ML061000096

2006/03/22-GALL AMP: XI.S1, ASME Section XI, Subsection IWE (Audit Worksheet GALL Report AMP)

ML061000096
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/RLRC, 415-2232
Shared Package
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Download: ML061000096 (9)

Text

AUDIT WORKSHEET GALL REPORT AMP PLANT: ______________________________

LRA AMP: __________________________ REVIEWER: ______________________

GALL AMP: XI.S1, ASME Section XI, Subsection IWE DATE: __________________________

Program Auditable GALL Criteria Documentation of Audit Finding Element Program A. 10 CFR 50.55a imposes the inservice inspection (ISI) Consistent with GALL AMP: Yes No Description requirements of the American Society of Mechanical Engineers Document(s) used to confirm Criteria:

(ASME) Boiler and Pressure Vessel (B&PV) Code,Section XI, Subsection IWE for steel containments (Class MC) and steel liners for concrete containments (Class CC). The full scope of IWE includes steel containment shells and their integral Comment:

attachments; steel liners for concrete containments and their integral attachments; containment hatches and airlocks; seals, gaskets and moisture barriers; and pressure-retaining bolting.

This evaluation covers the 2001 edition (an applicant may rely on a different version of the ASME B&PVC, but should justify such use; an applicant may wish to refer to the SOC for an update of 10CFR 50.55a to justify the use of a more recent edition of the ASME B&PVC) including the 2002 and 2003 Addenda, as approved in 10 CFR 50.55a. ASME Code Section XI, Subsection IWE and the additional requirements specified in 10 CFR 50.55a(b)(2) constitute an existing mandated program applicable to managing aging of steel containments, steel liners of concrete containments, and other containment components for license renewal.

The primary ISI method specified in IWE is visual examination (general visual, VT-3, VT-1). Limited volumetric examination (ultrasonic thickness measurement) and surface examination (e.g., liquid penetrant) may also be necessary in some XI.S1 ASME Section XI, Subsection IWE 1

Program Auditable GALL Criteria Documentation of Audit Finding Element instances. Bolt preload is checked by either a torque or tension test. IWE specifies acceptance criteria, corrective actions, and expansion of the inspection scope when degradation exceeding the acceptance criteria is found.

The evaluation of 10 CFR 50.55a and Subsection IWE as an aging management program (AMP) for license renewal is provided below

1. Scope of A. Subsection IWE-1000 specifies the components of steel Consistent with GALL AMP: Yes No Program containments and steel liners of concrete containments within Document(s) used to confirm Criteria:

its scope. The components within the scope of Subsection IWE are Class MC pressure-retaining components (steel containments) and their integral attachments; metallic shell and penetration liners of Class CC containments and their integral Comment:

attachments; containment seals and gaskets; containment pressure-retaining bolting; and metal containment surface areas, including welds and base metal. The concrete portions of containments are inspected in accordance with Subsection IWL.

B. Subsection IWE exempts the following from examination: Consistent with GALL AMP: Yes No (1) Components that are outside the boundaries of the Document(s) used to confirm Criteria:

containment as defined in the plant-specific design specification; (2) Embedded or inaccessible portions of containment components that met the requirements of the original construction code of record; Comment:

(3) Components that become embedded or inaccessible as a result of vessel repair or replacement, provided IWE-1232 and IWE-5220 are met; and (4) Piping, pumps, and valves that are part of the containment system or that penetrate or are attached to the containment vessel (governed by IWB or IWC).

XI.S1 ASME Section XI, Subsection IWE 2

Program Auditable GALL Criteria Documentation of Audit Finding Element C. 10 CFR 50.55a(b)(2)(ix) specifies additional requirements for Consistent with GALL AMP: Yes No inaccessible areas. It states that the licensee is to evaluate the Document(s) used to confirm Criteria:

acceptability of inaccessible areas when conditions exist in accessible areas that could indicate the presence of or result in degradation to such inaccessible areas. Examination requirements for containment supports are not within the scope Comment:

of Subsection IWE.

2. Preventive A. No preventive actions are specified; Subsection IWE is a Consistent with GALL AMP: Yes No Actions monitoring program. Document(s) used to confirm Criteria:

Comment:

3. Parameters A. Table IWE-2500-1 specifies seven categories for Consistent with GALL AMP: Yes No Monitored/ examination. The categories, parts examined, and examination Document(s) used to confirm Criteria:

Inspected methods are presented in a table that is located at the GALL Report, XI.S1, ASME,Section XI, Subsection IWE. The first six examination categories (E-A through E-G) constitute the ISI requirements of IWE. Examination category E-P references Comment:

10 CFR Part 50, Appendix J leak rate testing. Appendix J leak rate testing is evaluated as a separate AMP for license renewal in XI.S4.

