ML12090A745
| ML12090A745 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 10/23/2008 |
| From: | Entergy Nuclear Operations |
| To: | Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| Shared Package | |
| ML12090A727 | List:
|
| References | |
| RAS 22156, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01 CR-IP2-2008-04754 | |
| Download: ML12090A745 (13) | |
Text
ENT000426 Submitted:
March 30 , 2012 Entergy CONDITION REPORT I CR-IP2-2008-047S4 Originator:
Aze v ed o, Nelson F Originator Site Group: IP 2 P&C Eng C o de s Mgmt IP2 Originator Phone: 7346775 Operability Required:
Y Reportability Required:
Y Supervisor Name: Burr o ni , Richard J Discovered Date: 10/2312008 06:04 Condition
==
Description:==
Initiated Date: 10123/200806
- 1 3 Visual in s pections of the underground piping exposed by the upper excavation between the CST and the Aux Feed Pump building revealed five area s where the co ating had degraded. Subsequent UT inspecti o n s indicated th a t the piping rem a ins at full thickne s s and therefore there has been no corrosion (o ther than min o r surface corrosi o n) of the piping as a result o f coating degradation in the s e five areas. Immediate Action
Description:
Discu ss ed the re s ults with the appropriate s takeholder
- s. Suggested Action
Description:
Complete exc a vation of the l o wer hole , perf o rm visuallUT inspection of the p i ping in the l o wer hole and repair any arae s where the c oa ting has degraded.
EQUIPMENT:
Tag Name Tag Suffix Name Component Code Process System Code TRENDING (For Reference Purposes Only): Trend Type REPORT WEIGHT HEPFACTOR EM INPO BINNING KEYWORDS KEYWORDS KEYWORDS KEYWORDS KEYWORDS # P E RIODIC REVIEW -INITIAL Trend Code 1 E ESPC ER3 PIPE COND KW-AGE MANAGEMENT KW-NDE KW -PIPE WALL KW-MARGIN REVIEW KW-CODES & STANDARDS 05127/09 NA as CR cl os ed this dat e Entergy I CORRECTIVE ACTION I CR-IP2-2008-047S4 CANumber:
Site I* Group Assigned By: 1P2 CRG/CARB/OSRC 1P2 Assigned To: 1P2 P&C Eng Codes Mgmt 1P2 Subassigned To : Originated By: Harrison , Christine B Performed By: Azevedo,Nelson F Subperformed By: Approved By: Closed By: Azevedo , Nelson F Name Harrison,Christine B Azevedo,Nelson F 101291200807
- 22:4 1 I 1118/2008 09:36:34 111181200809:36:34 Current Due Date: 11/1912008 CA Type: DISP -CA Initial Due Date: 1111912008 Plant Constraint:
- NONE CA
Description:
Please review and assign further corrective actions as required.
Response:
The three CST pipes (aux feed pump supply, CST return and CST overflow) were exposed at two location s for approximately 10' each. An inspection in the upper hole identified five areas which required coating repair and one area in the lower hole which required coating repair. In addition , there were several areas in the overflow pipe in the lower hole which required coating repair. These repairs have been completed and the upper hole has been backfilled.
The lower hole is ready for backfilling.
UT thickness measurements were also performed on those areas where the base metal was exposed and the se inspection s confirmed that the pipe thickne ss remains at nominal thickne ss (i.e. within the manufacturers tolerance).
All of these activities have been performed under WO 164495. CA 0002 has been issued to evaluate any future inspections and its associated technical basis. Subresponse
- Closure Comments: _____________ ... __ .. ___________________ . __ .. _________ . __________ " ___________
.. ___________
.. __ ., ________ . " __ *** _______
Entergy I CORRECTIVE ACTION I CR-IP2-2008-047S4 CANumber:
2 Site Group Assigned By: Assigned To: IP2 IP2 P&C Eng Codes Mgmt IP2 P&C Eng Codes Staff IP2 Subassigned To : Originated By: Azevedo , Nelson F Performed By: Azevedo,Nelson F Subperformed By: Approved By: Closed By: Azevedo , Nelson F Name Azevedo,Nelson F Lee,Robert C 1111412008 14: 39:29 12/111200812
- 1l:l5 1211112008 12: 11: 15 Current Due Date: 1211212008 CA Type: ACTION Initial Due Date: 12/1212008 Plant Constraint:
- NONE CA
Description:
Determine if additional future inspections are required for these pipes. Provide the technical basis for the decision.
