ML060950610

GALL AMP: XI.M29, Aboveground Steel Tanks (Audit Worksheet GALL Report AMP)

ML060950610
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
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References
%dam200611, TAC MC9668
Download: ML060950610 (5)

Text

AUDIT WORKSHEET GALL REPORT AMP PLANT: ______________________________

LRA AMP: __________________________ REVIEWER: ______________________

GALL AMP: XI.M29, Aboveground Steel Tanks DATE: __________________________

Program Auditable GALL Criteria Documentation of Audit Finding Element Program A. The program includes preventive measures to mitigate Consistent with GALL AMP: Yes No Description corrosion by protecting the external surface of steel tanks with Document(s) used to confirm Criteria:

paint or coatings in accordance with standard industry practice.

The program also relies on periodic system walkdowns to monitor degradation of the protective paint or coating. However, for storage tanks supported on earthen or concrete foundations, Comment:

corrosion may occur at inaccessible locations, such as the tank bottom. Accordingly, verification of the effectiveness of the program is to be performed to ensure that significant degradation in inaccessible locations is not occurring and the component intended function will be maintained during the extended period of operation. For reasons set forth below, an acceptable verification program consists of thickness measurement of the tank bottom surface.

1. Scope of A. The program consists of (a) preventive measures to mitigate Consistent with GALL AMP: Yes No Program corrosion by protecting the external surfaces of carbon steel Document(s) used to confirm Criteria:

tanks protected with paint or coatings and Comment B. (b) periodic system walkdowns to manage the effects of Consistent with GALL AMP: Yes No corrosion on the intended function of these tanks. Plant Document(s) used to confirm Criteria:

walkdowns cover the entire outer surface of the tank up to its surface in contact with soil or concrete.

XI.M29 Aboveground Steel Tanks 1

Program Auditable GALL Criteria Documentation of Audit Finding Element Comment:

2. Preventive A. In accordance with industry practice, tanks are coated with Consistent with GALL AMP: Yes No Actions protective paint or coating to mitigate corrosion by protecting the Document(s) used to confirm Criteria:

external surface of the tank from environmental exposure.

Sealant or caulking at the interface edge between the tank and concrete or earthen foundation mitigates corrosion of the bottom surface of the tank by preventing water and moisture from Comment:

penetrating the interface, which would lead to corrosion of the bottom surface.

3. Parameters A. The AMP utilizes periodic plant system walkdowns to monitor Consistent with GALL AMP: Yes No Monitored/ degradation of coatings, sealants, and caulking because it is a Document(s) used to confirm Criteria:

Inspected condition directly related to the potential loss of materials.

Comment:

4. Detection of A. Degradation of exterior carbon steel surfaces cannot occur Consistent with GALL AMP: Yes No Aging Effects without degradation of paint or coatings on the outer surface Document(s) used to confirm Criteria:

and of sealant and caulking at the interface between the component and concrete. Periodic system walkdowns to confirm that the paint, coating, sealant, and caulking are intact is an effective method to manage the effects of corrosion on the Comment:

external surface of the component.

B. However, corrosion may occur at inaccessible locations, such Consistent with GALL AMP: Yes No as the tank bottom surface, thus, thickness measurement of the Document(s) used to confirm Criteria:

tank bottom is to be taken to ensure that significant degradation is not occurring and the component intended function will be maintained during the extended period of operation.

Comment:

XI.M29 Aboveground Steel Tanks 2

Program Auditable GALL Criteria Documentation of Audit Finding Element 5.Monitoring A. The effects of corrosion of the aboveground external surface Consistent with GALL AMP: Yes No and Trending are detectable by visual techniques. Based on operating Document(s) used to confirm Criteria:

experience, plant system walkdowns during each outage provide for timely detection of aging effects. The effects of corrosion of the underground external surface are detectable by thickness measurement of the tank bottom and are monitored Comment:

and trended if significant material loss is detected.

6. Acceptance A. Any degradation of paint, coating, sealant, and caulking is Consistent with GALL AMP: Yes No Criteria reported and will require further evaluation. Degradation Document(s) used to confirm Criteria:

consists of cracking, flaking, or peeling of paint or coatings, and drying, cracking or missing sealant and caulking. Thickness measurements of the tank bottom are evaluated against the design thickness and corrosion allowance. Comment:

7. Corrective A. The site corrective actions program, quality assurance (QA) Consistent with GALL AMP: Yes No Actions procedures, site review and approval process, and Document(s) used to confirm Criteria:

administrative controls are implemented in accordance with 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 corrective actions, Comment:

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. Coating degradation, such as flaking and peeling, has Consistent with GALL AMP: Yes No XI.M29 Aboveground Steel Tanks 3

Program Auditable GALL Criteria Documentation of Audit Finding Element Experience occurred in safety-related systems and structures (Nuclear Document(s) used to confirm Criteria:

Regulatory Commission [NRC] Generic Letter [GL] 98-04).

Corrosion damage near the concrete-metal interface and sand-metal interface has been reported in metal containments (NRC Information Notice [IN] 89-79, Supplement 1, and NRC Comment:

IN 86-99, Supplement 1).

XI.M29 Aboveground Steel Tanks 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.M29 Aboveground Steel Tanks 5