ML061000116
| ML061000116 | |
| 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 | |
| ML060950189 | List:
|
| References | |
| %dam200611, TAC MC9668 | |
| Download: ML061000116 (5) | |
Text
AUDIT WORKSHEET GALL REPORT AMP PLANT: ______________________________
LRA AMP: __________________________ REVIEWER: ______________________
GALL AMP: XI.S3, ASME Section XI, Subsection IWF 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 Code,Section XI, for Class 1, 2, 3, and MC piping and components and their associated supports. Inservice inspection of supports for ASME piping and components is addressed in Section XI, Subsection IWF. This Comment:
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 IWF constitutes an existing mandated program applicable to managing aging of ASME Class 1, 2, 3, and MC supports for license renewal.
The IWF scope of inspection for supports is based on sampling of the total support population. The sample size varies depending on the ASME Class. The largest sample size is specified for the most critical supports (ASME Class 1). The sample size decreases for the less critical supports (ASME Class 2 and 3). Discovery of support deficiencies during regularly scheduled inspections triggers an increase of the inspection scope, in order to ensure that the full extent of deficiencies is identified. The primary inspection method XI.S3 ASME Section XI, Subsection IWF 1
Program Auditable GALL Criteria Documentation of Audit Finding Element employed is visual examination. Degradation that potentially compromises support function or load capacity is identified for evaluation. IWF specifies acceptance criteria and corrective actions. Supports requiring corrective actions are re-examined during the next inspection period.
The evaluation of Subsection IWF as an aging management program (AMP) for license renewal is provided below.
- 1. Scope of A. For Class 1 piping and component supports, Subsection IWF Consistent with GALL AMP: Yes No Program (1989 edition) refers to Subsection IWB for the inspection scope Document(s) used to confirm Criteria:
and schedule. According to Table IWB-2500-1, only 25% of nonexempt supports are subject to examination. Supports exempt from examination are the supports for piping systems that are exempt from examination, according to pipe diameter or Comment:
service. The same supports are inspected in each 10-year inspection interval. For Class 2, 3, and MC piping and component supports, Subsection IWF (1989 edition) refers to Subsections IWC, IWD, and IWE for the inspection scope and schedule. According to Table IWC-2500-1, 7.5% of nonexempt supports are subject to examination for Class 2 systems. The same supports are inspected in each 10-year inspection interval. No specific numerical percentages are identified in Subsections IWD and IWE for Class 3 and Class MC, respectively.
Starting with the 1990 addenda, the scope of Subsection IWF was revised. The required percentages of each type of nonexempt support subject to examination were incorporated into Table IWF-2500-1. The revised percentages are 25% of Class 1 nonexempt piping supports, 15% of Class 2 nonexempt piping supports, 10% of Class 3 nonexempt piping supports, and 100% of supports other than piping supports (Class 1, 2, 3, and MC). For pipe supports, the total sample consists of supports from each system (such as main steam, feedwater, residual heat removal), where the individual sample sizes are proportional to the total number of nonexempt supports of each XI.S3 ASME Section XI, Subsection IWF 2
Program Auditable GALL Criteria Documentation of Audit Finding Element type and function within each system. For multiple components other than piping, within a system of similar design, function, and service, the supports of only one of the multiple components are required to be examined. To the extent practical, the same supports selected for examination during the first inspection interval are examined during each successive inspection interval.
- 2. Preventive A. No preventive actions are specified; Subsection IWF is an Consistent with GALL AMP: Yes No Actions inspection program. Document(s) used to confirm Criteria:
Comment:
- 3. Parameters A. IWF specifies visual examination (VT-3) of supports. The Consistent with GALL AMP: Yes No Formatted: Bullets and Numbering Monitored/ parameters monitored or inspected include corrosion; Document(s) used to confirm Criteria:
Inspected deformation; misalignment; improper clearances; improper spring settings; damage to close tolerance machined or sliding surfaces; and missing, detached, or loosened support items.
The visual inspection would be expected to identify relatively Comment:
large cracks.
