View source for NL-17-048, Supplemental Information Associated with NRC Issuance of LR-ISG-2015-01, Changes to Buried and Underground Piping and Tank Recommendations, for Review

{{Adams
| number = ML17129A605
| issue date = 04/28/2017
| title = Supplemental Information Associated with NRC Issuance of LR-ISG-2015-01, Changes to Buried and Underground Piping and Tank Recommendations, for Review
| author name = Vitale A
| author affiliation = Entergy Nuclear Northeast
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000247, 05000286
| license number = DPR-026, DPR-064
| contact person = 
| case reference number = LR-ISG-2015-01, NL-17-048
| document type = Letter type:NL
| page count = 19
}}

=Text=
{{#Wiki_filter:A             ..                                                        Entergv Nuclear Northeast Indian Point Energy Center
  *~Entergx 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Tel (914) 254-2055 Anthony J Vitale Site Vice President NL-17-048 April 28, 2017 U.S. Nuclear Regulatory Commission Document Control Desk 11545 Rockville Pike, TWFN-2 F1 Rockville, MD 20852-2738

==SUBJECT:==
Supplemental Information Associated with NRC issuance of LR-ISG-2015-01, "Changes to Buried and Underground Piping and Tank Recommendations,"
for the Review of the Indian Point Nuclear Generating Unit Nos. 2 and 3 License Renewal Application Indian Point NuclearGenerating Unit Nos. 2 and 3 Docket Nos. 50-247 and 50-286 (License Nos. DPR-26 and DPR-64)

==REFERENCES:==
: 1) Entergy Letter NL-07-039, "Indian Point Energy Center License Renewal Application" (April 23, 2007) (ML071210507)
: 2) NUREG-1801, "Generic Aging Lessons Learned (GALL) Report" Revision 1, published Sept. 2005
: 3) NRC License Renewal Interim Staff Guidance LR-ISG-2011-03, "Generic Aging Lessons Learned (GALL) Report Revision 2 AMP Xl.M41, "Buried and Underground Piping and Tanks," issued July 26, 2012
: 4) NRC Safety Evaluation Report Related to the License Renewal of Indian Point Nuclear Generating Unit Nos. 2 and 3 (NUREG-1930, Supplement
: 2) published July 2015
: 5) NRC License Renewal Interim Staff Guidance LR-ISG-2015-01, "Changes to Buried and Underground Piping and Tank Recommendations," issued February 4, 2016

==Dear Sir or Madam:==

By letter dated April 23, 2007, and as later supplemented, Entergy Nuclear Operations, Inc.
(Entergy) submitted a license renewal application (LRA) for the Indian Point Energy Center (IPEC) in accordance with 10 CFR Part 54 of the Nuclear Regulatory Commission's (NRC) regulations (Reference 1). Entergy submitted its LRA based on NUREG-1801, "Generic Aging Lessons Learned (GALL) Report," Revision 1 (Reference 2). In the LRA, Entergy compared the IPEC Buried Piping and Tanks Inspection Program to NUREG-1801, Section Xl.M34.
In 2010, the NRC staff issued Revision 2 of NUREG-1801, which included updated recommendations for a buried and underground piping and tanks program in a new Section Xl.M41. Those recommendations were refined in 2011 with issuance of Interim Staff Guidance LR-ISG-2011-03, "Generic Aging Lessons Learned (GALL) Report Revision 2 AMP Xl.M41,