Response:
==
Description:==
Determine if additional future inspection s are required for these pipes. Pr o vide the technical basis for the decision.
Response:
Completed assessments of these lines determined these lines to be of HIGH impact (2 lines are safety related), MEDIUM corrosion risk and HIGH inspection priority. The HIGH inspection pri o rity results from the safety function performed by Lines 1505 and 1509. The pipe material , so il re s istivity and s ite conditions factors result in these line s being of medium corrosion risk. The 3 inspected lines were: 12" Line 1505 -AFP suction line 8" Line 1509 -Condensate supply to the CST 10" Overflow line (no line number assigned, corrugated metal pipe) to manhole #5 These pipe s run underground in parallel with one another. As stated above, in accordance with the methodology provided by EN-DC-343 , for determining the inspection priority and re-in s pection interval, Lines 1505 and 1509 are o f High Priority. Accordingly , with the initial inspection of the se lines performed in O c tob e rlNovember 2008, re-inspection of of these line s is required within 8 years, or by September 20 16. The visual inspe c tion of these pipes at the l o wer excavation revealed that they were in generally good condi tio n, with the coa ting in t act a nd in acceptable cond ition. See the at tached as-found ins pe ct ion resul t s by the c oatings engineer, a nd po st coating repair inspection reports. A minor coating repair was re quire d at one location on 8" Line 1509, and the 10" overflow line req uired repa ir at the top port ion of the pipe at the crests of t he corrugations, possibl y indica t ive of coatin g da mage d uring the digging. B ase d on the re su lts of the se pipe visual in sp ectio n s (at the upp er and low e r ho les). and th e coat ing repa i rs performed, there was no evi denc e of any significan t pipe degradat ion tha t would warrant the re-inspection of these pipes at the same locations.
Future inspection of these lines will be performed at different location(s) along their length. The scheduling of the future inspections will be controlled under the IPEC Buried Pipe Program. CA #3 has been crea te d to track the s c hed uling of the future insp e c t ion of these lines , pend ing for ma l is s u e of the IPEC Buried P ip e Program documen t. Subresponse
- .. .. ... ---------.--------------_.----------
..
Entergy CORRECTIVE ACTION CR -IP2-2008-047 54 Closure Comments:
ttachments:
Resp Des cr ipti o n CST Lower Excava tion -As-Found Inspection Pa ge 1 of 1 Lee, Robert C
.. --.... -----From: Guarnaccia , S t ephen Sent: Wednesday, November 12 , 20084:34 PM LOWER £xc,fVA ,(I oA/ To: Lee, Robert C Cc: Arcate , John; Drake , R i chard S; Pineda , Juan J
Subject:
Unit 2 CST Piping Inspection Bob, I inspected the three eST pipes located in the excavation on the hill north of the Unit 2 ve. The large diameter pipe's coating, although rather inconsistent in spots, is acceptable.
The coating was found to have some reddish material attached to the lower left side that appeared to be corrosion byproducts.
I removed a few small samples of the material and checked them with a magnet. They were not ferrous in nature therefore not corrosion products.
The smaller diameter pipe's coating was more uniform in its appearance and in generally good condition.
There is one location on the upper top end that has a well defined crack in the coating running c i rcumferentially from the 11 o'clock to the 1 o'clock position.
The crack i s approximately four or five inches in length with a small amount of corrosion products emanating from it. This area must be repaired in accordance with the same requirements as the previous repairs. In my opinion, judging from the small amount of corrosion products and the good appearance of the coating the pipe does not need to be exposed for a more detailed inspection in order to determine the amount of mater i al lost. The corrugated pipe has a number of areas where the coating has been removed and they need to be repaired as previously instructed also. I recommend that you take a look at the pipes yourself to verify my findings in order to resolve the issue. I could not find your camera cable so I could not attach a picture at th i s time. Let's get together tomorrow morn i ng after the tailgate and v i ew the pictures.