Table IWF-2500-1 (1989 edition) specifies examination of the following.
(F1.10) Mechanical connections to pressure-retaining components and building structure; (F1.20) Weld connections to building structure; (F1.30) Weld and mechanical connections at intermediate joints in multi-connected integral and nonintegral supports; (F1.40) Clearances of guides and stops, alignment of supports, and assembly of support items; (F1.50) Spring supports and constant load supports; (F1.60) Sliding surfaces; (F1.70) Hot or cold position of spring supports and constant load supports.
(Starting with the 1990 addenda, these items are listed in XI.S3 ASME Section XI, Subsection IWF 3
Program Auditable GALL Criteria Documentation of Audit Finding Element paragraph IWF-2500.)
- 4. Detection of A. VT-3 visual examination is specified in Table IWF-2500-1. Consistent with GALL AMP: Yes No Aging Effects The complete inspection scope is repeated every 10-year Document(s) used to confirm Criteria:
inspection interval. The qualified VT-3 inspector uses judgment in assessing general corrosion; observed degradation is documented if loss of structural capacity is suspected.
Comment:
- 5. Monitoring A. There is no requirement to monitor or report progressive, Consistent with GALL AMP: Yes No and Trending time-dependent degradation. Unacceptable conditions, Document(s) used to confirm Criteria:
according to IWF-3400, are noted for correction or further evaluation.
Comment:
- 6. Acceptance A. The acceptance standards for visual examination are Consistent with GALL AMP: Yes No Formatted: Bullets and Numbering Criteria specified in IWF-3400. In IWF-3410(b)(5), "roughness or Document(s) used to confirm Criteria:
general corrosion which does not reduce the load bearing capacity of the support" is given as an example of a "non-relevant condition, which requires no further action. IWF-3410(a) identifies the following conditions as unacceptable. Comment:
(i) deformations or structural degradations of fasteners, springs, clamps, or other support items; (ii) missing, detached, or loosened support items; (iii) arc strikes, weld spatter, paint, scoring, roughness, or general corrosion on close tolerance machined or sliding surfaces; (iv) improper hot or cold positions of spring supports and constant load supports; (v) misalignment of supports; (vi) improper clearances of guides and stops.
Identification of unacceptable conditions triggers an expansion of the inspection scope, in accordance with IWF-2430, and reexamination of the supports requiring corrective actions during the next inspection period, in accordance with IWF-2420(b).
- 7. Corrective A. In accordance with IWF-3122, supports containing Consistent with GALL AMP: Yes No XI.S3 ASME Section XI, Subsection IWF 4
Program Auditable GALL Criteria Documentation of Audit Finding Element Actions unacceptable conditions are evaluated or tested, or corrected Document(s) used to confirm Criteria:
before returning to service. Corrective actions are delineated in IWF-3122.2. IWF-3122.3 provides an alternative for evaluation or testing, to substantiate structural integrity and/or functionality.
As discussed in the appendix to this report, the staff finds the Comment:
requirements of 10 CFR Part 50, Appendix B, acceptable to address the corrective actions.
- 8. A. As discussed in the appendix to this report, the staff finds the Consistent with GALL AMP: Yes No Confirmation requirements of 10 CFR Part 50, Appendix B, acceptable to Document(s) used to confirm Criteria:
Process address the confirmation process.
Comment:
- 9. A. As discussed in the appendix to this report, the staff finds the Consistent with GALL AMP: Yes No Administrative requirements of 10 CFR Part 50, Appendix B, acceptable to Document(s) used to confirm Criteria:
Controls address the administrative controls.
Comment:
- 10. Operating A. To date, IWF sampling inspections have been effective in Consistent with GALL AMP: Yes No Experience managing aging effects for ASME Class 1, 2, 3, and MC Document(s) used to confirm Criteria:
supports. There is reasonable assurance that the Subsection IWF inspection program will be effective through the period of extended operation.
Comment:
XI.S3 ASME Section XI, Subsection IWF 5
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.S3 ASME Section XI, Subsection IWF 6