ML060950596
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AUDIT WORKSHEET GALL REPORT AMP PLANT: ______________________________
LRA AMP: __________________________ REVIEWER: ______________________
GALL AMP: XI.M27, Fire Water System DATE: __________________________
Program Auditable GALL Criteria Documentation of Audit Finding Element Program A. This aging management program (AMP) applies to water- Consistent with GALL AMP: Yes No Description based fire protection systems that consist of sprinklers, nozzles, Document(s) used to confirm Criteria:
fittings, valves, hydrants, hose stations, standpipes, water storage tanks, and aboveground and underground piping and components that are tested in accordance with the applicable National Fire Protection Association (NFPA) codes and Comment:
standards. Such testing assures the minimum functionality of the systems. Also, these systems are normally maintained at required operating pressure and monitored such that loss of system pressure is immediately detected and corrective actions initiated.
B. A sample of sprinkler heads is to be inspected by using the Consistent with GALL AMP: Yes No guidance of NFPA 25 Inspection, Testing and Maintenance of Document(s) used to confirm Criteria:
Water-Based Fire Protection Systems (1998 Edition), Section 2-3.1.1, or NFPA 25 (2002 Edition), Section 5.3.1.1.1. This NFPA section states where sprinklers have been in place for 50 years, they shall be replaced or representative samples from Comment:
one or more sample areas shall be submitted to a recognized testing laboratory for field service testing. It also contains guidance to perform this sampling every 10 years after the initial field service testing.
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Program Auditable GALL Criteria Documentation of Audit Finding Element C. The fire protection system piping is to be subjected to Consistent with GALL AMP: Yes No required flow testing in accordance with guidance in NFPA 25 to Document(s) used to confirm Criteria:
verify design pressure or evaluated for wall thickness (e.g., non-intrusive volumetric testing or plant maintenance visual inspections) to ensure that aging effects are managed and that wall thickness is within acceptable limits. These inspections are Comment:
performed before the end of the current operating term and at plant-specific intervals thereafter during the period of extended operation. The plant-specific inspection intervals are to be determined by engineering evaluation of the fire protection piping to ensure that degradation will be detected before the loss of intended function. The purpose of the full flow testing and wall thickness evaluations is to ensure that corrosion, MIC, or biofouling is managed such that the system function is maintained.
- 1. Scope of A. The AMP focuses on managing loss of material due to Consistent with GALL AMP: Yes No Program corrosion, MIC, or biofouling of carbon steel and cast-iron Document(s) used to confirm Criteria:
components in fire protection systems exposed to water. Hose stations and standpipes are considered as piping in the AMP.
Comment
- 2. Preventive A. To ensure no significant corrosion, MIC, or biofouling has Consistent with GALL AMP: Yes No Actions occurred in water-based fire protection systems, periodic Document(s) used to confirm Criteria:
flushing, system performance testing, and inspections may be conducted.
Comment:
- 3. Parameters A. Loss of material due to corrosion and biofouling could reduce Consistent with GALL AMP: Yes No Monitored/ wall thickness of the fire protection piping system and result in Document(s) used to confirm Criteria:
Inspected system failure. Therefore, the parameters monitored are the systems ability to maintain pressure and internal system corrosion conditions.
Comment:
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Program Auditable GALL Criteria Documentation of Audit Finding Element B. Periodic flow testing of the fire water system is performed Consistent with GALL AMP: Yes No using the guidelines of NFPA 25, or wall thickness evaluations Document(s) used to confirm Criteria:
may be performed to ensure that the system maintains its intended function.
