ML12334A689

Official Exhibit - NYS000177-00-BD01 - Entergy, Corrective Action, Condition Report (CR-IP2-2005-03902) (Oct. 31, 2005) (CR-IP2-2005-03902)

ML12334A689
Person / Time
Site:	Indian Point
Issue date:	12/16/2011
From:	Harrison C B Entergy Nuclear Operations
To:	Atomic Safety and Licensing Board Panel
SECY RAS
References
RAS 21566, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01 CR-IP2-2005-03902
Download: ML12334A689 (7)

Text

United States Nuclear Regulatory Commission Official Hearing Exhibit In the Matter of

Entergy Nuclear Operations, Inc. (Indian Point Nuclear Generating Units 2 and 3)

ASLBP #:07-858-03-LR-BD01 Docket #:05000247 l 05000286 Exhibit #:

Identified:

Admitted: Withdrawn:

Rejected: Stricken: Other: NYS000177-00-BD01 10/15/2012 10/15/2012 NYS000177 Submitted: December 16, 2011 I Entergy I CORRECTIVE ACTION I CR-IP2-200S-03902 CANumber:

Group Name Assigned By: CRG/CARB/OSRC Assigned To: System Eng Mgmt Subassigned To: System Eng Elec/I&C Staff Originated By: Harrison,Christine B Performed By: Orlando,Thomas Sub performed By: Ingrassia,Christopher A Approved By: Closed By: Reynolds,1oseph A Current Due Date: 11/0112005 CA Type: DISP -ACE/HT Plant Constraint:

1. NONE CA

Description:

Harrison,Christine B Orlando,Thomas Ingrassia,Christopher A 10/4/2005 08:24:37 1111/2005 14:54:58 1111/2005 13:50:41 11/1/2005 15:40:41 Initial Due Date: 11/0112005 Please perfonn higher-tier apparent cause evaluation and assign further corrective actions as required.

Note that a corrective action is being assigned to CA&A to document the CARB presentation of your evaluation.

Response:

See sub response.

Sub response : See attached ACE. Closure Comments:

Per CA&A review, noted the ACE report addressed all expected discussion points and was therefore accepted pending CARB review. CA# 2 assigned to document the results of the CARB review, therefore this CA closed. Attachments:

Subresp Description CR-IP2-2005-03902 INPO AFI Cathodic Protection IPEC00018042 IPEC00018042 HIGHER-TIER APPARENT CAUSE Sheet 1 of 6 Condition Report Number: Assigned Department:

IP2*200S*03902 System Engineering PROBLEM STATEMENT: (see procedure Step 5.3[2](a))

INPO has completed it investigation and has issued the following AFI. (ER.3-2) The lack of a functioning cathodic protection system in severe environmental conditions leaves piping and structures susceptible to corrosion-induced failures.

An analysis has not been performed to identify the effects on system operation or if compensatory measures are needed. Is this ACE report documenting an Equipment Failure I D I Evaluation (EFE)? (see Procedure steps 5.3[2](b) and 5.5) Yes No IF Yes, then, complete the Equipment Failure Checklist form located in EN-Ll-118 OR other suitable, site-approved EFE analysis process. Items of the checklist with "Yes" responses are to be discussed in the narrative section of this report. IF No, then an EFE analysis is not required.

Did the CR involve one or more Human Performance (HP) Errors? (see Procedure steps 5.3[2](b) and 5.6) DYes For example, was the Event Classified as a HP Precursor, Error or Station Reset either by the CRG or the CR evaluator?

If Yes, then ensure EN-HU-101 HP Error Review Form is completed and provided in the ACE response or on a CA within the CR, as the CRG directs. If No, then the HP Error Review form is not required.

If the CR involves an Organizational

& Programmatic (O&P) issue, then use the evaluation guidance in EN-Ll-118, Attachment 9.11 (see Procedure step 5.7) NARRATIVE/EVENT DESCRIPTION/BACKGROUND: (see Procedure step S.3[2](c))

IPEC Cathodic Protection Unit 1 History

• The 1989 annual survey and investigating testing of the cathodic protection systems, by Con Edison Corrosion Engineering, indicated that the Unit 1 cathodic protection system had deteriorated and is no longer providing adequate protection.

• A modification was performed in the 1993/1994 time frame (Cathodic Protection Unit 1 Dock EGP-90-05076-E) that installed a new cathodic protection system consisting of six (6) rectifiers.

This was Phase I of the Unit 1/2 cathodic protection system upgrade. IPEC00018043 IPEC00018043 HIGHER-TIER APPARENT CAUSE Sheet 2 of6

• An evaluation of the Unit 1 cathodic protection system was performed in June, 1994 by Harco Technologies Corporation.

The evaluation concluded that the system was operating to adequately protect the dock.

