ML061000126

GALL AMP: XI.S4, 10 CFR 50, Appendix J (Audit Worksheet GALL Report AMP)

ML061000126
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
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References
%dam200611, TAC MC9668
Download: ML061000126 (5)

Text

AUDIT WORKSHEET GALL REPORT AMP PLANT: ______________________________

LRA AMP: __________________________ REVIEWER: ______________________

GALL AMP: XI.S4, 10 CFR 50, Appendix J DATE: __________________________

Program Auditable GALL Criteria Documentation of Audit Finding Element Program A. As described in 10 CFR Part 50, Appendix J, containment Consistent with GALL AMP: Yes No Description leak rate tests are required "to assure that (a) leakage through Document(s) used to confirm Criteria:

the primary reactor containment and systems and components penetrating primary containment shall not exceed allowable leakage rate values as specified in the technical specifications or associated bases and (b) periodic surveillance of reactor Comment:

containment penetrations and isolation valves is performed so that proper maintenance and repairs are made during the service life of the containment, and systems and components penetrating primary containment."

Appendix J provides two options, A and B, either of which can be chosen to meet the requirements of a containment LRT program. Under Option A, all of the testing must be performed on a periodic interval. Option B is a performance-based approach. Some of the differences between these options are discussed below, and more detailed information for Option B is provided in the Nuclear Regulatory Commission (NRC)

Regulatory Guide (RG) 1.163 and NEI 94-01, Rev. 0.

1. Scope of A. The scope of the containment LRT program includes all Consistent with GALL AMP: Yes No Program pressure-retaining components. Two types of tests are Document(s) used to confirm Criteria:

implemented. Type A tests are performed to measure the overall primary containment integrated leakage rate, which is obtained by summing leakage through all potential leakage paths, including containment welds, valves, fittings, and Comment XI.S4 10 CFR 50, Appendix J 1

Program Auditable GALL Criteria Documentation of Audit Finding Element components that penetrate containment. Type B tests are performed to measure local leakage rates across each pressure-containing or leakage-limiting boundary for containment penetrations. Type A and B tests described in 10 CFR Part 50, Appendix J, are acceptable methods for performing these LRTs. Leakage testing for containment isolation valves (normally performed under Type C tests), if not included under this program, is included under LRT programs for systems containing the isolation valves.

2. Preventive A. No preventive actions are specified; the containment LRT Consistent with GALL AMP: Yes No Actions program is a monitoring program. Document(s) used to confirm Criteria:

Comment:

3. Parameters A. The parameters to be monitored are leakage rates through Consistent with GALL AMP: Yes No Monitored/ containment shells; containment liners; and associated welds, Document(s) used to confirm Criteria:

Inspected penetrations, fittings, and other access openings.

Comment:

4. Detection of A. A containment LRT program is effective in detecting Consistent with GALL AMP: Yes No Aging Effects degradation of containment shells, liners, and components that Document(s) used to confirm Criteria:

compromise the containment pressure boundary, including seals and gaskets. While the calculation of leakage rates demonstrates the leak-tightness and structural integrity of the containment, it does not by itself provide information that would Comment:

indicate that aging degradation has initiated or that the capacity of the containment may have been reduced for other types of loads, such as seismic loading. This would be achieved with the additional implementation of an acceptable containment inservice inspection program as described in XI.S1 and XI.S2.

5. Monitoring A. Because the LRT program is repeated throughout the Consistent with GALL AMP: Yes No XI.S4 10 CFR 50, Appendix J 2

Program Auditable GALL Criteria Documentation of Audit Finding Element and Trending operating license period, the entire pressure boundary is Document(s) used to confirm Criteria:

monitored over time. The frequency of these tests depends on which option (A or B) is selected. With Option A, testing is performed on a regular fixed time interval as defined in 10 CFR Part 50, Appendix J. In the case of Option B, the interval for Comment:

testing may be increased on the basis of acceptable performance in meeting leakage limits in prior tests. Additional details for implementing Option B are provided in NRC Regulatory Guide 1.163 and NEI 94-01, Rev. 0.

6. Acceptance A. Acceptance criteria for leakage rates are defined in plant Consistent with GALL AMP: Yes No Criteria technical specifications. These acceptance criteria meet the Document(s) used to confirm Criteria:

requirements in 10 CFR Part 50, Appendix J, and are part of each plant's current licensing basis. The current licensing basis carries forward to the period of extended operation.

Comment:

7. Corrective A. Corrective actions are taken in accordance with 10 CFR Consistent with GALL AMP: Yes No Actions Part 50, Appendix J, and NEI 94-01. When leakage rates do not Document(s) used to confirm Criteria:

meet the acceptance criteria, an evaluation is performed to identify the cause of the unacceptable performance, and appropriate corrective actions must be taken. As discussed in the appendix to this report, the staff finds the requirements of Comment:

10 CFR Part 50, Appendix B, acceptable to address the corrective actions.

8. A. When corrective actions are implemented to repair a Consistent with GALL AMP: Yes No Confirmation condition that causes excessive leakage, confirmation by Document(s) used to confirm Criteria:

Process additional leak rate testing is performed to confirm that the deficiency has been corrected. 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. Comment:

9. A. Results of the LRT program are documented as described in Consistent with GALL AMP: Yes No Administrative 10 CFR Part 50, Appendix J, to demonstrate that the Document(s) used to confirm Criteria:

Controls acceptance criteria for leakage have been satisfied. The test results that exceed the performance criteria must be assessed XI.S4 10 CFR 50, Appendix J 3

Program Auditable GALL Criteria Documentation of Audit Finding Element under 10 CFR 50.72 and 10 CFR 50.73. As discussed in the appendix to this report, the staff finds the requirements of Comment:

10 CFR Part 50, Appendix B, acceptable to address the administrative controls.

10. Operating A. To date, the 10 CFR Part 50, Appendix J, LRT program has Consistent with GALL AMP: Yes No Experience been effective in preventing unacceptable leakage through the Document(s) used to confirm Criteria:

containment pressure boundary. Implementation of Option B for testing frequency must be consistent with plant-specific operating experience.

Comment:

XI.S4 10 CFR 50, Appendix J 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.S4 10 CFR 50, Appendix J 5