NL-17-048 Docket Nos. 50-247 and 50-286 Page 2 of 2 '
"Buried and Underground Piping and Tanks," (Reference 3). As indicated in Supplement 2 to NUREG-1930, published in 2015 (Reference 4), the NRC staff evaluated elements of the IPEC program against recommendations published in ISG-2011-03 and concluded that Entergy had demonstrated that the effects of aging would be adequately managed during the period of extended operation.
On February 4, 2016, the NRC issued Interim Staff Guidance LR-ISG-2015-01, "Changes to Buried and Underground Piping and Tank Recommendations," (Reference 5) which replaced aging management program (AMP) Xl.M41, "Buried and Underground Piping and Tanks," and the associated Updated Final Safety Analysis Report Summary Description in LR-ISG-2011-03, "Changes to the Generic Aging Lessons Learned (GALL) Report, Revision 2 Aging Management Program (AMP) Xl.M41, 'Buried and Underground Piping and Tanks."
The NRC has requested Entergy to review and summarize IPEC's LRA position regarding LR-ISG-2015-01. Attachment 1 provides the results of the comparison of the IPEG Buried Piping and Tanks Inspection Program to the new recommendations promulgated in LR-ISG-2015-01. shows the changes to the license renewal application that are warranted based on the results of this comparison.
There are no new commitments being made in this submittal.
r If you have any questions, or require additional information, please contact Mr. Robert Walpole at 914-254-6710.
I dec!re under penalty of perjury that the foregoing is true and correct. Executed on
   'i 1-~"5}           '2017.                         ,
Sincerely, AJV/rl                   /
Attachments:       1. Comparison of the IPEC Buried Piping and Tanks Inspection Program to the New Recommendations Promulgated in LR-ISG-2015-01
: 2. Changes to the License Renewal Application cc:    Mr. Daniel H. Dorman, Regional Administrator, NRC Region I Mr. Sherwin E. Turk, NRC Office of General Counsel, Special Counsel                          /I Mr. William Burton, NRC Senior Project Manager, Division of License Renewal Mr. Richard V. Guzman, NRR Senior Project Manager Ms. Bridget Frymire, New York State Department of Public Service Mr. John B. Rhodes, President and CEO NYSERDA NRC Resident ~nspector's Office

ATTACHMENT 1 TO NL-17-048 Comparison of the IPEC Buried Piping and Tanks Inspection Program to the New Recommendations Promulgated in LR-ISG-2015-01 ENTERGY NUCLEAR OPERATIONS, INC.
INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 DOCKET NOS. 50-247 AND 50-286

NL-17-048 Attachment '1 Page 1 of 9 LR-ISG-2015-01 Technical Change                Impact on Buried Piping and Tanks Inspection Program Preventive Actions (Element 2.);
Combining the two tables is a formatting Combined Table 2a and 2b in to one table       change that does not affect the IPEC Xl.M41-1. Also added "There are no             program. The fact that there are no recommended preventive actions for             recommended preventive actions for           )
titanium alloy, super austeriitic stainless    titanium, super austenitic stainless or nickel steels, and nickel alloy materials."           alloys has no effect on the IPEC program.
Changes to notes are discussed separately below.
No change is necessary.
Preventive Actions (Element 2 c.) added:                                                         /
This provision was in LR-ISG-2011-03.
The cathodic protection system monitoring      Entergy indicated in letter NL-13-098 that          .J interval discussed in Section 10.3 of NACE     the cathodic protection system would be SP0169-2007 may not be extended beyond         monitored every 12 months. For
_one y~ar.                                      clarification, Entergy is adding this provision to Appendix A and Appendix B program descriptions.
Preventive Actions (Element 2 g.iii.c.)
added:                                         This change added an option of crediting an annual fire water system leakage test in lieu For fire mains installed in accordance with    of performing inspections. on the system National Fire Protection Association NFPA      piping. Testing of1fire protection systems as 24, preventive actions beyond those in         an alternative to inspections is not credited NFPA 24 need not be provided if... (c) an      at IPEC.
annual system leakage rate test is conducted.                                     No change is necessary.
Preventive Actions (Element 2 e.iii) added:                                         Cathodic protection levels are maintained as described in NL-13-132 and soil conditions Depending on the environment, steel and        are not aggressive such that cracking is not stainless steel components can experience      an aging ef'.fect requiring management. In      \
stress corrosion cracking dependent on the     addition, the stainless steel piping in the cathodic protection polarization level,        program operates at temperatures below temperature, pH, etc. If these conditions are *140 &deg;F, which is the threshold for stress applicable, the applicant describes the        corrosion cracking in stainless steel.
conditions and alternative cathodic protection levels in the LRA.                  No change is necessary.