• In March of 2002 CR-IP2-2002-02533 documented that most of the cathodic protection strings were seriously degraded and all of the strings on 14 rectifier were not functioning.

In addition degradation of the dock has been noted. This is due to the lack of cathodic protection.

Actions Completed A cost summary has been prepared by Civil/Structural Engineering for the remediation of the Unit 1 dock. Actions Needed (Detailed in the Cost Summary)

• Determine the condition of the dock structures.

• Repair the dock structures.

• Repair the cathodic protection anodes.

• Survey the dock and restore the cathodic protection system to operation.

Summary Unit 2 The Unit 1 cathodic protection system is no longer providing adequate protection to the dock. History

• The 1989 annual survey and investigating testing of the cathodic protection systems, by Con Edison Corrosion Engineering, indicated that the Unit 2 cathodic protection system has deteriorated and is no longer providing adequate protection.

• A modification was initiated to restore the cathodic protection system to operation.

The modification consisted of four phases.

• Phase I -Unit 1 Cathodic Protection detailed above.

• Phase II -Unit 2 Dock Sheet Piles.

• Phase III -Unit 2 Circulating and Service Water lines.

• Phase IV -Unit 2 H-Piles.

• Phase II (ECX-93-05076-E) of the modification was installed.

The modification installed two (2) new rectifiers (Rectifier A and 8). The start-up of the system was performed on 3/16/01. Shortly after the initial start-up the system failed due to a lack of proper maintenance.

• The history of the "A' water side rectifier is not known. The documentation shows it may have been shutdown since installation.

It appears that it was never placed in service. IPEC00018044 IPEC00018044 HIGHER-TIER APPARENT CAUSE Sheet 3 of 6

• On 9/13/01 and 7/25/03 the '8' land side rectifier transformer failed. The transformer was replaced on 7/2/05. The system has not been restored to service. The FSAR lists the following structures as being protected by cathodic protection:

1) Circulation water lines 2) Service water lines 3) Bearing piles 4) Sheet piling (earth and water side) and wing wall anchorage system 5) Metallic structures inside intake structure (traveling screens, bar racks, circulating water pump suction, service water pump suction).

Contrary to this statement the structures, systems and components mentioned in items 1,2,3 and 5 do not have cathodic protection.

The reason is due to the lack of cathodic protection systems being installed for these structures, systems and components.

See CR-IP2-2005-02790.

The de-icing lines were removed under modification CPG-84-02732-50 and therefore no longer require cathodic protection.

The traveling screen and bar racks were replaced under projects 02732-50 and 52176-00 with stainless steel material and therefore no longer require cathodic protection.

Actions Completed A cost summary has been prepared by Civil/Structural Engineering for the remediation of the Unit 2 dock. Actions Needed

• Survey the dock and restore A and 8 rectifiers to service. Work order IP2-05-20405 exists for this and should be performed as soon as possible to provide corrosion protection of the sheet piles. This survey requires an outside vendor.

• Perform an inspection of the structures stated in the FSAR to determine their condition.

• Install Phases III and IV of the cathodic protection upgrade to restore cathodic protection to the structures mentioned in the FSAR. Summary The Unit 2 cathodic protection system has not been providing adequate protection since at least 1989. General corrosion has been noted on the dock structures.

IPEC00018045 IPEC00018045 HIGHER-TIER APPARENT CAUSE Sheet 4 of6 Unit 3 History

• The entire cathodic protection system was "temporarily" removed in the mid nineteen eighties to support the installation of the intake structure enclosure.

• A cathodic protection system has not been re-installed.

• It appears that there may have been sacrificial anodes for the intake structure.

These anodes were removed in 1992 under modification MMP-91-03-146 (work order 13-920193100).

• The Intake Structure sheet piling wing walls were worked upon in 1986 and 1994 via modifications 86-03-138IS and 94-03-194IS.

• In 1990, the sheet piling for the Condensate Polisher building required work due to corrosion.

• In 1994, most of the Discharge Canal sheet piling system had to be replaced due to corrosion induced loss of material at a cost that was in the millions of dollars range. The FSAR lists the following structures protected by cathodic protection:

1) De-icing lines 2) Bearing piles 3) Sheet piling (earth and water side) and wing wall anchorage system 4) Metallic structures inside intake structure (traveling screens, bar racks, circulating water pump suction, service water pump suction).

Contrary to this statement none of these structures are protected by cathodic protection.

See CR-IP3-200S-03398.

Actions Needed (assigned by CR-IP3-200S-03398)

• Perform an analysis and inspection of the structures mentioned in the FSAR. (ER IP3-0S-224S7).

• Install a cathodic protection system as needed based on the analysis and inspection (ER IP3-0S-224S7).

