ML060950582
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AUDIT WORKSHEET GALL REPORT AMP PLANT: ______________________________
LRA AMP: __________________________ REVIEWER: ______________________
GALL AMP: XI.M25, BWR Reactor Water Cleanup System DATE: __________________________
Program Auditable GALL Criteria Documentation of Audit Finding Element Program A. The program includes inservice inspection (ISI) and Consistent with GALL AMP: Yes No Description monitoring and control of reactor coolant water chemistry to Document(s) used to confirm Criteria:
manage the effects of stress corrosion cracking (SCC) or intergranular stress corrosion cracking (IGSCC) on the intended function of austenitic stainless steel (SS) piping in the reactor water cleanup (RWCU) system. Based on the Nuclear Comment:
Regulatory Commission (NRC) criteria related to inspection guidelines for RWCU piping welds outboard of the second isolation valve, the program includes the measures delineated in NUREG-0313, Rev. 2, and NRC Generic Letter (GL) 88-01.
Coolant water chemistry is monitored and maintained in accordance with the Electric Power Research Institute (EPRI) guidelines in boiling water reactor vessel and internals project (BWRVIP) -29 (TR-103515) to minimize the potential of cracking due to SCC or IGSCC.
- 1. Scope of A. Based on the NRC letter (September 15, 1995) on the Consistent with GALL AMP: Yes No Program screening criteria related to inspection guidelines for RWCU Document(s) used to confirm Criteria:
piping welds outboard of the second isolation valve, the program includes the measures delineated in NUREG-0313, Rev. 2, and NRC GL 88-01 to monitor SCC or IGSCC and its effects on the intended function of austenitic SS piping. The Comment:
screening criteria include:
- a. Satisfactory completion of all actions requested in NRC GL 89-10, XI.M25 BWR Reactor Water Cleanup System 1
Program Auditable GALL Criteria Documentation of Audit Finding Element
- b. No detection of IGSCC in RWCU welds inboard of the second isolation valves (ongoing inspection in accordance with the guidance in NRC GL 88-01), and
- c. No detection of IGSCC in RWCU welds outboard of the second isolation valves after inspecting a minimum of 10% of the susceptible piping.
No IGSCC inspection is recommended for plants that meet all the above three criteria or that meet criterion (a) and piping is made of material that is resistant to IGSCC.
- 2. Preventive A. The comprehensive program outlined in NUREG-0313 and Consistent with GALL AMP: Yes No Actions NRC GL 88-01 addresses improvements in all three elements Document(s) used to confirm Criteria:
that, in combination, cause SCC or IGSCC. These elements are a susceptible (sensitized) material, a significant tensile stress, and an aggressive environment. The program delineated in NUREG-0313 and NRC GL 88-01 includes recommendations Comment:
regarding selection of materials that are resistant to sensitization, use of special processes that reduce residual tensile stresses, and monitoring and maintenance of coolant chemistry. The resistant materials are used for new and replacement components and include low-carbon grades of austenitic SS and weld metal, with a maximum carbon of 0.035 wt.% and a minimum ferrite of 7.5% in weld metal and cast austenitic stainless steel (CASS). Inconel 82 is the only commonly used nickel-base weld metal considered resistant to SCC; other nickel-alloys, such as Alloy 600, are evaluated on an individual basis.
B. Special processes are used for existing as well as new and Consistent with GALL AMP: Yes No replacement components. These processes include solution Document(s) used to confirm Criteria:
heat treatment, heat sink welding, induction heating, and mechanical stress improvement.
Comment:
C. The program delineated in NUREG-0313 and NRC GL 88-01 Consistent with GALL AMP: Yes No varies depending on the plant- specific reactor water chemistry Document(s) used to confirm Criteria:
XI.M25 BWR Reactor Water Cleanup System 2
Program Auditable GALL Criteria Documentation of Audit Finding Element to mitigate SCC or IGSCC.
Comment:
- 3. Parameters A. The aging management program (AMP) monitors SCC or Consistent with GALL AMP: Yes No Monitored/ IGSCC of austenitic SS piping by detection and sizing of cracks Document(s) used to confirm Criteria:
Inspected by implementing the inspection guidelines delineated in the NRC screening criteria for the RWCU piping outboard of isolation valves. The following schedules are followed:
Schedule A: No inspection is required for plants that meet all Comment:
three criteria set forth above, or if they meet only criterion (a).
