable values.

NPPD will enhance the Buried Piping and Tanks Inspection Program described in LRA Section B.1.3 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 piping segments and tanks will be classified as having a high, medium or low impact of leakage based on items such as the safety class, the hazard posed by fluid contained in the piping, and the impact of leakage on plant operation. The corrosion risk will be determined through consideration of items such as piping or tank material, soil resistivity, drainage, the presence of cathodic protection, and the type of coating. The inspection priority and frequency for periodic inspections of the in-scope piping and tanks will be established based on the results of the risk assessment. Inspections will be performed using inspection techniques with demonstrated effectiveness.

PROCEDURE 0.42 REVISION 24 PAGE 20 OF 28.

4 ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS© Prior to the period of extended operation, NPPD will inspect all high-risk buried tanks and at least one high-risk buried piping segment in each system within the scope of license renewal that has high-risk buried piping. This includes, but is NLS2010050-05 January 18, 2014 not limited to, safety-related systems, which are service water, diesel generator fuel oil, high pressure coolant injection, and standby gas treatment systems.

Irrespective of risk ranking, NPPD will inspect at least one segment of buried piping in each of the three in-scope systems, service water, fire protection, and condensate makeup.

I PROCEDURE 0.42 REVISION 24 PAGE 21 OF 28 1