ML060950579
| ML060950579 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee  |
| 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 | |
| ML060950189 | List:
|
| References | |
| %dam200611, TAC MC9668 | |
| Download: ML060950579 (8) | |
Text
AUDIT WORKSHEET GALL REPORT AMP PLANT: ______________________________
LRA AMP: __________________________ REVIEWER: ______________________
GALL AMP: XI.M24, Compressed Air Monitoring DATE: __________________________
Program Auditable GALL Criteria Documentation of Audit Finding Element Program A. The program consists of inspection, monitoring, and testing Consistent with GALL AMP: Yes No Description of the entire system. This includes (a) frequent leak testing of Document(s) used to confirm Criteria:
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 Comment:
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.
B. The AMP is based on results of the plant owners response to Consistent with GALL AMP: Yes No Nuclear Regulatory Commission (NRC) Generic Letter (GL) 88- Document(s) used to confirm Criteria:
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 Comment:
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 XI.M24 Compressed Air Monitoring 1
Program Auditable GALL Criteria Documentation of Audit Finding Element 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 A. The program manages the effects of corrosion and the Consistent with GALL AMP: Yes No Program presence of unacceptable levels of contaminants on the Document(s) used to confirm Criteria:
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 Comment:
air quality at several locations in the system.
- 2. Preventive A. The system air quality is monitored and maintained in Consistent with GALL AMP: Yes No Actions accordance with the plant owners testing and inspection plans, Document(s) used to confirm Criteria:
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 Comment:
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.
XI.M24 Compressed Air Monitoring 2
Program Auditable GALL Criteria Documentation of Audit Finding Element
- 3. Parameters A. Inservice inspection (ISI) and testing is performed to verify Consistent with GALL AMP: Yes No Monitored/ proper air quality and confirm that maintenance practices, Document(s) used to confirm Criteria:
Inspected emergency procedures, and training are adequate to ensure that the intended function of the air system is maintained.
Comment:
- 4. Detection of A. Guidelines in EPRI NP-7079, EPRI TR-108147, and ASME Consistent with GALL AMP: Yes No Aging Effects OM-S/G-1998, Part 17, ensure timely detection of degradation Document(s) used to confirm Criteria:
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 Comment:
item of components to meet specified performance limits.
- 5. Monitoring A. Effects of corrosion and the presence of contaminants are Consistent with GALL AMP: Yes No and Trending monitored by visual inspection and periodic system and Document(s) used to confirm Criteria:
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 Comment:
compared to data from previous tests to provide for timely detection of aging effects.
- 6. Acceptance A. Acceptance criteria are established for the system and for Consistent with GALL AMP: Yes No Criteria individual components that contain specific limits or acceptance Document(s) used to confirm Criteria:
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. Comment:
- 7. Corrective A. Corrective actions are taken if any parameters are out of Consistent with GALL AMP: Yes No Actions acceptable ranges, such as moisture content in the system air. Document(s) used to confirm Criteria:
As discussed in the appendix to this report, the staff finds the XI.M24 Compressed Air Monitoring 3
Program Auditable GALL Criteria Documentation of Audit Finding Element requirements of 10 CFR Part 50, Appendix B, acceptable to address the corrective actions.
Comment:
- 8. A. The site corrective actions program, quality assurance (QA) Consistent with GALL AMP: Yes No Confirmation procedures, site review and approval process, and Document(s) used to confirm Criteria:
Process 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 Comment:
confirmation process and administrative controls.
- 9. A. See Item 8, above. Consistent with GALL AMP: Yes No Administrative Document(s) used to confirm Criteria:
Controls Comment:
- 10. Operating A. Potentially significant safety-related problems pertaining to air Consistent with GALL AMP: Yes No Experience systems have been documented in NRC IN 81-38, IN 87-28, Document(s) used to confirm Criteria:
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, Comment:
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.
XI.M24 Compressed Air Monitoring 4
EXCEPTIONS Item Program Elements LRA Exception Description Basis for Accepting Exception Documents Reviewed Number (Identifier, Para.# and/or Page #)
1.
2.
ENHANCEMENTS Item Program Elements LRA Enhancement Description Basis for Accepting Enhancement Documents Reviewed Number (Identifier, Para.# and/or Page #)
1.
2.
DOCUMENT REVIEWED DURING AUDIT Document Number Identifier (number) Title Revision and/or Date 1.
2.
3.
4.
XI.M24 Compressed Air Monitoring 5