Steve G. x6609 /2 I, /-JA/l-
& /, LII../e /5 0 9 IJ':? 0 tJ C*ON OffN5AT Ii '5/,A PP,-Y /0 CST CORRECTIVE ACTION CR -IP2* 2008-047 54 CA Number: 3 Site Group Assigned By: Assigned To: IP2 IP2 P&C Eng Codes Mgmt IP2 P&C Eng Codes Staff IP2 Subassigned To : Originated By: Azevedo ,Ne lson F Performed By: Lee,Robert C Subperformed By: Approved By: Closed By: Lee,Robert C Name Azevedo,Nelson F Lee , Robert C , 121111200812:10:46 2/191200922:54:55 2/1912009 22:54:55 Current Due Date: 02/2412009 CA Type: ACTION Initial Due Date: 0212412009 Plant Constraint:
- NONE CA
Description:
Track the sc heduling of the future inspection of these lines, pending formal issue of the IPEC Buried Pipe Program document.
Response:
In lieu of each of the Entergy sites issuing its own buried piping program document, it has been decided by the Buried Piping Peer Group that a fleet Central Engineering Program (CEP) Buried Piping Program Document will be generated, (Target date for issue is 4th QTR 2009). To manage and track all inspection ac tivities, each site will use Iddeal Scheduleworks (or equivalent) software.
The details and results of the impact , corrosion risk assessments, inspection prioritization and schedules will be captured and maintained by Iddeal Schedulew orks. For the buried condensate piping from the IP2 CST to the AFW Bldg that is the concern of this CA , as previously stated, these lines are categorized as being high priority for inspection. As such, the re-inspection will be performed 8 years from the intial inspection, or by end of 2 016. Capture of the IPEC buried pipe program activities, key program data and performance indicators into Iddeal is being tracked by LO-HQNLO-2008-00015 CA 65. Attached to this reponse is an EXCEL spreadsheet identifying the IP2 buried piping inspection schedule.
The subject piping and their f uture inspection dates have been highlighted.
This CA may be closed to the aforementioned HQNLO CA. Subresponse
- Closure Comments:
Attachments:
Res p Description IP2 Buried Piping Inspection Schedule I nitiaiinspect i o n Sctleciu 1e !e ll1 plate ... Plant: IP2 Date: 1112012008
- insp .schOO y ea r HIGH IMPACT PIPING 3 2008 Inso .oriorllv #-2flines Initialns d 2 2009 6 2010 5 2011 6 '*2012 3 2013 i :i 2016 '2 *'2017 'ii *20is-5 2019 5Y 12131/2013 8Y 12/30/2016 lOY 1213012018 r-I [., Ie. HIGH 22 MEDIUM 3 LOW o Total 25 t :'l 2020 3 2021 1;0 :!7d Novru;' 1 1 ..... ......... .... ...., ............ _ .. .
Prio<.ity (R E:[):by2013
- (YELLOW) -
1 ..... .... . .. ... .... . . .. . ....... _.... .. . 3)(Subsequent inspection sche<Juleissubject to revisjon, pending result s of init i al High Priority. (RED). -within 8 years ofinitialinspectitm
- Medium Prior ity (YELLOW)
- within 10 years of i ntial inspection. Start Finish Impact Corrosion Inspection Initial Inspection Initial Subsequent Section # Activity Name Inspect ion Interval Description System Inspection Inspection (inmal) (initial)
Assessment Risk P r iority (vears) (vears) (by 2013) (b y 2021) I 1iW'-2CWM-!
Pipe in s p ec tion 1/112010 12/3112010 HIGH MEDIUM HIGH 5 8 CW Supply Header* IS" City Water 2010 2018 "n_" a!>-2CWM"-2.
