ML060950596

2006/03/22-GALL AMP: XI.M27, Fire Water System (Audit Worksheet GALL Report AMP)

ML060950596
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/RLRA, 415-2232
Shared Package
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References
%dam200611, TAC MC9668
Download: ML060950596 (5)

Text

XI.M27 Fire Water System 1 AUDIT W ORKSHEET GALL R EPORT AMP PLANT: ______________________________

LRA AMP: __________________________

R EVIEWER: ______________________

GALL AMP: XI.M27, Fire Water System DATE: __________________________

Program Element Auditable GALL Criteria Documentation of Audit Finding Program Description A. This aging management program (AMP) applies to water-based fire protection systems that consist of sprinklers, nozzles, fittings, valves, hydrants, hose stations, standpipes, water storage tanks, and aboveground and underground piping and components that are tested in accordance with the applicable National Fire Protection Association (NFPA) codes and standards. Such testing assures the minimum functionality of the systems. Also, these systems are normally maintained at required operating pressure and monitored such that loss of system pressure is immediately detected and corrective actions initiated. Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment: " B. A sample of sprinkler heads is to be inspected by using the guidance of NFPA 25 "Inspection, Testing and Maintenance of Water-Based Fire Protection Systems" (1998 Edition), Section 2-3.1.1, or NFPA 25 (2002 Edition), Section 5.3.1.1.1. This NFPA section states "where sprinklers have been in place for 50 years, they shall be replaced or representative samples from one or more sample areas shall be submitted to a recognized testing laboratory for field service testing." It also contains guidance to perform this sampling every 10 years after the initial field service testing. Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment:

XI.M27 Fire Water System 2 Program Element Auditable GALL Criteria Documentation of Audit Finding " C. The fire protection system piping is to be subjected to required flow testing in accordance with guidance in NFPA 25 to verify design pressure or evaluated for wall thickness (e.g., non-intrusive volumetric testing or plant maintenance visual inspections) to ensure that aging effects are managed and that wall thickness is within acceptable limits. These inspections are performed before the end of the current operating term and at plant-specific intervals thereafter during the period of extended operation. The plant-specific inspection intervals are to be determined by engineering evaluation of the fire protection piping to ensure that degradation will be detected before the loss of intended function. The purpose of the full flow testing and wall thickness evaluations is to ensure that corrosion, MIC, or biofouling is managed such that the system function is maintained. Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment: 1. Scope of Program A. The AMP focuses on managing loss of material due to corrosion, MIC, or biofouling of carbon steel and cast-iron components in fire protection systems exposed to water. Hose stations and standpipes are considered as piping in the AMP. Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment 2. Preventive Actions A. To ensure no significant corrosion, MIC, or biofouling has occurred in water-based fire protection systems, periodic flushing, system performance testing, and inspections may be conducted. Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment: 3. Parameters Monitored/ Inspected A. Loss of material due to corrosion and biofouling could reduce wall thickness of the fire protection piping system and result in system failure. Therefore, the parameters monitored are the system's ability to maintain pressure and internal system corrosion conditions. Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment:

XI.M27 Fire Water System 3 Program Element Auditable GALL Criteria Documentation of Audit Finding " B. Periodic flow testing of the fire water system is performed using the guidelines of NFPA 25, or wall thickness evaluations may be performed to ensure that the system maintains its intended function. Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment: 4. Detection of Aging Effects A. Fire protection system testing is performed to assure that the system functions by maintaining required operating pressures.

Wall thickness evaluations of fire protection piping are performed on system components using non-intrusive techniques (e.g., volumetric testing) to identify evidence of loss of material due to corrosion. These inspections are performed before the end of the current operating term and at plant-specific intervals thereafter during the period of extended operation. As an alternative to non-intrusive testing, the plant maintenance process may include a visual inspection of the internal surface of the fire protection piping upon each entry to the system for routine or corrective maintenance, as long as it can be demonstrated that inspections are performed (based on past maintenance history) on a representative number of locations on a reasonable basis. These inspections must be capable of evaluating (1) wall thickness to ensure against catastrophic failure and (2) the inner diameter of the piping as it applies to the design flow of the fire protection system. If the environmental and material conditions that exist on the interior surface of the below grade fire protection piping are similar to the conditions that exist within the above grade fire protection piping, the results of the inspections of the above grade fire protection piping can be extrapolated to evaluate the condition of below grade fire protection piping. If not, additional inspection activities are needed to ensure that the intended function of below grade fire protection piping will be maintained consistent with the current licensing basis for the period of extended operation. Continuous system pressure monitoring, system flow Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment:

XI.M27 Fire Water System 4 Program Element Auditable GALL Criteria Documentation of Audit Finding testing, and wall thickness evaluations of piping are effective means to ensure that corrosion and biofouling are not occurring and the system's intended function is maintained. " B. General requirements of existing fire protection programs include testing and maintenance of fire detection and protection systems and surveillance procedures to ensure that fire detectors, as well as fire protection systems and components are operable. Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment: " C. Visual inspection of yard fire hydrants performed annually in accordance with NFPA 25 ensures timely detection of signs of degradation, such as corrosion. Fire hydrant hose hydrostatic tests, gasket inspections, and fire hydrant flow tests, performed annually, ensure that fire hydrants can perform their intended function and provide opportunities for degradation to be detected before a loss of intended function can occur. Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment: " D. Sprinkler heads are inspected before the end of the 50-year sprinkler head service life and at 10-year intervals thereafter during the extended period of operation to ensure that signs of degradation, such as corrosion, are detected in a timely manner. Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment: 5. Monitoring and Trending A. System discharge pressure is monitored continuously. Results of system performance testing are monitored and trended as specified by the associated plant commitments pertaining to NFPA codes and standards. Degradation identified by non-intrusive or internal inspection is evaluated. Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment:

XI.M27 Fire Water System 5 Program Element Auditable GALL Criteria Documentation of Audit Finding 6. Acceptance Criteria A. The acceptance criteria are (a) the ability of a fire protection system to maintain required pressure, (b) no unacceptable signs of degradation observed during non-intrusive or visual assessment of internal system conditions, and (c) that no biofouling exists in the sprinkler systems that could cause corrosion in the sprinkler heads. Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

Comment: 7. Corrective Actions A. Repair and replacement actions are initiated as necessary. For fire water systems and components identified within scope that are subject to an AMR for license renewal, the applicant's 10 CFR Part 50, Appendix B, program is used for corrective actions, confirmation process, and administrative controls for aging management during the period of extended operation. 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: 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. Water-based fire protection systems designed, inspected, tested and maintained in accordance with the NFPA minimum standards have demonstrated reliable performance. Consistent with GALL AMP:

Yes No Document(s) used to confirm Criteria:

XI.M27 Fire Water System 6 Program Element Auditable GALL Criteria Documentation of Audit Finding Comment:

XI.M27 Fire Water System 7 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. -.