Summary The Unit 3 structures, systems and components mentioned in the FSAR have not been protected from corrosion since the mid nineteen eighties, since there has been no cathodic protection system installed.

General corrosion has been noted on the dock structures.

There is also a concern with the Unit 3 sewage pipe line that was placed into service in 1989. The modification was not completed, including the cathodic protection of the line. IPEC00018046 IPEC00018046 HIGHER-TIER APPARENT CAUSE Sheet 5 of 6 Summary The sewage pipe line may not be protected from corrosion since installation in 1989. See CR-IP3-2000-00394 (ER 13-007762221).

APPARENT/CONTRIBUTING CAUSE(S}: (see Procedure step 5.3[2](d))

The apparent cause for the current condition of the Cathodic Protection System has been addressed in CR-IP3-2005-03398.

The apparent cause is stated as: Latent organization weakness in that the risk associated with the lack of a Cathodic Protection system was not clearly understood by personnel approving resource allocation to complete the modification process. Based on the interviews conducted, in spite of studies, statements regarding the risks involved, and carefully planned work details, the Cathodic Protection system was always been downgraded on the prioritized Capital Budget list. A contributing cause for the current condition of the Cathodic Protection System was due a lack of ownership in that the CP system was not considered a system at IPEC in need of assignment of an individual monitoring performance.

The apparent cause for the INPO AFI is a combination of the latent organizational weakness and lack of ownership as detailed above (CR-IP3-2005-03398).

Had there been proper focus on the System on a Station level the actions needed, as detailed in the narrative/evenUdescription/background section of this report, for the Cathodic Protection System and SSCs protected by the Cathodic Protection System could have been properly prioritized and incorporated into the Station schedule.

Had there been ownership of Cathodic Protection on a System level the actions needed, as detailed in the narrative/evenUdescription/background section of this report, could have been raised to the appropriate attention needed for the System on a Station level. EXTENT OF CONDITION: (see Procedure step 5.3[2](e))

This apparent cause report addresses the entire Cathodic Protection System at IPEC. Therefore the extent of condition is encompassed in the narrative/event description/background section of this report. SAFETY IMPLICATIONS: (see Procedure step 5.3[2](f))

There are no radiological, nuclear of industrial safety issues associated with the lack of Cathodic Protection.

This is based on recent Maintenance Rule Inspections of the intake structures that have found the structure to be acceptable with deficiencies.

A lack of a Cathodic Protection System could result in an industrial safety issue if the structural integrity of the dock was affected.

PREVIOUS SITE OPERATING EXPERIENCE: (see Procedure step 5.3[2](g))

This apparent cause report addresses the entire Cathodic Protection System at IPEC. Therefore the previous site operating experience is encompassed in the narrative/event description/background section of this report. IPEC00018047 IPEC00018047 HIGHER-TIER APPARENT CAUSE Sheet 6 of6 EXTERNAL (INDUSTRY)

OPERATING EXPERIENCE: (see Procedure step 5.3[2](h))

A search of the INPO database was conducted using the words cathodic protection.

The search revealed many operating experience reports. These reports detailed failures of cathodic protection systems and failures of structures, systems and components due to a lack of cathodic protection.

The search also revealed a recent (August 2005) operating experience digest dedicated to cathodic protection.

The digest notes the cathodic protection.

issues identified in operating experience reports and INPO evaluations.

CORRECTIVE ACTION(S): (see Procedure step 5.3[2](i))

The actions needed, as detailed in the narrative/eventldescription/background section of this report, for the Cathodic Protection System have already been identified through past condition reports or studies. The details of these actions have not been compiled into a common document.

A common IPEC document detailing all of the actions needed for the Unit 1, 2 and 3 Cathodic Protection Systems would ensure that the actions are properly incorporated into the Station schedule and that the Station places the proper focus on the Cathodic Protection System. ISSUE / PROBLEM SOLUTION / RESOLUTION

/ ACTION / COMPLETED

[note any Work Orders, MODs, other] The Cathodic Protection System is not a The Cathodic Protection System is a System at IPEC and a System system at IPEC. Engineer has been assigned to the system. Also see CR-IP3-2005-03398 CA-4 PROPOSED/ASSIGNED CORRECTIVE ACTIONS ITEM # ISSUE/CAUSE SOLUTION / RESOLUTION TYPE CA Assigned Due Date [note any Work Orders, MODs, Department other] AC-1 A common IPEC document Develop an action plan for the Corrective System 1/5/06 detailing all of the actions IPEC Cathodic Protection Engineering needed/identified for the System. Assign additional Electrical Cathodic Protection System corrective actions for the action does not exist. plan actions if necessary.

PCRS CA# 3 EVALUATOR (Print Name) Date report completed Phone Extension of Investigator Christopher A. Ingrassia 10/31/05 271-7047 IPEC00018048 IPEC00018048