P i pe inspec tion 1/112010 1213112010 HIGH MEDIUM HIGH 5 8 cw to AFP Bldg* 8" Line 1502 City'Water 2010 2018 Pipe in s pect i on 111(2010 1213112010 HIGH MEDIUM HIGH 5 8 EOG FOST equalizing line F'uelOil 2010 2018 Pipe i n sp ection 111120 10 121311201 0 HIGH MEDIUM HIGH 5 8 EDG FOST
- 4" lank fill Fuel ell 2010 2018 Service tlP-2SW-l Pipe in spection 111120 1 1 1213112011 HIGH MEDIUM HIGH 5 8 Maio SW Header -24" Line 40 8 Wate-r 2011 2019 Main SW Header -24" Une 4d£t"
'*geMce fjP-2SW-2 Pipe inspection 1/1 1 2 011 1 21 31/2011 HIGH MEDIUM HIGH 5 8 Water 2011 2019 ,,.. IIp-2SW-3 Pipe inspection 1/112012 1213112012 HIGH MEDIUM HIGH 5 8 sw Branch to lAce HXs-3" Lin e 1704 Service 2012 2020 Water H-Service 13P-2SW-4 Pipe insp e ction 1/1/2012 12131/2012 HIGH MEDIUM HIGH 5 8 SW 8fanctl to lAce HXs-3" Lin e 1 7 0 5 W ater 2012 2020 BP-2SW-5 Pipe inspection 111/2011 1213112011 HIGH MEDIUM HIGH 5 8 I
- 24" u-405. Serv i ce -"" -2ll1.9 ; lev Pipe Inspection 10/2008 A 11/2008 A HIGH M EDIUM HIGH 5 8 CST 10 AFWP Suction. 1 2" Un. 1505 Aux 4th Q1r 2008
- 2016 \+ Feedwaler COMP L ETE . BP-2AFW-2 Pipe inspection 1012008 A 11/2008 A HIGH M EDIUM HIGH 5 8 (; CS T I n l et* 8" U ne 150 9 Aux 4th Q1r 2008* 2016 Feedwater COMPLETE BP-2AFW-3 r----CST . . _ Aux -Pipe inspection 11112013 1213112013 HIGH MEDIUM HIGH 5 8 __ . !-._ 202 1 -F eed.WOU8f.-
, q. ( .. Aux 4th atr 2006 * (lP-2AFW-4 Pipe inspection 10!2008A 1f12OO8A.
HIGH MEDIUM HIGH 5 8 CST Overflow* 10" I C.M.P.) Feedwalll!
_ ._COMf'kE-T-li
... 2016 Pipe Inspeclion 1/112009 1213112009 HIGH MEDIUM HIGH 5 8 r---CWP dlsch to Condenser
-Circulating 2009 2017 Water Pipe ins p ection 1/1 1 2 009 121 3 1 12009 H I GH MEDIUM HIGH 5 8 CWP discl1 to Condenser
- C irculat!ng 2009 2017 Water Impact Corrosion Inspection Initial Inspection Initial Subsequent I Nam e inspection Interval Description System I n spection Inspection Assessment Risk Priority (years) (years) (by 2013) (by 2021) 1 , Pipe inspection 1 1 112010 121:5112010 HIGH MEDIUM HIGH 5 8 CWP disch to Condenser 84" Clrcutating 2010 2018 Water
- Pip e inspection t 1 21 3112010 HIGH MEDIUM HIGH 5 8 CWP disch to Condenser* 84" CirCtJlating 2010 2018 Water Pipe inspection 11112011 1213112011 HIGH MEDIUM HIGH 5 8 CWP disch to Condenser
-84" Ci r culating 2011 2019 Water Pipe inspection 111 1 201 1213112011 HIGH MEDIUM HIGH 5 8 CWP disch to Condenser Circulating 2011 2019 i Water Pi p e in spe ctioo 11112012 1213112012 HIGH LOW MEDIUM 8 10 lA Line to Intake Struct *1X:'" Instrument 2012 2022 Air Pipe in s pect i on 111120 1 2 1213112012 HI GH LOW MEDIUM 8 10 I A Supply to AFP Bldg* 2" Instrument 2012 2022 . Ai( I Pi pe i nspec tion 11112012 1 213i12012 H I GH LOW MEDIUM 8 10 IA Supply to VC
- 2" Instrument 2012 2022 Air Pipe i n s p e ction 1: 11 H I GH MEDIUM HIGH 5 8 piping to penet lW' Cont. Penet 2013 2021 Press. Pipe in spect ion 12 12 1 31120 1 2 HIGH MEDIUM HIGH 5 8 RWST Overllow to WHT Pit 6" Uno 299 Waste 20 1 2 2020 Disposal Pipe i nspection 11112013 12/3112013 HIGH MEDIUM HIGH 5 8 PWST O v erflow to Une 299
- 3" Waste 2013 2021 , --, Disposal Entergy CORRECTIVE ACTION CR-IP2-2008-047 54 CA Number: 4 Site Group Name Assigned By: Assigned To: IP2 IP2 CAA Staff IP2 P&C Eng Codes Mgmt IP2 Reynolds , Joseph A Azevedo,Nelson F Subassigned To : Originated By: lowitt,Roseann Performed By: Azevedo , Nelson F Subperformed By: Approved By: Closed By: Reynolds , Joseph A Current Due Date: 03/04/2009 CA Type: CR CLOSURE REVIEW Plant Constraint:
- NONE CA
Description:
21201200906:35
- 34 21271200906
- 56:02 21271200907:45:26 Initial Due Date: 03/0412009 CAT -C , ALL CORRECTIVE ACTIONS ARE CLOSED FOR THIS CR, THEREFORE THIS CR MAYBE READY TO CLOSE. REVIEW CR AND APPROVE 1 DISAPPROVE CLOSURE IN ACCORDANCE WITH EN-LI-l 02, SECTION 5.9. Response:
This CR is not ready for closure. CA 005 has been issued for follow up evaluations.
Subresponse
- Closure Comments:
Per CAA review, noted the CR owner did NOT approve the closure of the CR, and assigned additional action. Therefore this CR removed from the closure process and this completed action closed.
Entergy CORRECTIVE ACTION CR -IP2-2008-047 54 CA Number: 5 Site Group Name Assigned By: Assigned To: IP2 IP2 P&C Eng Codes Mgmt IP 2 P&C Eng Codes Staff IP2 Azevedo,Nelson F Lee , Robert C Subassigned To: Originated By: Azevedo,Nelson F Performed By: Azevedo,Nelson F Subperformed By: Approved By: Closed By: Azevedo,Nelson F Current Due Date: 05/3112009 CA Type: ACTION Plant Constraint:
- NONE CA
Description:
212712009 06:55 :05 5127/200909:
17:22 5/2712009 09: 17:22 Initial Due Date: 05/3112009 Given the results of the leak in the AFP build i ng , determine if the scope and/or frequency of future buried condensate lines s hould be modified.
This should cover both IP2 and IP3. Response:
The initial Impact and Corrsoi o n Risk s assessments for the AFW underground piping were performed iaw fleet procedure EN-DC-343 "Buried Piping & Tank Inspection and Monitorin g Program." Those assessment resulted in the categorization of Lines 1505 and 1509 as high inspection priority lines, with first in sp ection performed within 5 years (by EOY 2012), and subsequent re-inspection within 8 years thereafter (EOY 2020). Responding to the ISE Panel recommendation to adopt a more agressive inspection schedule, and s pecifically to complete excavation and inspections by EOY 2008, the IP2 AFW lines 1505, 1509 and overflow line were excavated and inspected at 2 location s in Nov 2008. While there was some pipe coating degradation observed, there was no evidence of external corrosion.
UT determination of the pipe wall thickness at the areas of degraded coating degradation s howed that the pipe wall was at least greater than 87.5% of the nominal pipe wall. These findings were consistent with the assessments which es t a b lishe d the inspection priority for these lines. The Failure analysis of the section of removed pipe from Line 1509 containing the through wall failure, and extent of condition review are documented under CR-IP2-2009-00666 CA # 4. As part of extent of condition, additional g uided wave inspection of Lines 1505 and 1509 will be performed by September 2009, as follows: IP2 8" (Line 1509) Condensate Return Line in the excavated area in the FRY Room. (C R-IP2-2009-00666 CA #21) IP2 12" (Line 1505) Condensate Supply Line in the excavated area in the FRY Room. (CR-IP2-2009-00666 CA #22 ) IP3 12" Condensat e Supply Line outside the Auxiliary Feedwater Pump Building where it goes underground. (CR-IP2-2009-0 06 6 6 CA #24) IP3 8" Conden sat e Re turn Line outside the Auxil iary Feedw ater Pump Building w h e re it exits the ground. (CR-IP2-2009
-0 0666 C A #25) The results of the above additional inspections will b e evaluated by PCE and u s ed t o adjust the (EN-DC-343 specified) 8 year interval for subsequent inspections, as appropriate.
