ML060950567

GALL AMP: XI.M21, Closed-Cycle Cooling Water System (Audit Worksheet GALL Report AMP)

ML060950567
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	03/22/2006
From:	Morgan M NRC/NRR/ADRO/DLR/RLRC
To:	Office of Nuclear Reactor Regulation
morgan M NRR/NRC/DLR/RLRC, 415-2232
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References
%dam200611, TAC MC9668
Download: ML060950567 (6)

Text

XI.M21 Closed-Cycle Cooling Water System 1

AUDIT WORKSHEET GALL REPORT AMP PLANT: ______________________________

LRA AMP: __________________________

REVIEWER: ______________________

GALL AMP: XI.M21, Closed-Cycle Cooling Water System DATE: __________________________

Program Element Auditable GALL Criteria Documentation of Audit Finding Program Description A. The program includes (a) preventive measures to minimize corrosion and stress corrosion cracking (SCC) and (b) testing and inspection to monitor the effects of corrosion and SCC on the intended function of the component. The program relies on maintenance of system corrosion inhibitor concentrations within the specified limits of Electric Power Research Institute (EPRI)

TR-107396 to minimize corrosion and SCC. Non-chemistry monitoring techniques such as testing and inspection in accordance with guidance in EPRI TR-107396 for closed-cycle cooling water (CCCW) systems provide one acceptable method to evaluate system and component performance. These measures will ensure that the intended functions of the CCCW system and components serviced by the CCCW system are not compromised by aging.

Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment:

1. Scope of Program A. A CCCW system is defined as part of the service water system that is not subject to significant sources of contamination, in which water chemistry is controlled and in which heat is not directly rejected to a heat sink. The program described in this section applies only to such a system. If one or more of these conditions are not satisfied, the system is to be considered an open-cycle cooling water system. The staff notes that if the adequacy of cooling water chemistry control cannot be confirmed, the system is treated as an open-cycle system as indicated in Action III of Generic Letter (GL) 89-13.

Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment:

XI.M21 Closed-Cycle Cooling Water System 2

Program Element Auditable GALL Criteria Documentation of Audit Finding

2. Preventive Actions A. The program relies on the use of appropriate materials, lining, or coating to protect the underlying metal surfaces and maintain system corrosion inhibitor concentrations within the specified limits of EPRI TR-107396 to minimize corrosion and SCC. The program includes monitoring and control of cooling water chemistry to minimize exposure to aggressive environments and application of corrosion inhibitor in the CCCW system to mitigate general, crevice, and pitting corrosion as well as SCC.

Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment:

3. Parameters Monitored/

Inspected A. The aging management program monitors the effects of corrosion and SCC by testing and inspection in accordance with guidance in EPRI TR-107396 to evaluate system and component condition. For pumps, the parameters monitored include flow, discharge pressures, and suction pressures.

Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment:

B. For heat exchangers, the parameters monitored include flow, inlet and outlet temperatures, and differential pressure.

Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment:

4. Detection of Aging Effects A. Control of water chemistry does not preclude corrosion or SCC at locations of stagnant flow conditions or crevices.

Degradation of a component due to corrosion or SCC would result in degradation of system or component performance. The extent and schedule of inspections and testing should assure detection of corrosion or SCC before the loss of the intended function of the component. Performance and functional testing ensures acceptable functioning of the CCCW system or components serviced by the CCCW system. For systems and components in continuous operation, performance adequacy should be verified by monitoring component performance through data trends for evaluation of heat transfer capability, system branch flow changes and chemistry data trends.

Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment:

XI.M21 Closed-Cycle Cooling Water System 3

Program Element Auditable GALL Criteria Documentation of Audit Finding Components not normally in operation are periodically tested to ensure operability.

5. Monitoring and Trending A. The frequency of sampling water chemistry varies and can occur on a continuous, daily, weekly, or as needed basis, as indicated by plant operating conditions and the type of chemical treatment. In accordance with EPRI TR-107396, internal visual inspections and performance/functional tests are to be performed periodically to demonstrate system operability and confirm the effectiveness of the program.

Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment:

B. Tests to evaluate heat removal capability of the system and degradation of system components may also be used. The testing intervals should be established based on plant-specific considerations such as system conditions, trending, and past operating experience, and may be adjusted based on the results of a reliability analysis, type of service, frequency of operation, or age of components and systems.

Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment:

6. Acceptance Criteria A. Corrosion inhibitor concentrations are maintained within the limits specified in the EPRI water chemistry guidelines for CCCW. System and component performance test results are evaluated in accordance with system and component design basis requirements. Acceptance criteria and tolerances are to be based on system design parameters and functions.

Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment:

7. Corrective Actions A. Corrosion inhibitor concentrations outside the allowable limits are returned to the acceptable range within the time period specified in the EPRI water chemistry guidelines for CCCW. If the system or component fails to perform adequately, corrective actions are taken. As discussed in the appendix to this report, the staff finds the requirements of 10 CFR Part 50, Appendix B, acceptable to address the corrective actions.

Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment:

8.

Confirmation Process A. Site quality assurance (QA) procedures, review and approval processes, and administrative controls are implemented in accordance with the requirements of 10 CFR Part 50, Appendix B. As discussed in the appendix to this report, the staff finds the Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

XI.M21 Closed-Cycle Cooling Water System 4

Program Element Auditable GALL Criteria Documentation of Audit Finding requirements of 10 CFR Part 50, Appendix B, acceptable to address the confirmation process and administrative controls.

Comment:

9.

Administrative Controls A. See Item 8, above.

Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment:

10. Operating Experience A. Degradation of closed-cycle cooling water systems due to corrosion product buildup (NRC Licensee Event Report [LER]

50-327/93-029-00) or through-wall cracks in supply lines (NRC 50-280/91-019-00) has been observed in operating plants.

Accordingly, operating experience demonstrates the need for this program.

Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment:

XI.M21 Closed-Cycle Cooling Water System 5

EXCEPTIONS Item Number Program Elements LRA Exception Description Basis for Accepting Exception Documents Reviewed (Identifier, Para.# and/or Page #)

1.

2.

ENHANCEMENTS Item Number Program Elements LRA Enhancement Description Basis for Accepting Enhancement Documents Reviewed (Identifier, Para.# and/or Page #)

1.

2.

DOCUMENT REVIEWED DURING AUDIT Document Number Identifier (number)

Title Revision and/or Date

1.

2.

3.

4.

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