Comment:
- 4. Detection of A. Fire protection system testing is performed to assure that the Consistent with GALL AMP: Yes No Aging Effects system functions by maintaining required operating pressures. Document(s) used to confirm Criteria:
Wall thickness evaluations of fire protection piping are performed on system components using non-intrusive techniques (e.g., volumetric testing) to identify evidence of loss of material due to corrosion. These inspections are performed Comment:
before the end of the current operating term and at plant-specific intervals thereafter during the period of extended operation. As an alternative to non-intrusive testing, the plant maintenance process may include a visual inspection of the internal surface of the fire protection piping upon each entry to the system for routine or corrective maintenance, as long as it can be demonstrated that inspections are performed (based on past maintenance history) on a representative number of locations on a reasonable basis. These inspections must be capable of evaluating (1) wall thickness to ensure against catastrophic failure and (2) the inner diameter of the piping as it applies to the design flow of the fire protection system. If the environmental and material conditions that exist on the interior surface of the below grade fire protection piping are similar to the conditions that exist within the above grade fire protection piping, the results of the inspections of the above grade fire protection piping can be extrapolated to evaluate the condition of below grade fire protection piping. If not, additional inspection activities are needed to ensure that the intended function of below grade fire protection piping will be maintained consistent with the current licensing basis for the period of extended operation. Continuous system pressure monitoring, system flow XI.M27 Fire Water System 3
Program Auditable GALL Criteria Documentation of Audit Finding Element testing, and wall thickness evaluations of piping are effective means to ensure that corrosion and biofouling are not occurring and the systems intended function is maintained.
B. General requirements of existing fire protection programs Consistent with GALL AMP: Yes No include testing and maintenance of fire detection and protection Document(s) used to confirm Criteria:
systems and surveillance procedures to ensure that fire detectors, as well as fire protection systems and components are operable.
Comment:
C. Visual inspection of yard fire hydrants performed annually in Consistent with GALL AMP: Yes No accordance with NFPA 25 ensures timely detection of signs of Document(s) used to confirm Criteria:
degradation, such as corrosion. Fire hydrant hose hydrostatic tests, gasket inspections, and fire hydrant flow tests, performed annually, ensure that fire hydrants can perform their intended function and provide opportunities for degradation to be Comment:
detected before a loss of intended function can occur.
D. Sprinkler heads are inspected before the end of the 50-year Consistent with GALL AMP: Yes No sprinkler head service life and at 10-year intervals thereafter Document(s) used to confirm Criteria:
during the extended period of operation to ensure that signs of degradation, such as corrosion, are detected in a timely manner.
Comment:
- 5. Monitoring A. System discharge pressure is monitored continuously. Consistent with GALL AMP: Yes No and Trending Results of system performance testing are monitored and Document(s) used to confirm Criteria:
trended as specified by the associated plant commitments pertaining to NFPA codes and standards. Degradation identified by non-intrusive or internal inspection is evaluated.
Comment:
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Program Auditable GALL Criteria Documentation of Audit Finding Element
- 6. Acceptance A. The acceptance criteria are (a) the ability of a fire protection Consistent with GALL AMP: Yes No Criteria system to maintain required pressure, (b) no unacceptable signs Document(s) used to confirm Criteria:
of degradation observed during non-intrusive or visual assessment of internal system conditions, and (c) that no biofouling exists in the sprinkler systems that could cause corrosion in the sprinkler heads. Comment:
- 7. Corrective A. Repair and replacement actions are initiated as necessary. Consistent with GALL AMP: Yes No Actions For fire water systems and components identified within scope Document(s) used to confirm Criteria:
that are subject to an AMR for license renewal, the applicants 10 CFR Part 50, Appendix B, program is used for corrective actions, confirmation process, and administrative controls for aging management during the period of extended operation. As Comment:
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, confirmation process, and administrative controls.
- 8. A. See Item 7, above. Consistent with GALL AMP: Yes No Confirmation Document(s) used to confirm Criteria:
Process Comment:
- 9. A. See Item 7, above. Consistent with GALL AMP: Yes No Administrative Document(s) used to confirm Criteria:
Controls Comment:
- 10. Operating A. Water-based fire protection systems designed, inspected, Consistent with GALL AMP: Yes No Experience tested and maintained in accordance with the NFPA minimum Document(s) used to confirm Criteria:
standards have demonstrated reliable performance.
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Program Auditable GALL Criteria Documentation of Audit Finding Element Comment:
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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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