bresponse:
Entergy 1 CORRECTIVE ACTION I CR-IP2-2008-047S4 Closure Comments:
En CORRECTIVE ACTION CR-IP2-2008-047S4 CANumber:
6 Site Group Name Assigned By: IP2 IP2 CAA Mgmt IP2 Donnelly,John M Azevedo,Nelson F Assigned To: P&C Eng Codes Mgmt IP2 Subassigned To: Originated By: Reynolds,Joseph A Performed By: Azevedo , Nelson F Subperformed By: Approved By: Closed By: Reynolds,Joseph A Current Due Date: 06/04/2009 CA Type: CR CLOSURE REVIEW Plant Constraint:
- NONE CA
Description:
Periodic Review CA 5/1412009 1O:55:07 5127/2009 09: 19: 17 51271200909:33:54 Initial Due Date: 06/0412009 Please note , this CAT C CR has been open approximately greater than 6 months and therefore requires a periodic review per attachment 9.8 of EN-U-l02. Ensure attachment 9.8 (attached) is completed.
Review and complete the Long Term 9.9 form if appropriate. Both forms are required if the CR is classified as a Long Term CR. In accordance with EN-U-I 02, Corrective Action Process, section 5.8 [5] (a) and/or (b) a periodic review of the CR is needed to assure the timeliness challenges for the issue resolution are understood, the impact to plant operations under the present plant conditions as well as the continued risk imposed by the action remaining open are acceptable , the repair priority is appropriate and the administrative CA processing expectations have been performed as expected thus far for the CR (i.e. CARB approvals, Extensions approved by correct level of management , etc). As the CR owner, please review the Condition Report lAW EN-U-l 02 section 5.8 [5] (a) (I) through (7) and document the resolution to the procedure discussion points. Attachment 9.8 to U-102 (a form) is available from the CA&A webpage to assist in the review. IF your review determines the CR should also be reclassified as a Long Term CR, ensure the information requested in attachment 9.9 to U-102 (another form available via the CA&A webpage) is captured in the CA response.
Reclassifying the CR as long term (if appropriate) lengthens the periodic review to annually.
For all cases, U-102 requires the Director or GMPO level position (or higher) that approved/acknowledged the acceptability of the periodic review conclusions to be documented.
Document the results of the periodic rev i ew in the response t o this new CA. If used, atta c h the completed CR periodic review form (U-102 -att achmen t 9.8) to t h e response se ction o f th i s CA. Remember the Long Term classification only applies if the restr icti on to completing the task involves one of th e following fo ur pla nUproces s re strictions.
(1) A Modificati on or Design Ch ange must be co mp leted to res olve the actio n, (2) More than on e t rain ing cycl e is re quired to compl ete the ac tion, (3) Outs ide Re gulator Age ncy (NRC, etc) app roval is req uire d to com plet e the actio n , (4) a Forced Outage or Refueling Outage or FEG week of sufficient duratio n is required to establish plant conditions to complete the action. Response:
All CA s from th is CR are now clo se d and no add i ti onal correct i ve a ctio ns are re qu i r ed at this ti me. The refor e, this ev a lu a tion is no lo nger req uired s ince this C R i s no w ready fo r closu re.
I I Entergy CORRECTIVE ACTION CR -IP2-2008-047 54 Closure Comments:
Per CAA review, noted the CR owner recommended and approved the closure of the CR (this was verified via verbal communication with respondent by the CAA reviewer).
Therefore this interim review action is no longer needed and was closed. CAA changed the CA type to closure review and updated the trend codes to reflect the status of the review. Then this completed action closed. Attachments:
Ca Description Periodic review form