ML060950347

2006/03/22-GALL AMP: XI.M11A, Nickel Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors

ML060950347
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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References
%dam200611, TAC MC9668
Download: ML060950347 (10)

Text

AUDIT WORKSHEET GALL REPORT AMP PLANT: ______________________________

LRA AMP: __________________________ REVIEWER: ______________________

GALL AMP: XI.M11A, Nickel Alloy Penetration Nozzles Welded to the Upper DATE: __________________________

Reactor Vessel Closure Heads of Pressurized Water Reactors Program Auditable GALL Criteria Documentation of Audit Finding Element Program A. This program is established to ensure that augmented Consistent with GALL AMP: Yes No Description inservice inspections (ISI) of all nickel-alloy vessel head Document(s) used to confirm Criteria:

penetration (VHP) nozzles welded to the upper reactor vessel (RV) head of a PWR-designed light-water reactor will continue to be performed as mandated by the interim requirements in Order EA-03-009, Issuance of Order Establishing Interim Comment:

Inspection Requirements for Reactor Pressure Vessel Heads at Pressurized Water Reactors (PWRs), as amended by the First Revision of the Order, or by any subsequent NRC requirements that may be established to supersede the requirements of Order EA-03-009. Since 1997, the Nuclear Regulatory Commission (NRC) has issued a number of generic communications on the topic of primary water stress corrosion cracking (PWSCC) in upper VHP nozzles. These generic communications included issuance of NRC Generic Letter (GL) 97-01, Bulletin 2001-01, Bulletin 2002-01, and Bulletin 2002-02. In response to its reviews of the industrys responses to these generic communications, the staff determined that PWSCC-induced cracking of upper VHP nozzles was a significant safety issue for operating PWRs that warranted issuance of an NRC Order for augmented inspection of PWR upper VHP nozzles and upper RV heads. On February 11, 2003, the Commission issued Order EA-03-009 to all holders of PWR operating licenses. Order EA-03-009 was issued in accordance with the regulatory bases and XI.M11A Nickel Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of PWRs 1

Program Auditable GALL Criteria Documentation of Audit Finding Element requirements of 10 CFR 2.202 and the adequate protection backfit provisions of 10 CFR 50.109. In this Order, the NRC required specific augmented inspections of reactor vessel closure heads and the associated nickel-alloy penetration nozzles in U.S. PWRs. The NRC issued the First Revised Order EA-03-009 on February 20, 2004, to clarify which locations of the PWR vessel head penetration nozzles were applicable to the requirements of the Order. All PWR licensees in the U.S.

were required to submit 20-day and 60-day responses to Order EA-03-009 and to First Revised Order EA-03-009 (henceforth referred to in this document collectively as the Order, as amended). The Order, as amended, established a mandated augmented inspection process for upper VHP nozzles and upper RV heads that supplements the leakage tests and visual VT-2 examinations requirements established in Section XI of the ASME Boiler and Pressure Vessel Code, Table IWB-2500-1, Examination Category B-P. The interim requirements of the Order, as amended, also established the NRCs required technical method for calculating the susceptibility ranking of a plants upper VHP nozzles to PWSCC and a required process for establishing the inspection methods and inspection frequencies for a plants VHP nozzles in accordance with its susceptibility ranking.

1. Scope of A. The program is focused on managing the effects of cracking Consistent with GALL AMP: Yes No Program due to PWSCC of the nickel-alloy used in the fabrication of the Document(s) used to confirm Criteria:

upper VHP nozzles at PWR-designed nuclear facilities. The scope of this AMP is limited to upper VHP nozzles, including control rod drive mechanism (CRDM) nozzles, control element drive mechanism (CEDM) nozzles, thermocouples (TC) nozzles, Comment in-core instrumentation (ICI) nozzles, and vent line nozzles; associated J-groove welds; and the adjoining upper RV closure head.

XI.M11A Nickel Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of PWRs 2

Program Auditable GALL Criteria Documentation of Audit Finding Element

2. Preventive A. Preventive measures to mitigate PWSCC are in accordance Consistent with GALL AMP: Yes No Actions with PWR water chemistry guidelines for primary coolant Document(s) used to confirm Criteria:

systems, as established in EPRI Topical Report TR-105714 (applicants for license renewal may credit the version of the report on record at the facility at the time of submittal of its application). The program description and the evaluation and Comment:

technical basis of monitoring and maintaining reactor coolant water chemistry are presented in Chapter XI.M2, "Water Chemistry.

3. Parameters A. The program monitors for cracking/PWSCC and loss of Consistent with GALL AMP: Yes No Monitored/ material/wastage in the upper VHP nozzles to ensure the Document(s) used to confirm Criteria:

Inspected structural integrity of the VHP nozzles prior to a loss of their intended safety function.

Comment:

B. The program also monitors for evidence of reactor coolant Consistent with GALL AMP: Yes No leakage as a result of through-wall cracks that may exist in the Document(s) used to confirm Criteria:

upper VHP nozzles or their associated partial penetration J-groove welds. Evidence of reactor coolant leakage may manifest itself in the form of boric acid residues on the upper RV head or adjacent components or in the form of corrosion Comment:

products that result from rusting of the low-alloy steel materials used to fabricate the RVs.