Piping is made of material that is resistant to IGSCC, as described above in preventive actions.
Schedule B: For plants that meet only criterion (a): Inspect at least 2% of the welds or two welds every refueling outage, whichever sample is larger.
Schedule C: For plants that do not meet criterion (a): Inspect at least 10% of the welds every refueling outage.
- 4. Detection of A. The extent, method, and schedule of the inspection and test Consistent with GALL AMP: Yes No Aging Effects techniques delineated in the NRC inspection criteria for RWCU Document(s) used to confirm Criteria:
piping and NRC GL 88-01 are designed to maintain structural integrity and to detect aging effects before the loss of intended function of austenitic SS piping and fittings. Guidelines for the inspection schedule, methods, personnel, sample expansion, Comment:
and leak detection guidelines are based on the guidelines of NRC GL 88-01.
NRC GL 88-01 recommends that the detailed inspection procedure, components, and examination personnel be qualified by a formal program approved by the NRC. Inspection can reveal cracking and leakage of coolant. The extent and frequency of inspections recommended by the program are based on the condition of each weld (e.g., whether the weldments were made from IGSCC-resistant material, whether a stress improvement process was applied to a weldment to XI.M25 BWR Reactor Water Cleanup System 3
Program Auditable GALL Criteria Documentation of Audit Finding Element reduce the residual stresses, and how the weld was repaired if it had been cracked).
- 5. Monitoring A. The extent and schedule for inspection in accordance with Consistent with GALL AMP: Yes No and Trending the recommendations of NRC GL 88-01 provide timely detection Document(s) used to confirm Criteria:
of cracks and leakage of coolant. Based on inspection results, NRC GL 88-01 provides guidelines for additional samples of welds to be inspected when one or more cracked welds are found in a weld category. Comment:
- 6. Acceptance A. The NRC GL 88-01 recommends that any indication detected Consistent with GALL AMP: Yes No Criteria be evaluated in accordance with the requirements of ASME Document(s) used to confirm Criteria:
Section XI, Subsection IWB-3640 (2001 edition including the 2002 and 2003 Addenda).
Comment:
- 7. Corrective A. The guidance for weld overlay repair, stress improvement, or Consistent with GALL AMP: Yes No Actions replacement is provided in NRC GL 88-01. As discussed in the Document(s) used to confirm Criteria:
appendix to this report, the staff finds the requirements of 10 CFR Part 50, Appendix B, acceptable to address the corrective actions.
Comment:
- 8. A. Site quality assurance (QA) procedures, review and approval Consistent with GALL AMP: Yes No Confirmation processes, and administrative controls are implemented in Document(s) used to confirm Criteria:
Process accordance with 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. Comment:
- 9. A. See Item 8, above. Consistent with GALL AMP: Yes No Administrative Document(s) used to confirm Criteria:
Controls Comment:
- 10. Operating A. The IGSCC has occurred in small- and large-diameter boiling Consistent with GALL AMP: Yes No XI.M25 BWR Reactor Water Cleanup System 4
Program Auditable GALL Criteria Documentation of Audit Finding Element Experience water reactor (BWR) piping made of austenitic stainless steels Document(s) used to confirm Criteria:
or nickel alloys. The comprehensive program outlined in NRC GL 88-01 and NUREG-0313 addresses improvements in all elements that cause SCC or IGSCC (e.g., susceptible material, significant tensile stress, and an aggressive environment) and is Comment:
effective in managing IGSCC in austenitic SS piping in the RWCU system.
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EXCEPTIONS Item Program Elements LRA Exception Description Basis for Accepting Exception Documents Reviewed Number (Identifier, Para.# and/or Page #)
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ENHANCEMENTS Item Program Elements LRA Enhancement Description Basis for Accepting Enhancement Documents Reviewed Number (Identifier, Para.# and/or Page #)
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DOCUMENT REVIEWED DURING AUDIT Document Number Identifier (number) Title Revision and/or Date 1.
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