NL-17-048 Attachment 1 Page 2 of 9 LR-ISG-2015-01 Technical Change                 Impact on Buried Piping and Tanks Inspection Program Parameters Monitored or Inspected                                     I (Element 3 b.i., 3.b.ii., 3.b.iii., 3.b.iv.)      Item b of Element 3 indicates that surface added:                                            condition is the parameter monitored with visual inspections. The IPEC program
: b. Visual inspections of the external surface     provides for visual inspections, for which condition of the component should detect:         surface condition is' inherently the parameter
: i. loss of material due to general, pitting,      monitored.
crevice, and microbiologically-infl~enced corrosion (MIC) for aluminum alloy (MIC is        There is no buried cementiti6us piping in not applicable for aluminum alloys), copper       scope for license renewal.
alloy, steel, stainless steel, super austenitic, and titanium alloy components;                    In NL-09-088, IPEC identified buried plastic ii. loss of material due to wear for polymeric    (PVC) piping as being in the scope of materials;                                        license renewal. The purpose of this piping iii. cracking, spalling, and corrosion or         in the plant drains system is to protect the exposure of rebar for cementitious pipe;          RHR pump motors from internal flooding.
iv. cracking, blistering, change in color due     The piping is routed below grade to a nearby to water absorption for high-density              storm drain manhole in the transformer yard.
polyethylene (HOPE) and fiberglass                Operator actions are also used to prevent components.                                       flooding of the RHR pump motors. The
                                                 *aging management review for this piping identified no aging effects due to the lack of stressors in a soil environment and the non-aggressive soil as confirmed by soil samples. This conclusion was confirmed by NRC staff as documented in NUREG-1930 Vol. 2 Section 3.3A.2.3.15. As a result, there are no polymeric components in the scope of the Buried Piping and Tanks Inspection Program.
No change is necessary.

NL-17-048 Attachment 1 Page 3 of 9 LR-ISG-2015-01 Technical Change              Impact on Buried Piping and Tanks Inspection Program Parameters Monitored or Inspected (Element 3 c) added:                           LRA Section B.1.6 specifies that qualified inspection techniques be used and that
: c. Volumetric nondestructive examination       volumetric examination I
be performed if techniques as well as pit depth gages or       significant wall loss is detected on calipers may be used for measuring wall        underground piping. The direction for thickness as long as: (a) they have been       performing volumetric examination if demonstrated to be effective for the material, significant wall loss is detected from buried environment, and conditions (e.g., remote      piping will be added to LRA Section B.1.6.
methods) during the examination; and (b) they are capable of quantifying general wall thickness and the depth of pits. Wall thickness measurements are conducted to ensure that minimum wall thickness requirements are met.
Parameters Monitored or Inspected (Element 3 d.) added:                          The IPEC soil is nonaggressive and cathodic protection levels are maintained as stated in Inspections for cracking due to stress         LRA Section B.1.6 in letter NL-13-132.
corrosion cracking for steel, stainless steel  Therefore, the aging management review and susceptible aluminum alloy materials       results did not identify cracking as an aging utilize a method that has been demonstrated    effect requiring management. IPEC does to be capable of detecting cracking.           not credit the Buried Piping and Tanks Coatings that: (a) are intact, well-adhered,   Inspection Program to manage cracking.
and otherwise sound for the remaining inspection interval. .. do not have to be      No change is necessary.
removed.
I

NL-17-048 Attachment 1 Page 4 of.9 LR-ISG-2015-01 Technical Change             Impact on Buried Piping and Tanks Inspection Program Parameters Monitored or Inspected (Element 3 f.) added:                          IPEC does not credit alternatives to direct visual examinations for fire mains.
When using alternatives to excavated direct yisual examination of fire mains, appropriate  No change is necessary.
inspection parameters are used in order to detect indications of fire main leakage. For I
example:
iI* During periodic flow test, a reduction in available flow rate.
I i,i. For jockey pump monitoring, an increase in I
the number of pump starts or run time of the pump.
Iii.
I During annual system leakage rate testing an increase in unaccounted flow leak tates (i.e., the leakage path could be through k valve disc and seat, which is not pertinent to this AMP).
I Detection of Aging Effects (Element 4)
I added:
I As stated in NL-13-037, inspections are I                                             distributed between IP2 and IP3 according For multi-unit sites the inspections are       to material and code category. The
~istributed evenly among the units             numbers of inspection were not identical between the two units because of differences in plant design and in opportunities for inspections.
No change is necessary.

