ML061000147
| ML061000147 | |
| 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 | |
| ML060950189 | List:
|
| References | |
| %dam200611, TAC MC9668 | |
| Download: ML061000147 (6) | |
Text
AUDIT WORKSHEET GALL REPORT AMP PLANT: ______________________________
LRA AMP: __________________________ REVIEWER: ______________________
GALL AMP: XI.S8, Protective Coating Monitoring And Maintenance DATE: __________________________
Program Program Auditable GALL Criteria Documentation of Audit Finding Element Program A. Proper maintenance of protective coatings inside Consistent with GALL AMP: Yes No Description containment (defined as Service Level I in Nuclear Regulatory Document(s) used to confirm Criteria:
Commission [NRC] Regulatory Guide [RG] 1.54, Rev. 1) is essential to ensure operability of post-accident safety systems that rely on water recycled through the containment sump/drain system. Degradation of coatings can lead to clogging of Comment:
strainers, which reduces flow through the sump/drain system.
This has been addressed in NRC Generic Letter (GL) 98-04.
Maintenance of Service Level I coatings applied to carbon steel surfaces inside containment (e.g., steel liner, steel containment shell, penetrations, hatches) also serves to prevent or minimize loss of material due to corrosion. Regulatory Position C4 in RG 1.54, Rev. 1, describes an acceptable technical basis for a Service Level I coatings monitoring and maintenance program that can be credited for managing the effects of corrosion for carbon steel elements inside containment. The attributes of an acceptable program are described below.
A comparable program for monitoring and maintaining protective coatings inside containment, developed in accordance with RG 1.54, Rev. 0 or the American National Standards Institute (ANSI) standards (since withdrawn) referenced in RG 1.54, Rev. 0, and coatings maintenance programs described in licensee responses to GL 98-04, is also acceptable as an aging management program (AMP) for license XI.S8 Protective Coating Monitoring and Maintenance Program 1
Program Auditable GALL Criteria Documentation of Audit Finding Element renewal.
- 1. Scope of A. The minimum scope of the program is Service Level I Consistent with GALL AMP: Yes No Program coatings, defined in RG 1.54, Rev 1, as follows: "Service Level I Document(s) used to confirm Criteria:
coatings are used in areas inside the reactor containment where the coating failure could adversely affect the operation of post-accident fluid systems and thereby impair safe shutdown.
Comment:
- 2. Preventive A. With respect to loss of material due to corrosion of carbon Consistent with GALL AMP: Yes No Actions steel elements, this program is a preventive action. Document(s) used to confirm Criteria:
Comment:
- 3. Parameters A. Regulatory Position C4 in RG 1.54, Rev 1, states that "ASTM Consistent with GALL AMP: Yes No Monitored/ D 5163-96 provides guidelines that are acceptable to the NRC Document(s) used to confirm Criteria:
Inspected staff for establishing an in-service coatings monitoring program for Service Level I coating systems in operating nuclear power plants...." ASTM D 5163-96 has been superseded by ASTM D 5163-05. ASTM D 5163-05, subparagraph 10.2, identifies the Comment:
parameters monitored or inspected to be "any visible defects, such as blistering, cracking, flaking, peeling, rusting, and physical damage."
- 4. Detection of A. ASTM D 5163-05, paragraph 6, defines the inspection Consistent with GALL AMP: Yes No Aging Effects frequency to be each refueling outage or during other major Document(s) used to confirm Criteria:
maintenance outages as needed. ASTM D 5163-05, paragraph 9, discusses the qualifications for inspection personnel, the inspection coordinator and the inspection results evaluator.
ASTM D 5163-05, subparagraph 10.1, discusses development Comment:
of the inspection plan and the inspection methods to be used. It states, "A general visual inspection shall be conducted on all readily accessible coated surfaces during a walk-through. After a walk-through, or during the general visual inspection, thorough visual inspections shall be carried out on previously designated areas and on areas noted as deficient during the walk-through.
XI.S8 Protective Coating Monitoring and Maintenance Program 2
Program Auditable GALL Criteria Documentation of Audit Finding Element A thorough visual inspection shall also be carried out on all coatings near sumps or screens associated with the Emergency Core Cooling System (ECCS)." This subparagraph also addresses field documentation of inspection results. ASTM D 5163-05, subparagraph 10.5, identifies instruments and equipment needed for inspection.
- 5. Monitoring A. ASTM D 5163-05 identifies monitoring and trending activities Consistent with GALL AMP: Yes No and Trending in subparagraph 7.2, which specifies a pre-inspection review of Document(s) used to confirm Criteria:
the previous two monitoring reports, and in subparagraph 11.1.2, which specifies that the inspection report should prioritize repair areas as either needing repair during the same outage or postponed to future outages, but under surveillance in Comment:
the interim period.
- 6. Acceptance A. ASTM D 5163-05, subparagraphs 10.2.1 through 10.2.6, Consistent with GALL AMP: Yes No Criteria 10.3, and 10.4, contain one acceptable method for Document(s) used to confirm Criteria:
characterization, documentation, and testing of defective or deficient coating surfaces. Additional ASTM and other recognized test methods are available for use in characterizing the severity of observed defects and deficiencies. The Comment:
evaluation covers blistering, cracking, flaking, peeling, delamination, and rusting. ASTM D 5163-05, paragraph 12, addresses evaluation. It specifies that the inspection report is to be evaluated by the responsible evaluation personnel, who prepare a summary of findings and recommendations for future surveillance or repair, including an analysis of reasons or suspected reasons for failure. Repair work is prioritized as major or minor defective areas. A recommended corrective action plan is required for major defective areas, so that these areas can be repaired during the same outage, if appropriate.
- 7. Corrective A. As discussed in the appendix to this report, the staff finds the Consistent with GALL AMP: Yes No Actions requirements of 10 CFR Part 50, Appendix B, acceptable to Document(s) used to confirm Criteria:
address the corrective actions.
XI.S8 Protective Coating Monitoring and Maintenance Program 3
Program Auditable GALL Criteria Documentation of Audit Finding Element Comment:
- 8. A. As discussed in the appendix to this report, the staff finds the Consistent with GALL AMP: Yes No Confirmation requirements of 10 CFR Part 50, Appendix B, acceptable to Document(s) used to confirm Criteria:
Process address the confirmation process.
Comment:
- 9. A. As discussed in the appendix to this report, the staff finds the Consistent with GALL AMP: Yes No Administrative requirements of 10 CFR Part 50, Appendix B, acceptable to Document(s) used to confirm Criteria:
Controls address the administrative controls.
Comment:
- 10. Operating A. NRC Generic Letter 98-04 describes industry experience Consistent with GALL AMP: Yes No Experience pertaining to coatings degradation inside containment and the Document(s) used to confirm Criteria:
consequential clogging of sump strainers. RG 1.54, Rev. 1, was issued in July 2000. Monitoring and maintenance of Service Level I coatings conducted in accordance with Regulatory Position C4 is expected to be an effective program for managing Comment:
degradation of Service Level I coatings, and consequently an effective means to manage loss of material due to corrosion of carbon steel structural elements inside containment.
XI.S8 Protective Coating Monitoring and Maintenance Program 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.S8 Protective Coating Monitoring and Maintenance Program 5