ML060950637

GALL AMP: XI.M36, External Surfaces Monitoring (Audit Worksheet GALL Report AMP)

ML060950637
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: ML060950637 (5)

Text

AUDIT WORKSHEET GALL REPORT AMP PLANT: ______________________________

LRA AMP: __________________________ REVIEWER: ______________________

GALL AMP: XI.M36, External Surfaces Monitoring DATE: __________________________

Program Auditable GALL Criteria Documentation of Audit Finding Element Program A. The External Surfaces Monitoring program is based on Consistent with GALL AMP: Yes No Description system inspections and walkdowns. This program consists of Document(s) used to confirm Criteria:

periodic visual inspections of steel components such as piping, piping components, ducting, and other components within the scope of license renewal and subject to AMR in order to manage aging effects. The program manages aging effects Comment:

through visual inspection of external surfaces for evidence of material loss. Loss of material due to boric acid corrosion is managed by the Boric Acid Corrosion Program.

1. Scope of A. This program visually inspects the external surface of in- Consistent with GALL AMP: Yes No Program scope components and monitors external surfaces of steel Document(s) used to confirm Criteria:

components in systems within the scope of license renewal and subject to AMR for loss of material and leakage. Visual inspections are expected to identify loss of material due to general corrosion in accessible steel components. Loss of Comment material due to pitting and crevice corrosion may not be detectable through these same visual inspections, however, general corrosion is expected to be present and detectable such that, should pitting and crevice corrosion exist, general corrosion will manifest itself as visible rust or rust byproducts (e.g., discoloration or coating degradation) and be detectable prior to any loss of intended function. Therefore, this program is acceptable for use in inspecting for loss of material for general, pitting and crevice corrosion.

B. Surfaces that are inaccessible or not readily visible during Consistent with GALL AMP: Yes No XI.M36 External Surfaces Monitoring 1

Program Auditable GALL Criteria Documentation of Audit Finding Element plant operations are inspected during refueling outages. Document(s) used to confirm Criteria:

Surfaces that are inaccessible or not readily visible during both plant operations and refueling outages are inspected at such intervals that would provide reasonable assurance that the effects of aging will be managed such that applicable Comment:

components will perform their intended function during the period of extended operation.

Surfaces that are insulated may be inspected when the external surface is exposed (i.e., maintenance) at such intervals that would provide reasonable assurance that the effects of aging will be managed such that applicable components will perform their intended function during the period of extended operation.

C. The program may also be credited with managing loss of Consistent with GALL AMP: Yes No material from internal surfaces, for situations in which material Document(s) used to confirm Criteria:

and environment combinations are the same for internal and external surfaces such that external surface condition is representative of internal surface condition. When credited, the program should describe the component internal environment Comment:

and the credited similar external component environment inspected.

2. Preventive A. The External Surfaces Monitoring Program is a visual Consistent with GALL AMP: Yes No Actions monitoring program that does not include preventive actions. Document(s) used to confirm Criteria:

Comment:

3. Parameters A. The External Surfaces Monitoring Program utilizes periodic Consistent with GALL AMP: Yes No Monitored/ plant system inspections and walkdowns to monitor for material Document(s) used to confirm Criteria:

Inspected degradation and leakage. This program inspects components such as piping, piping components, ducting and other components. Coatings deterioration is an indicator of possible underlying degradation. Comment:

Examples of inspection parameters include:

• corrosion and material wastage (loss of material);

XI.M36 External Surfaces Monitoring 2

Program Auditable GALL Criteria Documentation of Audit Finding Element

• leakage from or onto external surfaces;

• worn, flaking, or oxide-coated surfaces;

• corrosion stains on thermal insulation;

• protective coating degradation (cracking and flaking)

4. Detection of A. Degradation of steel surfaces cannot occur without the Consistent with GALL AMP: Yes No Aging Effects degradation of the paint or coating. Confirmation of the integrity Document(s) used to confirm Criteria:

of the paint or coating is an effective method for managing the effects of corrosion on the steel surface. A visual inspection is conducted for component surfaces at least once per refueling cycle. This frequency accommodates inspections of Comment:

components that may be in locations that are normally only accessible during outages. System walkdowns are normally performed on a frequency that exceeds once per fuel cycle.

Surfaces that are inaccessible or not readily visible during plant operations and refueling outages are inspected at such intervals that would ensure the components intended function is maintained. The intervals of inspections may be adjusted as necessary based on plant-specific inspection results and industry experience.

This program is credited with managing the loss of material for external surfaces and the loss of material for internal surfaces exposed to the same environment as the external surface.

5. Monitoring A. Visual inspection activities are performed and associated Consistent with GALL AMP: Yes No and Trending personnel are qualified in accordance with site controlled Document(s) used to confirm Criteria:

procedures and processes. The External Surfaces Monitoring Program uses standardized monitoring and trending activities to track degradation. Deficiencies are documented using approved processes and procedures such that results can be trended. Comment:

However, the program does not include formal trending.

Inspections are performed at frequencies identified in Detection of Aging Effects.

XI.M36 External Surfaces Monitoring 3

Program Auditable GALL Criteria Documentation of Audit Finding Element

6. Acceptance A. For each component/aging effect combination, the Consistent with GALL AMP: Yes No Criteria acceptance criteria are defined to ensure that the need for Document(s) used to confirm Criteria:

corrective actions will be identified before loss of intended functions. Acceptance criteria include design standards, procedural requirements, current licensing basis, industry codes or standards, and engineering evaluation. Comment:

7. Corrective A. Site quality assurance (QA) procedures, review and approval Consistent with GALL AMP: Yes No Actions processes, and administrative controls are implemented in Document(s) used to confirm Criteria:

accordance with the 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, acceptable to address the corrective actions, confirmation process, and Comment:

administrative controls.

8. A. See Item 7, above. Consistent with GALL AMP: Yes No Confirmation Document(s) used to confirm Criteria:

Process Comment:

9. A. See Item 7, above. Consistent with GALL AMP: Yes No Administrative Document(s) used to confirm Criteria:

Controls Comment:

10. Operating A. External surfaces inspections via system inspections and Consistent with GALL AMP: Yes No Experience walkdowns have been in effect at many utilities since the mid Document(s) used to confirm Criteria:

1990's in support of the Maintenance Rule (10 CFR 50.65) and have proven effective in maintaining the material condition of plant systems. The elements that comprise these inspections (e.g., the scope of the inspections and inspection techniques) Comment:

are consistent with industry practice.

XI.M36 External Surfaces Monitoring 4

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

1.

2.

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

1.

2.

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

2.

3.

4.

XI.M36 External Surfaces Monitoring 5