ML060950624

2006/03/22-GALL AMP: XI.M32, One-Time Inspection (Audit Worksheet GALL Report AMP)

ML060950624
Person / Time
Site:	Vermont Yankee
Issue date:	03/22/2006
From:	Morgan M J NRC/NRR/ADRO/DLR/RLRC
To:	Office of Nuclear Reactor Regulation
morgan M J NRR/NRC/DLR/RLRC, 415-2232
Shared Package
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References
%dam200611, TAC MC9668
Download: ML060950624 (6)

Text

XI.M32 One-Time Inspection 1 AUDIT W ORKSHEET GALL R EPORT AMP PLANT: ______________________________

LRA AMP: __________________________

R EVIEWER: ______________________

GALL AMP: XI.M32, One-Time Inspection DATE: __________________________

Program Element Auditable GALL Criteria Documentation of Audit Finding Program Description A. The program includes measures to verify the effectiveness of an aging management program (AMP) and confirm the insignificance of an aging effect. Situations in which additional confirmation is appropriate include (a) an aging effect is not expected to occur but the data is insufficient to rule it out with reasonable confidence; (b) an aging effect is expected to progress very slowly in the specified environment, but the local environment may be more adverse than that generally expected; or (c) the characteristics of the aging effect include a long incubation period. For these cases, there is to be confirmation that either the aging effect is indeed not occurring, or the aging effect is occurring very slowly so as not to affect the component or structure intended function during the period of extended operation. Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment: " B. A one-time inspection may also be used to provide additional assurance that aging that has not yet manifested itself is not occurring, or that the evidence of aging shows that the aging is so insignificant that an aging management program is not warranted. (Class 1 piping less than or equal to NPS 4 is addressed in Chapter XI.M35, One Time Inspection of ASME Code Class 1 Small Bore-Piping)

One-time inspections may also be used to verify the system-wide effectiveness of an AMP that is designed to prevent or minimize aging to the extent that it will not cause the loss of Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment:

XI.M32 One-Time Inspection 2 Program Element Auditable GALL Criteria Documentation of Audit Finding intended function during the period of extended operation. For example, effective control of water chemistry can prevent some aging effects and minimize others. However, there may be locations that are isolated from the flow stream for extended periods and are susceptible to the gradual accumulation or concentration of agents that promote certain aging effects. This program provides inspections that either verifies that unacceptable degradation is not occurring or trigger additional actions that will assure the intended function of affected components will be maintained during the period of extended operation.

" C. The elements of the program include (a) determination of the sample size based on an assessment of materials of fabrication, environment, plausible aging effects, and operating experience; (b) identification of the inspection locations in the system or component based on the aging effect; (c) determination of the examination technique, including acceptance criteria that would be effective in managing the aging effect for which the component is examined; and (d) evaluation of the need for follow-up examinations to monitor the progression of aging if age-related degradation is found that could jeopardize an intended function before the end of the period of extended operation. When evidence of an aging effect is revealed by a one-time inspection, the routine evaluation of the inspection results would identify appropriate corrective actions. Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment: " D. As set forth below, an acceptable verification program may consist of a one-time inspection of selected components and susceptible locations in the system. An alternative acceptable program may include routine maintenance or a review of repair or inspection records to confirm that these components have been inspected for aging degradation and significant aging degradation has not occurred. One-time inspection, or any other action or program, created to verify the effectiveness of an AMP Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment:

XI.M32 One-Time Inspection 3 Program Element Auditable GALL Criteria Documentation of Audit Finding and confirm the absence of an aging effect, is to be reviewed by the staff on a plant-specific basis. 1. Scope of Program A. The program includes measures to verify that unacceptable degradation is not occurring, thereby validating the effectiveness of existing AMPs or confirming that there is no need to manage aging-related degradation for the period of extended operation. The structures and components for which one-time inspection is specified to verify the effectiveness of the AMPs (e.g., water chemistry control, etc.) have been identified in the Generic Aging Lessons Learned (GALL) Report. Examples include the feedwater system components in boiling water reactors (BWRs) and pressurized water reactors (PWRs). Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment: 2. Preventive Actions A. One-time inspection is an inspection activity independent of methods to mitigate or prevent degradation. Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment: 3. Parameters Monitored/ Inspected A. The program monitors parameters directly related to the degradation of a component. Inspection is to be performed by qualified personnel following procedures consistent with the requirements of the American Society of Mechanical Engineers (ASME) Code and 10 CFR 50, Appendix B, using a variety of nondestructive examination (NDE) methods, including visual, volumetric, and surface techniques. Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment: 4. Detection of Aging Effects A. The inspection includes a representative sample of the system population, and, where practical, focuses on the bounding or lead components most susceptible to aging due to time in service, severity of operating conditions, and lowest design margin. The program will rely on established NDE techniques, including visual, ultrasonic, and surface techniques that are performed by qualified personnel following procedures consistent with the ASME Code and 10 CFR Part 50, Appendix B. Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment:

XI.M32 One-Time Inspection 4 Program Element Auditable GALL Criteria Documentation of Audit Finding The inspection and test techniques will have a demonstrated history of effectiveness in detecting the aging effect of concern. Typically, the one time inspections should be performed as indicated in the following table.

See the GALL Report, XI.M32, One-Time Inspection, for more information. 5. Monitoring and Trending A. The program provides for increasing of the inspection sample size and locations in the event that aging effects are detected. Determination of the sample size is based on an assessment of materials of fabrication, environment, plausible aging effects, and operating experience. Unacceptable inspection findings are evaluated in accordance with the site corrective action process to determine the need for subsequent (including periodic) inspections and for monitoring and trending the results. Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment: 6. Acceptance Criteria A. Any indication or relevant conditions of degradation detected are evaluated. For example, the ultrasonic thickness measurements are to be compared to predetermined limits, such as the design minimum wall thickness for piping. Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment: 7. Corrective Actions A. Site quality assurance (QA) procedures, review and approval processes, and administrative controls are implemented in accordance with the requirements of 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:

XI.M32 One-Time Inspection 5 Program Element Auditable GALL Criteria Documentation of Audit Finding 9. Administrative Controls A. See Item 7, above. Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment: 10. Operating Experience A. This program applies to potential aging effects for which there are currently no operating experience indicating the need for an aging management program. Nevertheless, the elements that comprise these inspections (e.g., the scope of the inspections and inspection techniques) are consistent with industry practice. Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment:

XI.M32 One-Time Inspection 6 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 D URING A UDIT Document Number Identifier (number) Title Revision and/or Date 1. 2. 3. 4. -.