ML060950579

GALL AMP: XI.M24, Compressed Air Monitoring (Audit Worksheet GALL Report AMP)

ML060950579
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
Shared Package
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References
%dam200611, TAC MC9668
Download: ML060950579 (8)

Text

XI.M24 Compressed Air Monitoring 1

AUDIT WORKSHEET GALL REPORT AMP PLANT: ______________________________

LRA AMP: __________________________

REVIEWER: ______________________

GALL AMP: XI.M24, Compressed Air Monitoring DATE: __________________________

Program Element Auditable GALL Criteria Documentation of Audit Finding Program Description A. The program consists of inspection, monitoring, and testing of the entire system. This includes (a) frequent leak testing of valves, piping, and other system components, especially those made of carbon steel and stainless steel; and (b) preventive monitoring that checks air quality at various locations in the system to ensure that oil, water, rust, dirt, and other contaminants are kept within the specified limits. The aging management program (AMP) provides for timely corrective actions to ensure that the system is operating within specified limits.

Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment:

B. The AMP is based on results of the plant owners response to Nuclear Regulatory Commission (NRC) Generic Letter (GL) 88-14, augmented by previous NRC Information Notices (IN) 81-38, IN 87-28, and IN 87-28 S1, and by the Institute of Nuclear Power Operations Significant Operating Experience Report (INPO SOER) 88-01. The NRC GL 88-14, issued after several years of study of problems and failures of instrument air systems, recommends each holder of an operating license to perform an extensive design and operations review and verification of its instrument air system. The GL 88-14 also recommends the licensees to describe their program for maintaining proper instrument air quality. The AMP also incorporates provisions conforming to the guidance of the Electric Power Research Institute (EPRI) NP-7079, issued in Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment:

XI.M24 Compressed Air Monitoring 2

Program Element Auditable GALL Criteria Documentation of Audit Finding 1990, to assist utilities in identifying and correcting system problems in the instrument air system and to enable them to maintain required industry safety standards. Subsequent to these initial actions by all plant licensees to implement an improved AMP, some utilities decided to replace their instrument air system with newer models and types of components. The EPRI then issued TR-108147, which addresses maintenance of the latest compressors and other instrument air system components currently in use at those plants. The American Society of Mechanical Engineers operations and maintenance standards and guides (ASME OM-S/G-1998, Part 17) provides additional guidance to the maintenance of the instrument air system by offering recommended test methods, test intervals, parameters to be measured and evaluated, acceptance criteria, corrective actions, and records requirements.

1. Scope of Program A. The program manages the effects of corrosion and the presence of unacceptable levels of contaminants on the intended function of the compressed air system. The AMP includes frequent leak testing of valves, piping, and other system components, especially those made of carbon steel and stainless steel, and a preventive maintenance program to check air quality at several locations in the system.

Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment:

2. Preventive Actions A. The system air quality is monitored and maintained in accordance with the plant owners testing and inspection plans, which are designed to ensure that the system and components meet specified operability requirements. These requirements are prepared from consideration of manufacturer's recommendations for individual components and guidelines based on ASME OM-S/G-1998, Part 17; ISA-S7.0.01-1996; EPRI NP-7079; and EPRI TR-108147. The preventive maintenance program addresses various aspects of the inoperability of air-operated components due to corrosion and the presence of oil, water, rust, and other contaminants.

Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment:

XI.M24 Compressed Air Monitoring 3

Program Element Auditable GALL Criteria Documentation of Audit Finding

3. Parameters Monitored/

Inspected A. Inservice inspection (ISI) and testing is performed to verify proper air quality and confirm that maintenance practices, emergency procedures, and training are adequate to ensure that the intended function of the air system is maintained.

Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment:

4. Detection of Aging Effects A. Guidelines in EPRI NP-7079, EPRI TR-108147, and ASME OM-S/G-1998, Part 17, ensure timely detection of degradation of the compressed air system function. Degradation of the piping and any components would become evident by observation of excessive corrosion, by the discovery of unacceptable leakage rates, and by failure of the system or any item of components to meet specified performance limits.

Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment:

5. Monitoring and Trending A. Effects of corrosion and the presence of contaminants are monitored by visual inspection and periodic system and component tests, including leak rate tests on the system and on individual items of components. These tests verify proper operation by comparing measured values of performance with specified performance limits. Test data are analyzed and compared to data from previous tests to provide for timely detection of aging effects.

Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment:

6. Acceptance Criteria A. Acceptance criteria are established for the system and for individual components that contain specific limits or acceptance ranges based on design basis conditions and/or components vendor specifications. The testing results are analyzed to verify that the design and performance of the system is in accordance with its intended function.

Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment:

7. Corrective Actions A. Corrective actions are taken if any parameters are out of acceptable ranges, such as moisture content in the system air.

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.M24 Compressed Air Monitoring 4

Program Element Auditable GALL Criteria Documentation of Audit Finding requirements of 10 CFR Part 50, Appendix B, acceptable to address the corrective actions.

Comment:

8.

Confirmation Process A. The site corrective actions program, quality assurance (QA) procedures, site review and approval process, 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 requirements of 10 CFR Part 50, Appendix B, acceptable to address the confirmation process and administrative controls.

Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

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. Potentially significant safety-related problems pertaining to air systems have been documented in NRC IN 81-38, IN 87-28, IN 87-28 S1 and license event report (LER) 50-237/94-005-3.

Some of the systems that have been significantly degraded or have failed due to the problems in the air system include the decay heat removal, auxiliary feedwater, main steam isolation, containment isolation, and fuel pool seal system. As a result of NRC GL 88-14 and consideration of INPO SOER 88-01, EPRI NP-7079, and EPRI TR-108147, performance of air systems has improved significantly.

Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment:

XI.M24 Compressed Air Monitoring 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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