NL-17-048 Attachment 1 Page 5 of 9 LR-ISG-2015-01 Technical Change               Impact on Buried Piping and Tanks Inspection Program Detection I
of Aging Effects (Element 4 rable Xl.M41-2}                                The numbers of inspections performed in the IPEC program exceed the numbers pignificantly revised all preventive action    recommended for plants in Category F, categories and numbers of inspections.         which has the highest numbers of
~hanged the word "availability" to "operated"  recommended inspections. Cathodic for cathodic protection Category C             protection is not credited to reduce the applicability.                                 number of piping inspections at IPEC.
I                                              Nevertheless, the IPEC program specifies
* cathodic protection system availability of 85% where availability is defined as percent of the time the rectifiers are in service providing cathodic protection.
No change is necessary.
petection of Aging Effects (Element 4 a..)
added:                                         This item discusses transitioning to a I                                              category for which additional inspections are ifransitioning to a higher number of           specified. Because cathodic protection is inspections                                    not credited, IPEC meets the criteria for preventive action Category F, which has the highest number of recommended inspections. The IPEC program provides for approximately twice as many inspections as recommended for Category F.
No change is necessary.
Detection I
of Aging Effects (Element 4
t.)added:                                      Buried copper alloy piping was added to the IPEC program in 2013. This provision of the here piping constructed of steel, copper    ISG allows the combination of copper alloy 1
alloy, or aluminum alloy has been coated       piping with .steel piping to meet the With the same coating system and the           recomm~nded number of inspections. Since backfill has the same requirements, the total IPEC has carbon steel and copper alloy
 'nspections for this piping may be combined   buried piping that are coated with the same to satisfy the recommended inspection          mate.rial and have similar backfill, Sections
~uantity.                                      A.2.1.5 and A.3.1.5 were revised to identify that carbon steel and copper alloy are combined into the same inspection population.
(

NL-17-048 Attachment 1 Page 6 of 9 LR-ISG-2015-01 Technical Change             Impact on Buried Piping and Tanks Inspection Program Detection of Aging Effects (Element 4 I
I   b.iv.) added:                                 This change reduces the required number of
\__
I    ,                                       inspections for polymeric piping if it is If all of the in-scope polymeric material is  nonsafety-related. There are no polymeric I
ronsafety-related, no more than one           components in the scope of the IPEC Buried rpection need be conducted.                   Piping and Tanks Inspection Program.
f  cceptance Criteria (Element 6 b.) added:
No change is necessary.
There are no polymeric components in the     1 Cracking is absent in rigid polymeric         scope of the IPEC Buried Piping and Tanks tomponents. Blistering, gouges, or wear of    Inspection Program.
honmetallic piping is evaluated.
fI                              .
cceptance Criteria (Element 6 c.) added:
No change is necessary.
Section B.1.6 is revised to include projection if"he measured wall thickness projected to    of wall thickness to the end of the period of the end of the period of extended operation   extended operation.
tneets minimum wall thickness                            I tequirements.
I Acceptance Criteria (Element 6 d.) added:
I                   -                        As noted above, the aging management Indications of cracking in metallic pipe are review did not identify cracking as an aging tnanaged in accordance with the "corrective   effect requiring management for buried
    ~ctions" program element.                     piping at IPEC. Nevertheless, Section B.1.6 I                ,                           includes the provision that adverse indications will be entered into the plant corrective action program for evaluation of extent of condition and for I
determination of appropriate corrective actions (e.g.,
increased inspection frequency, repair, replacement). Cracking of piping in the scope of the IPEC program is a condition that warrants entry into the corrective action program.
No change is necessary.

NL-17-048 Attachment 1 Page 7 of 9 LR-ISG-2015-01 Technical Change                 Impact on Buried Piping and Tanks Inspection Program Acceptance Criteria (Element 6 f.) added:
I                                               Corrective action for failure to meet the Backfill is acceptable if the inspections do    backfill acceptance criteria is moving to a hot reveal evidence that the backfill caused    higher inspection category. IPEC already
~amage to the component's coatings or the       performs numbers of inspections greater surface of the component (if not coated).       than specified for Category F, the category with the highest number of recommended inspections.
No change is necessary.
Acceptance I
Criteria (Element 6 j.) added; r'hen fire water system leak rate testing is    Testing of fire protection systems as an fonducted, leak rates are within acceptance     alternative to inspections is not credited at lim~s of plant-specific documents.              IPEC.
No change is necessarv.
Acceptance Criteria (Element 6 m.) added:
Program description states that IPEC will k1ternatives to the -850 mV criterion for steel utilize the polarization potential of at least piping in Table Xl.M41-3.                       (i.e. more negative than) -850 mV instant-off as the acceptance criteria. No alternatives have been adopted.
No change is nece$s_ary.
Forrective Actions (Element 7 b.) added:
The IPEC program includes provisions for If coated or uncoated metallic piping or tanks  supplementing visual inspections with
~how evidence of corrosion, the remaining       surf~ce or volumetric non-destructive testing Wall thickness in the affected area is          if indications of significant loss of material
~etermined to ensure that the minimum wall      are observed for underground piping. This thickness is maintained. This may include       provision is added to Sections A.2.1.5, *
~ifferent values for large area minimum wall    A.3.1.5 and B.1.6 to address buried piping.
thickness and local area wall thickness. If
~he wall thickness extrapolated to the end of the period of extended operation meets tninimum wall thickness requirements, *
~ecommendations for expansion of sample rize, below do not apply.

