ML060950610

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

ML060950610
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: ML060950610 (5)

Text

XI.M29 Aboveground Steel Tanks 1

AUDIT WORKSHEET GALL REPORT AMP PLANT: ______________________________

LRA AMP: __________________________

REVIEWER: ______________________

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

Program Element Auditable GALL Criteria Documentation of Audit Finding Program Description A. The program includes preventive measures to mitigate corrosion by protecting the external surface of steel tanks with 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, 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.

Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment:

1. Scope of Program A. The program consists of (a) preventive measures to mitigate corrosion by protecting the external surfaces of carbon steel tanks protected with paint or coatings and Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment B. (b) periodic system walkdowns to manage the effects of corrosion on the intended function of these tanks. Plant walkdowns cover the entire outer surface of the tank up to its surface in contact with soil or concrete.

Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

XI.M29 Aboveground Steel Tanks 2

Program Element Auditable GALL Criteria Documentation of Audit Finding Comment:

2. Preventive Actions A. In accordance with industry practice, tanks are coated with protective paint or coating to mitigate corrosion by protecting the 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 penetrating the interface, which would lead to corrosion of the bottom surface.

Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment:

3. Parameters Monitored/

Inspected A. The AMP utilizes periodic plant system walkdowns to monitor degradation of coatings, sealants, and caulking because it is a condition directly related to the potential loss of materials.

Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment:

4. Detection of Aging Effects A. Degradation of exterior carbon steel surfaces cannot occur without degradation of paint or coatings on the outer surface 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 external surface of the component.

Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment:

B. However, corrosion may occur at inaccessible locations, such as the tank bottom surface, thus, thickness measurement of the 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.

Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment:

XI.M29 Aboveground Steel Tanks 3

Program Element Auditable GALL Criteria Documentation of Audit Finding 5.Monitoring and Trending A. The effects of corrosion of the aboveground external surface are detectable by visual techniques. Based on operating 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 and trended if significant material loss is detected.

Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment:

6. Acceptance Criteria A. Any degradation of paint, coating, sealant, and caulking is reported and will require further evaluation. Degradation 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.

Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment:

7. Corrective Actions A. The site corrective actions program, quality assurance (QA) procedures, site review and approval process, and 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, confirmation process, and administrative controls.

Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment:

8.

Confirmation Process A. See Item 7, above.

Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment:

9.

Administrative Controls A. See Item 7, above.

Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment:

10. Operating A. Coating degradation, such as flaking and peeling, has Consistent with GALL AMP:

Yes No

XI.M29 Aboveground Steel Tanks 4

Program Element Auditable GALL Criteria Documentation of Audit Finding Experience occurred in safety-related systems and structures (Nuclear 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 IN 86-99, Supplement 1).

Document(s) used to confirm Criteria:

Comment:

XI.M29 Aboveground Steel Tanks 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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