4. Detection of A. Implementation of inspections required by the Order, as Consistent with GALL AMP: Yes No Aging Effects amended, or any subsequent NRC requirements, as applicable, Document(s) used to confirm Criteria:

assures detection of cracks in the upper VHP nozzles and any loss of material/wastage of the upper RV head prior to a loss of intended function of the components. Detection of cracking (including those induced by PWSCC) is accomplished through Comment:

implementation of a combination of bare-metal visual examination and/or non-visual examination techniques, as discussed in the Order, as amended. Bare-metal visual examinations required by the Order, as amended, are used to detect reactor coolant leakage from the VHP nozzles or their XI.M11A Nickel Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of PWRs 3

Program Auditable GALL Criteria Documentation of Audit Finding Element associated J-groove welds and for any loss of material that may be induced as a result of boric-acid wastage.

B. Non-visual examination techniques required by the Order, as Consistent with GALL AMP: Yes No amended, are also used to detect these aging effects and are Document(s) used to confirm Criteria:

performed using either surface examination techniques (eddy current or penetrant testing) or volumetric examination techniques (ultrasonic testing).

Comment:

C. The specific types of examinations to be implemented are Consistent with GALL AMP: Yes No dependent on a plants susceptibility ranking for its VHP Document(s) used to confirm Criteria:

nozzles. Inspection methods selected for examination are implemented in accordance with appropriate inspection requirements of Section IV.C of the Order, as amended, as applicable for a plants susceptibility ranking (i.e., in accordance Comment:

with the appropriate inspection methods mandated for Low, Moderate, High, or Replaced susceptibility category plants).

Any deviations from implementing the appropriate required inspection methods of the Order, as amended, will be submitted for NRC review and approval in accordance with the Order, as amended.

5. Monitoring A. As required by the Order, as amended, inspection schedules Consistent with GALL AMP: Yes No and Trending and frequencies for the applicants VHP nozzles are Document(s) used to confirm Criteria:

implemented in accordance with required frequencies for the plants susceptibility category (i.e., in accordance with the specific inspection frequencies required for Low, Moderate, High, or Replaced susceptibility categories, as based on the Comment:

total effective degradation years). Any deviations from implementing the required inspection frequencies mandated by XI.M11A Nickel Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of PWRs 4

Program Auditable GALL Criteria Documentation of Audit Finding Element the Order, as amended, will be submitted for NRC review and approval in accordance with the Order, as amended.

Disposition of flaw indications detected during required examinations is implemented in accordance with the Acceptance Criteria and Corrective Actions Program attributes of this AMP.

6. Acceptance A. Relevant flaw indications detected as a result of the Consistent with GALL AMP: Yes No Criteria augmented inspections of the upper VHP nozzles are to be Document(s) used to confirm Criteria:

evaluated in accordance with acceptable law evaluation criteria provided in a letter from Mr. Richard Barrett, NRC, Office of Nuclear Reactor Regulation (NRR), Division of Engineering to Alex Marion, Nuclear Energy Institute (NEI), dated April 11, Comment:

2003, or in accordance with NRC-approved Code Cases that incorporate the flaw evaluation procedures and criteria of the NRCs April 11, 2003, letter to NEI.

7. Corrective A. Relevant flaw indications in the upper VHP nozzles or their Consistent with GALL AMP: Yes No Actions associated nickel-alloy J-groove weld materials are Document(s) used to confirm Criteria:

unacceptable for further service and are corrected through implementation of appropriate repair or replacement activities.

Comment:

B. In addition, detection of leakage or evidence of cracking in Consistent with GALL AMP: Yes No the VHP nozzles (including associated J-groove welds) of plants Document(s) used to confirm Criteria:

ranked in the Low, Moderate, or Replaced susceptibility categories requires that the plants VHP nozzles be immediately reclassified to the High susceptibility category and that the required augmented inspections for High susceptibility VHP Comment:

nozzles be implemented, commencing from the same outage in which the leakage or cracking was detected. Repair and replacement procedures and activities either must comply with ASME Section XI, as invoked by the requirements of 10 CFR 50.55a, or conform with applicable ASME Code Cases that have been endorsed in 10 CFR 50.55a by reference in the latest version of NRC Regulatory Guide 1.147. Alternative XI.M11A Nickel Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of PWRs 5

Program Auditable GALL Criteria Documentation of Audit Finding Element repair/replacement activities suggested instead of those endorsed by the NRC in either Section XI or NRC-approved Code Cases must be requested for NRC approval in accordance with either the acceptable alternative provisions of 10 CFR 50.55a(a)(3)(i) or hardship provisions of 10 CFR 50.55a(a)(3)(ii).

8. A. Site quality assurance (QA) procedures, review and approval Consistent with GALL AMP: Yes No Confirmation processes are implemented in accordance with the Document(s) used to confirm Criteria:

Process 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, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, Comment:

acceptable to address confirmation process and administrative controls.

9. A. See Item 8, above. Consistent with GALL AMP: Yes No Administrative Document(s) used to confirm Criteria:

Controls Comment:

10. Operating A. PWSCC is occurring in the VHP nozzles of U.S. PWRs, as Consistent with GALL AMP: Yes No Experience described in the program description above. In addition, Document(s) used to confirm Criteria:

applicants for license renewal should reference plant-specific operating experience that is applicable to PWSCC of its VHP nozzles.

Comment:

XI.M11A Nickel Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of PWRs 6

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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DOCUMENT REVIEWED DURING AUDIT Document Number Identifier (number) Title Revision and/or Date 1.

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XI.M11A Nickel Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of PWRs 7