NL-17-048 Attachment 1 Page 8 of 9 LR-ISG-2015-01 Technical Change              Impact on Buried Piping and Tanks Inspection Program Corrective Actions (Element 7 c.) added:
The IPEC program includes provisions to Provisions to limit the expansion of sample   double the sample size upon detection of size upon inspection results not meeting      significant coating damage as discussed in acceptance criteria. The number of            NL-13-098. In accordance with the ISG inspections within the affected piping        recommendations, the IPEC program will be categories are doubled or increased by 5,     revised to limit the number of inspections in whichever is smaller. This element also       the expanded sample to five (5). LRA includes provisions to relax the timing       Section B.1.6 is revised to add the sample recommendations for performance of the        expansion provisions from.NL-13-098 with additional inspections.                       modifications consistent with LR-ISG-2015-01 regarding sample expansion and timing of inspections on the expanded sample.
Corrective Actions (Element 7 e.) added:
ISG-2015-01 added an option of crediting an Sources of leakage detected during            annual fire water system leakage test in lieu pressure tests are identified and corrected. of performing inspections on the system piping. Testing of fire protection systems as an alternative to inspections is not credited at IPEC.
No change is necessary.
Corrective Actions (Element 7 f.) added;:
Testing of fire protection systems as an When using the option of monitoring the       alternative to inspections is not credited at activity of a jockey pump instead of          IPEC.
inspecting buried fire water system piping, a flow test or system leak rate test is         No change is necessary.
conducted by the end of the next refueling outage or as directed by the current licensing basis, whichever is shorter, when unexplained changes in jockey pump activity (or equivalent equipment or parameter) are observed.

NL-17-048 Attachment 1 Page 9 of 9 LR-ISG-2015-01 Technical Change.            Impact on Buried Piping and Tanks Inspection Program Corrective Actions (Element 7 g.) added:
    *I                                           As noted above, the aging management Indications of cracking are evaluated in    review did not identify cracking as an aging
     ~ccordance with applicable codes and plant- effect requiring management. Therefore,
     ~pacific design criteria.                   this corrective action is not applicable at IPEC. Nevertheless, LRA Section B.1.6              I includes the provision that adverse indications will be entered into the plant corrective action program for evaluation of extent of condition and for determination of appropriate corrective actions (e.g.,
increased inspection frequency, repair, replacement).
No change is necessary.
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ATTACHMENT 2 TO NL-17-048 Changes to the License Renewal Application ENTERGY NUCLEAR OPERATIONS, INC.
INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 DOCKET NOS. 50-247 AND 50-286