Table IWE-2500-1 references the applicable section in IWE-3500 that identifies the aging effects that are evaluated. The parameters monitored or inspected depend on the particular examination category. For Examination Category E-A, as an example, metallic surfaces (without coatings) are examined for evidence of cracking, discoloration, wear, pitting, excessive corrosion, arc strikes, gouges, surface discontinuities, dents, and other signs of surface irregularities. For Examination Category E-D, seals, gaskets, and moisture barriers are examined for wear, damage, erosion, tear, surface cracks, or other defects that may violate the leak-tight integrity.

4. Detection of A. The frequency and scope of examination specified in Consistent with GALL AMP: Yes No XI.S1 ASME Section XI, Subsection IWE 3

Program Auditable GALL Criteria Documentation of Audit Finding Element Aging Effects 10 CFR 50.55a and Subsection IWE ensure that aging effects Document(s) used to confirm Criteria:

would be detected before they would compromise the design-basis requirements. As indicated in IWE-2400, inservice examinations and pressure tests are performed in accordance with one of two inspection programs, A or B, on a specified Comment:

schedule. Under Inspection Program A, there are four inspection intervals (at 3, 10, 23, and 40 years) for which 100%

of the required examinations must be completed. Within each interval, there are various inspection periods for which a certain percentage of the examinations are to be performed to reach 100% at the end of that interval. In addition, a general visual examination is performed once each inspection period. After 40 years of operation, any future examinations will be performed in accordance with Inspection Program B. Under Inspection Program B, starting with the time the plant is placed into service, there is an initial inspection interval of 10 years and successive inspection intervals of 10 years each, during which 100% of the required examinations are to be completed. An expedited examination of containment is required by 10 CFR 50.55a in which an inservice (baseline) examination specified for the first period of the first inspection interval for containment is to be performed by September 9, 2001. Thereafter, subsequent examinations are performed every 10 years from the baseline examination. Regarding the extent of examination, all accessible surfaces receive a visual examination such as General Visual, VT-1, or VT-3 (see table in item 3 above). IWE-1240 requires augmented examinations (Examination Category E-C) of containment surface areas subject to degradation. A VT-1 visual examination is performed for areas accessible from both sides, and volumetric (ultrasonic thickness measurement) examination is performed for areas accessible from only one side.

5. Monitoring A. With the exception of inaccessible areas, all surfaces are Consistent with GALL AMP: Yes No and Trending monitored by virtue of the examination requirements on a Document(s) used to confirm Criteria:

XI.S1 ASME Section XI, Subsection IWE 4

Program Auditable GALL Criteria Documentation of Audit Finding Element scheduled basis. When component examination results require evaluation of flaws, evaluation of areas of degradation, or repairs, and the component is found to be acceptable for continued service, the areas containing such flaws, degradation, Comment:

or repairs shall be reexamined during the next inspection period, in accordance with Examination Category E-C. When these reexaminations reveal that the flaws, areas of degradation, or repairs remain essentially unchanged for three consecutive inspection periods, these areas no longer require augmented examination in accordance with Examination Category E-C.

B. IWE-2430 specifies that (a) examinations performed during Consistent with GALL AMP: Yes No any one inspection that reveal flaws or areas of degradation Document(s) used to confirm Criteria:

exceeding the acceptance standards are to be extended to include an additional number of examinations within the same category approximately equal to the initial number of examinations, and (b) when additional flaws or areas of Comment:

degradation that exceed the acceptance standards are revealed, all of the remaining examinations within the same category are to be performed to the extent specified in Table IWE-2500-1 for the inspection interval. Alternatives to these examinations are provided in 10 CFR 50.55a(b)(2)(ix)(D).

6. Acceptance A. IWE-3000 provides acceptance standards for components of Consistent with GALL AMP: Yes No Criteria steel containments and liners of concrete containments. Table Document(s) used to confirm Criteria:

IWE-3410-1 presents criteria to evaluate the acceptability of the containment components for service following the preservice examination and each inservice examination. This table specifies the acceptance standard for each examination Comment:

category. Most of the acceptance standards rely on visual examinations. Areas that are suspect require an engineering evaluation or require correction by repair or replacement. For some examinations, such as augmented examinations, numerical values are specified for the acceptance standards.

