ML061000147

2006/03/22-GALL AMP: XI.S8, Protective Coating Monitoring and Maintenance Program (Audit Worksheet GALL Report AMP)

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
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References
%dam200611, TAC MC9668
Download: ML061000147 (6)

Text

XI.S8 Protective Coating Monitoring and Maintenance Program 1 AUDIT W ORKSHEET GALL R EPORT AMP PLANT: ______________________________

LRA AMP: __________________________

R EVIEWER: ______________________

GALL AMP: XI.S8, Protective Coating Monitoring And Maintenance Program DATE: __________________________

Program Element Auditable GALL Criteria Documentation of Audit Finding Program Description A. Proper maintenance of protective coatings inside containment (defined as Service Level I in Nuclear Regulatory 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 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developed in accordance with RG 1.54, Rev. 0 or the American National Standards Institute (ANSI) standards (since withdrawn) referenced in RG 1.54, Rev. 0, and coatings maintenance programs described in licensee responses to GL 98-04, is also acceptable as an aging management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 Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment:

XI.S8 Protective Coating Monitoring and Maintenance Program 2 Program Element Auditable GALL Criteria Documentation of Audit Finding renewal. 1. Scope of Program A. The minimum scope of the program is Service Level I coatings, defined in RG 1.54, Rev 1, as follows: "Service Level I 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." Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment: 2. Preventive Actions A. With respect to loss of material due to corrosion of carbon steel elements, this program is a preventive action. Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment: 3. Parameters Monitored/ Inspected A. Regulatory Position C4 in RG 1.54, Rev 1, states that "ASTM D 5163-96 provides guidelines that are acceptable to the NRC 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 parameters monitored or inspected to be "any visible defects, such as blistering, cracking, flaking, peeling, rusting, and physical damage." Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment: 4. Detection of Aging Effects A. ASTM D 5163-05, paragraph 6, defines the inspection frequency to be each refueling outage or during other major 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 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. Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment:

XI.S8 Protective Coating Monitoring and Maintenance Program 3 Program Element Auditable GALL Criteria Documentation of Audit Finding 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 and Trending A. ASTM D 5163-05 identifies monitoring and trending activities in subparagraph 7.2, which specifies a pre-inspection review of 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 the interim period. Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment: 6. Acceptance Criteria A. ASTM D 5163-05, subparagraphs 10.2.1 through 10.2.6, 10.3, and 10.4, contain one acceptable method for 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 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. Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment: 7. Corrective Actions A. 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:

XI.S8 Protective Coating Monitoring and Maintenance Program 4 Program Element Auditable GALL Criteria Documentation of Audit Finding Comment: 8. Confirmation Process A. 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. Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment: 9.

Administrative Controls A. As discussed in the appendix to this report, the staff finds the requirements of 10 CFR Part 50, Appendix B, acceptable to address the administrative controls. Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment: 10. Operating Experience A. NRC Generic Letter 98-04 describes industry experience pertaining to coatings degradation inside containment and the 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 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. Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment:

XI.S8 Protective Coating Monitoring and Maintenance Program 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. -.