NL-17-048 Attachment 2 I
Page 1 of 6 I
A.2.1.5    Buried Piping and Tanks Inspection Program I
Th~ Buried Piping and Tanks Inspection Program is a new program that includes (a) preventive measures to mitigate corrosion and (b) inspections to manage the effects of corrosion on the pre:ssure-retaining capability of buried and underground carbon steel, copper alloy, gray cast iro~, and stainless steel components. The program manages loss of material for bolting on piping within the scope of the program. Preventive measures are in accordance with standard ind&#xb5;stry practice for maintaining external coatings and wrappings. Buried components are inspected when excavated during maintenance. If trending within the corrective action program identifies susceptible locations, the areas with a history of corrosion problems are evaluated for thel need for additional inspection, alternate coating, or replacement. Cathodic protection (CP) systems installed at IPEC provide additional protection of license renewal in-scope buried piping anq minimize corrosion in areas that have been found susceptible to corrosion based on indirect inspections or testing. To the extent they are proven effective, the CP systems at IPEC will be considered in risk ranking to ensure that the in-scope buried piping systems that are more su~ceptible to external corrosion continue to receive a higher risk ranking when determining inspection priority. IPEC will perform CP surveys at least once every twelve (12) months.
I I
IP2 will perform 20 direct visual inspections of buried piping during the 10 year period prior to thei PEO. IP2 will perform 14 direct visual inspections of carbon steel/copper alloy buried piping duning each 10-year period of the PEO. Soil samples will be taken prior to the PEO and at least on~e every 1O years in the PEO. Soil will be tested at a minimum of two locations at least three feet below the surface near in-scope piping to determine representative soil conditions for each system. If test results indicate the soil is corrosive then the number of carbon steel/copper alloy piping inspections will be increased to 20 during each 10-year period of the PEO. Visual
* insbections will be supplemented with surface or volumetric non-destructive testing if indications of significant loss of material are observed. Measured wall thickness will be projected to the end of the period of extended operation to ensure minimum wall thickness requirements are met.
--1 Th$ Buried Piping and Tanks Inspection Program will be implemented prior to the period of extE3nded operation. This new program will be implemented consistent with the corresponding prdgram described in NUREG-1801 Section Xl.M34, Buried Piping and Tanks Inspection with thei following modification.
I Th~ Buried Piping and Tanks Inspection Program will be modified based on operating I
experience to include a risk assessment of in-scope buried piping and tanks that includes co~sideration of the impacts of buried piping or tank leakage and of conditions affecting the risk for:corrosion. The program will classify pipe segments and tanks as having a high, medium or lo~ impact of leakage based on the safety class, the hazard posed by fluid contained in the piping and the impact of leakage on reliable plant operation. Corrosion risk will be determined thrcpugh consideration of piping or tank material, soil resistivity, drainage, the, presence of cat~odic protection and the type of coating. Inspection priority and frequency for periodic inspections of the in-scope piping and tanks will be based on the results of the risk assessment.
Inspections will be performed using qualified inspection techniques with demonstrated effectiveness, Inspections will begin prior to the period of extended operation.
I I                  .
Underground I
piping within the scope of license renewal and subject to aging management rev,iew will be visually inspected prior to the period of extended operation and then on a I

                                                                                         , NL-17-048 Attachment 2 Page 2of6 frequency of at least once every two years during the period of extended operation. This inspection frequency will be maintained unless the piping is subsequently coated in accordance wit~ the preventive actions specified in NUREG-1801 Section Xl.M41 ~s modified by LR-ISG-2011 032015-01. Visual inspections will be supplell')ented with surface or volumetric non-de~tructive testing if indications of significant loss of material are observed. Measured wall thidkness will be projected to the end of the period of extended operation to ensure minimum walll thickness requirements are met. Consistent with revised NUREG-1801 Section XLM41, sudh adverse indications will be entered into the plant corrective action program for evaluation of Jxtent of condition and for determination of appropriate corrective actions (e.g., increased inspection frequency, repair, replacement).                                /
A.~.1.5       Buried Piping and Tanks Inspection Program Th~ Buried Piping and Tanks Inspection Program is a new program that includes (a) preventive me~sures to mitigate corrosion and (b) inspections to manage the effects of corrosion on the pre~sure-retaining capability of buried and underground carbon steel, gray cast iron, copper a119y and stainless steel components. The program manages loss of material for bolting on piping within the scope of the program. Preventi"ie measures are in accordance with standard industry practice for maintaining external coatings and wrappings. Buried components are            .
inspected when excavated during maintenance. If trending within the corrective action program idehtifies susceptible locations, the areas with a history of corrosion problems are evaluated for the! need for additional inspection, alternate coating, or replacement. Cathodic protection (CP) systems installed at IPEC provide additional protection of license renewal in-scope buried piping 1
and minimize corrosion in areas that have been found susceptible to corrosion based on indirect inspections or testing. To the extent they are proven effective, the CP systems at IPEC will be cohsidered in risk ranking to ensure that the in-scope buried piping systems that are more su~ceptible to external corrosion continue to receive a higher risk ranking when determining inspection priority. IPEC will perform CP surveys at least once every twelve (12) months.
IP~   will perform 14 direct visual inspections of buried piping during the 10 year period prior the PEp. ~P3 will perform 16 direct visual inspections of carbon steel/copper alloy and stainless steel buried piping during each 10-year period of the PEO. SoiLsamples will be taken prior to thel PEO and at least once every 10 years into the PEO. Soil will be tested at a minimum of two loc?tions at least three feet below the surface near in-scope piping to determine representative soil conditions for each system. If test results indicate the soil is corrosive then the number of carbon steel/copper alloy piping inspections will be increased to 22 during each 10-year period of t~e PEO. Visual inspections will be supplemented with surface or volumetric non-destructive testing if indications of significant loss of material are observed. Measured wall thickness will be pro!jected to the end of the period of extended operation to ensure minimum wall thickness req:uirements are met.
Th~ Buried Piping and Tanks Inspection Program will be implemented prior to the period of extbnded operation. This new program will be implement~d consistent with the corresponding probram described in NUREG-1801 Section Xl.M34, Buried Piping and Tanks Inspection with thel follo~ing   ~~dification.            .              .         ..                   .      .
The Buried P1p1hg and Tanks Inspection Program will be mod1f1ed based on operating experience to include a risk assessment of in-scope buried piping and tanks that includes
* 1 co sideration of the impacts of buried piping or tank leakage and of conditions affecting the risk

