ML060950570

2006/03/22-GALL AMP: XI.M22, Boraflex Monitoring (Audit Worksheet GALL Report AMP)

ML060950570
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: ML060950570 (5)

Text

XI.M22 Boraflex Monitoring 1 AUDIT W ORKSHEET GALL R EPORT AMP PLANT: ______________________________

LRA AMP: __________________________

R EVIEWER: ______________________

GALL AMP: XI.M22, Boraflex Monitoring DATE: __________________________

Program Element Auditable GALL Criteria Documentation of Audit Finding Program Description A. A Boraflex monitoring program for the actual Boraflex panels is implemented in the spent fuel racks to assure that no unexpected degradation of the Boraflex material would compromise the criticality analysis in support of the design of spent fuel storage racks. The applicable aging management program (AMP), based on manufacturer's recommendations, relies on periodic inspection, testing, monitoring, and analysis of the criticality design to assure that the required 5% subcriticality margin is maintained. The frequency of the inspection and testing depends on the condition of the Boraflex, with a maximum of five years. Certain accelerated samples are tested every two years. Results based on test coupons have been found to be unreliable in determining the degree to which the actual Boraflex panels have been degraded. Therefore, this AMP includes: (1) performing neutron attenuation testing, called blackness testing, to determine gap formation in Boraflex panels; (2) completing sampling and analysis for silica levels in the spent fuel pool water and trending the results by using the EPRI RACKLIFE predictive code or its equivalent on a monthly, quarterly, or annual basis (depending on Boraflex panel condition); and (3) measuring boron areal density by techniques such as the BADGER device. Corrective actions are initiated if the test results find that the 5% subcriticality margin cannot be maintained because of current or projected future Boraflex Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment:

XI.M22 Boraflex Monitoring 2 Program Element Auditable GALL Criteria Documentation of Audit Finding degradation. 1. Scope of Program A. The AMP manages the effects of aging on sheets of neutron-absorbing materials affixed to spent fuel racks. For Boraflex panels, gamma irradiation and long-term exposure to the wet pool environment cause shrinkage resulting in gap formation, gradual degradation of the polymer matrix, and the release of silica to the spent fuel storage pool water. This results in the loss of boron carbide in the neutron absorber sheets. Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment: 2. Preventive Actions A. For Boraflex panels, monitoring silica levels in the storage pool water, measuring gap formation by blackness testing, periodically measuring boron areal density, and applying predictive codes, are performed. These actions ensure that degradation of the neutron-absorbing material is identified and corrected so the spent fuel storage racks will be capable of performing their intended functions during the period of extended operation, consistent with current licensing basis (CLB) design conditions. Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment: 3. Parameters Monitored/ Inspected A. The parameters monitored include physical conditions of the Boraflex panels, such as gap formation and decreased boron areal density, and the concentration of the silica in the spent fuel pool. These are conditions directly related to degradation of the Boraflex material. When Boraflex is subjected to gamma radiation and long-term exposure to the spent fuel pool environment, the silicon polymer matrix becomes degraded and silica filler and boron carbide are released into the spent fuel pool water. As indicated in the Nuclear Regulatory Commission (NRC) Information Notice (IN) 95-38 and NRC Generic Letter (GL) 96-04, the loss of boron carbide (washout) from Boraflex is characterized by slow dissolution of silica from the surface of the Boraflex and a gradual thinning of the material. Because Boraflex contains about 25% silica, 25% polydimethyl siloxane polymer, and 50% boron carbide, sampling and analysis of the presence of silica in the spent fuel pool provide an indication of depletion of boron carbide from Boraflex; however, the degree Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment:

XI.M22 Boraflex Monitoring 3 Program Element Auditable GALL Criteria Documentation of Audit Finding to which Boraflex has degraded is ascertained through measurement of the boron areal density. 4. Detection of Aging Effects A. The amount of boron carbide released from the Boraflex panel is determined through direct measurement of boron areal density and correlated with the levels of silica present with a predictive code. This is supplemented with detection of gaps through blackness testing and periodic verification of boron loss through areal density measurement techniques such as the BADGER device. Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment: 5. Monitoring and Trending A. The periodic inspection measurements and analysis are to be compared to values of previous measurements and analysis to provide a continuing level of data for trend analysis. Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment: 6. Acceptance Criteria A. The 5% subcriticality margin of the spent fuel racks is to be maintained for the period of extended operation. Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment: 7. Corrective Actions A. Corrective actions are initiated if the test results find that the 5% subcriticality margin cannot be maintained because of the current or projected future degradation. Corrective actions consist of providing additional neutron-absorbing capacity by Boral or boron steel inserts, or other options, which are available to maintain a subcriticality margin of 5%. 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. Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment: 8. Confirmation Process A. Site quality assurance (QA) procedures, site review and approval processes, and administrative controls are implemented in accordance with the requirements of 10 CFR Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

XI.M22 Boraflex Monitoring 4 Program Element Auditable GALL Criteria Documentation of Audit Finding 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 confirmation process and administrative controls.

Comment: 9. Administrative Controls A. See item 8, above. Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment: 10. Operating Experience A. The NRC IN 87-43 addresses the problems of development of tears and gaps (average 1-2 in., with the largest 4 in.) in Boraflex sheets due to gamma radiation-induced shrinkage of the material. NRC INs 93-70 and 95-38 and NRC GL 96-04 address several cases of significant degradation of Boraflex test coupons due to accelerated dissolution of Boraflex caused by pool water flow through panel enclosures and high accumulated gamma dose. Two spent fuel rack cells with about 12 years of service have only 40% of the Boraflex remaining. In such cases, the Boraflex may be replaced by boron steel inserts or by a completely new rack system using Boral. Experience with boron steel is limited; however, the application of Boral for use in the spent fuel storage racks predates the manufacturing and use of Boraflex. The experience with Boraflex panels indicates that coupon surveillance programs are not reliable. Therefore, during the period of extended operation, the measurement of boron areal density correlated, through a predictive code, with silica levels in the pool water is verified. These monitoring programs provide assurance that degradation of Boraflex sheets is monitored, so that appropriate actions can be taken in a timely manner if significant loss of neutron-absorbing capability is occurring. These monitoring programs ensure that the Boraflex sheets will maintain their integrity and will be effective in performing its intended function. Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment:

XI.M22 Boraflex Monitoring 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 D URING A UDIT Document Number Identifier (number) Title Revision and/or Date 1. 2. 3. 4. -.