ML13212A229

TI-2515-182 - Phase 2 - Review of Implementation of the Industry Initiative to Control Degradation of Underground Piping and Tanks.

ML13212A229
Person / Time
Site:	Saint Lucie
Issue date:	07/30/2013
From:	Vias S NRC/RGN-II/DRS/EB3
To:	Nazar M Florida Power & Light Co
References
Download: ML13212A229 (10)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 July 30, 2013 Mr. Mano Nazar Executive Vice President and Chief Nuclear Officer Florida Power and Light Company P.O. Box 14000 Juno Beach, FL 33408-0420

SUBJECT:

ST. LUCIE NUCLEAR PLANT - NOTIFICATION OF NRC INSPECTION AND REQUEST FOR INFORMATION

Dear Mr. Nazar:

On September 16, 2013, the Nuclear Regulatory Commission will begin inspection activities for the St. Lucie Nuclear Plant in accordance with Temporary Instruction (TI) 2515-182, Review of Implementation of the Industry Initiative to Control Degradation of Underground Piping and Tanks. This inspection is scheduled to be performed from September 16-18, 2013, and will address the inspection requirements for Phase 2 of this TI.

In order to minimize the impact to your on-site resources, and to ensure a productive inspection, we have enclosed a list of documents needed for the preparation and implementation of this inspection. The documents that are requested for this inspection include all relevant documents that will allow the inspector(s) to adequately complete Phase 2 of this inspection.

We have discussed the schedule for these inspection activities with your staff and understand that our regulatory contact for this inspection will be Mr. Ken Frehafer, of your organization. If there are any questions about this inspection or the material requested, please contact the lead inspector Michael Coursey at (404) 997-4430 or Abhijit.Sengupta@nrc.gov.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's Agencywide

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

Sincerely, RA Steven J. Vias, Chief Engineering Branch 3 Division of Reactor Safety Docket Nos.: 50-335, 389 License No. DPR-67, NPF-16

Enclosures:

Inspection Document Request Temporary Instruction (TI 2515-182)

TI-182 Phase II Questions cc: (See page 3)

M. Nazar 3 cc:

Joseph Jensen Bryan Koon Site Vice President Director St. Lucie Nuclear Plant Florida Division of Emergency Management Electronic Mail Distribution Electronic Mail Distribution Paul Freeman Donna Calabrese Vice President Emergency Preparedness Manager Organizational Effectiveness St. Lucie Plant Florida Power & Light Company Electronic Mail Distribution Electronic Mail Distribution J. Kammel Peter Wells Radiological Emergency Planning Vice President Administrator Outage Support CFAM Department of Public Safety Florida Power & Light Company Electronic Mail Distribution Electronic Mail Distribution Senior Resident Inspector Robert J. Hughes St. Lucie Nuclear Plant Plant General Manager U.S. Nuclear Regulatory Commission St. Lucie Nuclear Plant P.O. Box 6090 Electronic Mail Distribution Jensen Beach, FL 34957-2010 Daniel D. DeBoer Michael Baughman Operations Site Director Training Manager St. Lucie Nuclear Plant St. Lucie Nuclear Plant Electronic Mail Distribution Electronic Mail Distribution Eric Katzman Faye Outlaw Licensing Manager County Administrator St. Lucie Nuclear Plant St. Lucie County Electronic Mail Distribution Electronic Mail Distribution Larry Nicholson James Petro Director Managing Attorney-Nuclear Licensing Florida Power & Light Company Florida Power & Light Company Electronic Mail Distribution Electronic Mail Distribution Jack Southard Alison Brown Director Nuclear Licensing Public Safety Department Florida Power & Light Company St. Lucie County Electronic Mail Distribution Electronic Mail Distribution Cynthia Becker (Acting) Chief Florida Bureau of Radiation Control Department of Health Electronic Mail Distribution

Letter to Mano Nazar from Steven J. Vias dated July 31, 2013.

SUBJECT:

ST LUCIE NUCLEAR PLANT - NOTIFICATION OF INSPECTION AND REQUEST FOR INFORMATION Distribution:

RIDSNRRDIRS PUBLIC RidsNrrPMStLucie Resource

TEMPORARY INSTRUCTION 2515-182 INSPECTION DOCUMENT REQUEST Inspection Dates: September 16-18, 2013 Inspection Procedures: TI 2515-182, Review of Implementation of the Industry Initiative to Control Degradation of Underground Piping and Tanks Inspector: Abhijit Sengupta, Reactor Inspector Information Requested for the Preparation and Completion of the In-Office Inspection The following documents listed below are requested (electronic copy, if possible) by September 6, 2013, to facilitate the preparation for the on-site inspection week

1. Organization list of site individuals responsible for the sites underground piping and tanks program.

2. Copy of Site Underground Piping and Tanks program.

3. Please review the ENCLOSURE 2 TI-182 PHASE 2 QUESTIONS and provide response and/or document requests.

4. Schedule for completion of the following NEI 09-14, Guideline For The Management of Underground Piping and Tank Integrity, Revision 3, attributes:

Buried Piping Procedures and Oversight Risk Ranking Inspection Plan Plan Implementation Asset Management Plan Underground Piping and Tanks Procedures and Oversight Prioritization Condition Assessment Plan Plan Implementation Asset Management Plan Information to be provided On-Site to the Inspector following the Entrance Meeting A. Location maps of buried & underground piping and tanks identified by the inspector from the information requested for the preparation week.

B. Copy of EPRI document Recommendations for an Effective Program to Control the Degradation of Buried Pipe.

C. Self or third party assessments of the Underground Piping and Tanks Program (if any have been performed).

Enclosure 1

2 D. For any of the NEI 09-14 Rev.3 attributes identified below which have been completed prior to the NRCs onsite inspection, provide written records that demonstrate that the program attribute is complete.

Buried Piping

• Procedures and Oversight

• Risk Ranking

• Inspection Plan

• Plan Implementation

• Asset Management Plan Underground Piping and Tanks

• Procedures and Oversight

• Prioritization

• Condition Assessment Plan

• Plan Implementation

• Asset Management Plan Inspector Contact Information Mailing Address Abhijit Sengupta US NRC- Region II Reactor Inspector Attn: Abhijit Sengupta 404-997-4430 245 Peachtree Center Avenue, Suite 1200 Abhijit.Sengupta@nrc.gov Atlanta, GA 30303

TI-182 PHASE 2 QUESTIONS Questions Response Question Subpart Number Initiative Consistency 1 a Has the licensee taken any deviations to Yes / No either of the initiatives?

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

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

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

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

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

b Are these requirements periodic or event Periodic /

driven? Event Driven /

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

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

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

Enclosure 2

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

utilized by the licensee produce results in accordance with the initiative guidelines, i.e.,

which emphasize the importance of components which have a high likelihood and consequence of failure and deemphasize the importance of components which have a low likelihood and consequence of failure?

6 a As part of its risk ranking process did the Yes / No licensee estimate/determine the total length of buried/ underground piping included in the initiatives?

b As part of its risk ranking process did the Yes / No licensee estimate/determine the total length of high risk buried/underground piping included in the initiatives?

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

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

NACE SP0169)?

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

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

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

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

or have a substantial number of inspections Deferred been deferred?

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

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

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

d Did the corrective action include an Yes / No / N/A evaluation of extent of condition of the piping (no leaks) or tanks and possible expansion of scope of inspections? (Preference should be given to high risk piping and significant leaks where more information is likely to be available).

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

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

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

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

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

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