NL-17-048 Attachment 2 Page 3of6 for porrosion. The program will classify pipe segments and tanks as having a high, medium ~r loVl1 impact of leakage based on the safety class, the hazard posed by fluid contained in the pipmg and the impact of leakage on reliable plant operation. Corrosion risk will be determined thr~ugh I
consideration of piping or tank material, soil resistivity,. drainage, the presence of
* cathodic protection and the type of coating. Inspection priority and frequency for periodic inspections of the in-scope piping and tanks will be based on the results of the risk assessment.
Inspections will be performed using qualified inspection techniques with demonstrated eff~ctiveness, Inspections will begin prior to the period of extended operation. Underground piping within the scope of license renewal and subject to aging management review will be visJ.ally inspected prior to the period of extended operation and then on a frequency of at least onqe every two years during the period of exterided operation. This inspection frequency will be maintained unless the piping is subsequently coated in accordance with the preventive actions spJcified-in NUREG-1801 Section Xl.M41 as modified by LR-ISG-2011-03. V_isual inspections willlbe supplemented with surface or volumetric non-destructive testing if indications of significant loss of material are observed. Measured wall thickness will be projected to the end of the period of extended operation to ensure minimum wall thickness requirements are met.
Cohsistent with revised NUREG-1801 Section Xl.M41, such adverse indications will be entered intd the plant corrective action program for evaluation of extent of condition and for det~rmination of appropriate corrective actions (e.g.; increased inspection frequency, repair, replacement).

NL-17-048 Attachment 2 Page 4of6 B.1.6 BURIED PIPING AND TANKS INSPECTION Program pesccjption
' The Buried Piping and Tanks Inspection Program is a new program that includes (a) preventive measures to mitigate corrosion and (b). inspections to manage the effects of corrosion on the pressure-retaining capability of buried and underground carbon steel, gray cast iron, copper alloy and stainless steel components. The program manages loss of material for bolting on piping within the scope of the program. Preventive measures are in accordance with standard industry practice for maintaining external coatings and wrappings. Buried components are inspected when excavated during maintenance. If trending within the corrective action program identifies susceptible locations, the areas with a history of corrosion problems are evaluated for the need for additional inspection, alternate coating, or replacement. The program applies to buried components in the following systems.
* Safety injection
* Service water
* Fire protection
           *Fuel oil
* Security generator
           *City water
* Plant drains
* Auxiliary feedwater
* Containment isolation support*
* River water service (IP1)
* Circulating water system (IP2)
* Instrument air (IP2)
Of these systems, only the safety injection system contains radioactive fluids during normal operations. The safety injection system buried components are stainless steel. Stainless steel is used in the safety injection system for its corrosion resistance. This program also applies to .
underground components-in the IP3 service water and city water systems and the IP2 and IP3 fuel oil systems.
Cathodic protection systems installed at IPEC provide additional protection of license renewal in-scope buried piping and minimize corrosion in areas that have been found susceptible to corrosion based on indirect inspections (i.e., guided wave inspections) or testing (e.g., AP-EC surveys). To the extent they are proven effective, the CP systems at IPEC will be considered in risk ranking to ensure that the in-scope buried piping systems more susceptible to external corrosion continue to receive a higher risk ranking when determining inspection priority.
The CP systems will be monitored with the following acceptance criteria.
* Minimum -850 mV instant-off soil-to-pipe potential relative to a copper/copper sulfate reference electrode
* Maximum -1200 mV instant-off soil-to-pipe potential relative to a copper/copper sulfate reference electrode