For the containment steel shell or liner, material loss exceeding 10% of the nominal containment wall thickness, or material loss XI.S1 ASME Section XI, Subsection IWE 5

Program Auditable GALL Criteria Documentation of Audit Finding Element that is projected to exceed 10% of the nominal containment wall thickness before the next examination, are documented. Such areas are to be accepted by engineering evaluation or corrected by repair or replacement in accordance with IWE-3122.

7. Corrective A. Subsection IWE states that components whose examination Consistent with GALL AMP: Yes No Actions results indicate flaws or areas of degradation that do not meet Document(s) used to confirm Criteria:

the acceptance standards listed in Table-3410-1 are acceptable if an engineering evaluation indicates that the flaw or area of degradation is nonstructural in nature or has no effect on the structural integrity of the containment. Except as permitted by Comment:

10 CFR 50.55a(b)(ix)(D), components that do not meet the acceptance standards are subject to additional examination requirements, and the components are repaired or replaced to the extent necessary to meet the acceptance standards of IWE-3000. For repair of components within the scope of Subsection IWE, IWE-3124 states that repairs and reexaminations are to comply with IWA-4000. IWA-4000 provides repair specifications for pressure retaining components including metal containments and metallic liners of concrete containments. 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.

8. A. When areas of degradation are identified, an evaluation is Consistent with GALL AMP: Yes No Confirmation performed to determine whether repair or replacement is Document(s) used to confirm Criteria:

Process necessary. If the evaluation determines that repair or replacement is necessary, Subsection IWE specifies confirmation that appropriate corrective actions have been completed and are effective. Subsection IWE states that repairs Comment:

and reexaminations are to comply with the requirements of IWA-4000. Reexaminations are conducted in accordance with the requirements of IWA-2200, and the recorded results are to demonstrate that the repair meets the acceptance standards set forth in Table IWE-3410-1. As discussed in the appendix to this report, the staff finds the requirements of 10 CFR Part 50, XI.S1 ASME Section XI, Subsection IWE 6

Program Auditable GALL Criteria Documentation of Audit Finding Element Appendix B, acceptable to address the confirmation process.

9. A. IWA-6000 provides specifications for the preparation, Consistent with GALL AMP: Yes No Administrative submittal, and retention of records and reports. As discussed in Document(s) used to confirm Criteria:

Controls the appendix to this report, the staff finds the requirements of 10 CFR Part 50, Appendix B, acceptable to address administrative controls.

Comment:

10. Operating A. ASME Section XI, Subsection IWE, was incorporated into Consistent with GALL AMP: Yes No Experience 10 CFR 50.55a in 1996. Prior to this time, operating experience Document(s) used to confirm Criteria:

pertaining to degradation of steel components of containment was gained through the inspections required by 10 CFR Part 50, Appendix J and ad hoc inspections conducted by licensees and the Nuclear Regulatory Commission (NRC). NRC Information Comment:

Notice (INs) 86-99, 88-82 and 89-79 described occurrences of corrosion in steel containment shells. NRC Generic Letter (GL) 87-05 addressed the potential for corrosion of boiling water reactor (BWR) Mark I steel drywells in the sand pocket region.

More recently, NRC IN 97-10 identified specific locations where concrete containments are susceptible to liner plate corrosion.

The program is to consider the liner plate and containment shell corrosion concerns described in these generic communications.

Implementation of the ISI requirements of Subsection IWE, in accordance with 10 CFR 50.55a, is a necessary element of aging management for steel components of steel and concrete containments through the period of extended operation.

XI.S1 ASME Section XI, Subsection IWE 7

EXCEPTIONS Item Program Elements LRA Exception Description Basis for Accepting Exception Documents Reviewed Number (Identifier, Para.# and/or Page #)

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ENHANCEMENTS Item Program Elements LRA Enhancement Description Basis for Accepting Enhancement Documents Reviewed Number (Identifier, Para.# and/or Page #)

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2.

Document Reviewed During Audit DOCUMENT NUMBER IDENTIFIER (NUMBER) TITLE REVISION AND/OR DATE 1.

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4.

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XI.S1 ASME Section XI, Subsection IWE 8