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* Minimum availability of 85%. The percent of system availability is calculated by determining the percent of the time the rectifiers are in service providing cathodic protection. "In service" is defined as rectifier current output values greater than zero amps or zero volts. The time the system is out of service for testing is not included in the calculation of system availability.
* Minimum of 80% CP system effectiveness. Test locations must meet a soil-to-pipe potential of instant-off -850 mV to -1200 mV relative to a copper/copper sulfate reference electrode. The percent of CP effectiveness is calculated by using the last measured values at each test station and dividing the total number of CP survey points that meet the required acceptance criteria by the total number of points surveyed during the monitoring period.
Failure to meet these acceptance criteria will result in no credit being taken for the CP system in the risk ranking process. IPEC will perform CP surveys at least once every twelve (12) months.
The Buried Piping and Tanks Inspection Program will be modified based on operating experience to include a risk assessment of in-scope buried piping and tanks that includes consideration of the impacts of buried piping tank or tank leakage and of conditions affecting the risk for corrosion. The program will classify pipe segments and tanks as having a high, medium or low impact of leakage based on the safety class, the hazard posed by fluid contained in the piping and the impact of leakage on reliable plant operation. Corrosion risk will be determined through consideration of piping or tank material, soil resistivity, drainage, the presence of cathodic protection and the type of coating. Inspection priority and frequency for periodic inspections of the in-scope piping and tanks will be based on the results of the risk assessment.
Inspections will be performed using qualified inspection techniques with demonstrated effectiveness. Visual inspections will be supplemented with surface or volumetric non-destructive testing if indications of significant loss of material are observed. Measured wall thickness will be projected to the end of the period of extended operation to ensure minimum wall thickness requirements are met. Inspections will begin prior to the period of extended operation.
If future inspections reveal significant coating damage caused by non-conforming backfill. then 1 Entergy will double the inspection sample size up to an increase of five (5) inspections. If adverse indications are found in the expanded inspection sample. then Entergy will determine the extent of condition and the extent of cause. The size of the follow-up inspection sample will be determined based on the extent of condition and the extent of cause. The timing of the additional examinations will be based on the severity of the degradation and will be commensurate with the consequences of a leak or loss of function from the affected pipe. In all cases. the expanded sample inspections will be completed within the 10-year interval in which the original adverse indication was identified or. if identified in the latter half of the 10-year interval. within 4 years after the end of the 10-year interval. Sample size expansion may be limited by the extent of piping or tanks subject to the observed degradation mechanism.
Underground piping within the scope of license renewal and subject to aging management review will be visually inspected prior to the period of extended operation and then on a frequency of at least once every two years during the period of extended operation. This inspection frequency will be maintained unless the piping is sub~equently coated in accordance with the preventive actions specified in NUREG-1801 Section Xl.M41 as modified by LR-ISG-

NL-17-048 Attachment 2 Page 6of6 2011 032015-01. Visual inspections will be supplemented with surface or volumetric non-destructive testing if indications of significant loss of material are observed. Measured wall thickness will be projected to the end of the period of extended-operation to ensure minimum wall thickness requirements are met. Consistent with revised NUREG-1801 Section Xl.M41, such adverse indications will be entered into the plant corrective action program for evaluation of extent of condition and for determination of appropriate corrective actions (e.g., increased inspection frequency, repair, replacement).
The program will be implemented prior to the period of extended operation.
NUREG-1801 Consistency The Buried Piping and Tanks Inspection Program will be consistent with program attributes described in NUREG-1801, Section Xl.M34, Buried Piping and Tanks Inspection.
Exceptions to NUREG-1801 None Enhancements None Operating Experience The Buried Piping and Tanks Inspection Program is a new program. Plant and industry operating experience will be considered when implementing this program. Industry operating experience that forms the basis for the program is described in the operating experience element of the NUREG-1801 program description. IPEC1 plant-specific operating experience is not inconsistent with the operating experience in the NU REG-1801 program description.
The IPEC program is based on the program description in NUREG-1801, which in turn is based on industry operating experience. As such, operating experience assures that implementation of the Buried Piping and Tanks Inspection program will manage the effects of aging such that applicable components will continue to perform their intended functions consistent with the current licensing basis through the period of extended operation.
Conclusion The Buried Piping and Tanks Inspection Program will be effective for managing aging effects since it will incorporate proven monitoring techniques, acceptance criteria, corrective actions, and administrative controls. The Buried Piping and Tanks Inspection Program assures the effects of aging will be managed such that applicable components will continue to perform their intended functions consistent with the current licensing basis through the period of extended operation.}}