ML061000078

GALL AMP: XI.M38, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (Audit Worksheet GALL Report AMP)

ML061000078
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: ML061000078 (5)

Text

AUDIT WORKSHEET GALL REPORT AMP PLANT: ______________________________

LRA AMP: __________________________ REVIEWER: ______________________

GALL AMP: XI.M38, Inspection of Internal Surfaces in Miscellaneous Piping DATE: __________________________

and Ducting Components Program Auditable GALL Criteria Documentation of Audit Finding Element Program A. The program consists of inspections of the internal surfaces Consistent with GALL AMP: Yes No Description of steel piping, piping components, ducting, and other Document(s) used to confirm Criteria:

components that are not covered by other aging management programs. These internal inspections are performed during the periodic system and component surveillances or during the performance of maintenance activities when the surfaces are Comment:

made accessible for visual inspection. The program includes visual inspections to assure that existing environmental conditions are not causing material degradation that could result in a loss of component intended functions. If visual inspection of internal surfaces is not possible, then the applicant needs to provide a plant-specific program.

1. Scope of A. The program visual inspections include internal surfaces of Consistent with GALL AMP: Yes No Program steel piping, piping elements, ducting, and components in an Document(s) used to confirm Criteria:

internal environment (such as indoor uncontrolled air, condensation, and steam) that are not included in other aging management programs for loss of material. Inspections are performed when the internal surfaces are accessible during the Comment performance of periodic surveillances, during maintenance activities or during scheduled outages. This program includes indication of borated water leakage on internal surfaces.

XI.M38 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components 1

Program Auditable GALL Criteria Documentation of Audit Finding Element

2. Preventive A. This program is an inspection activity independent of Consistent with GALL AMP: Yes No Actions methods to mitigate or prevent degradation. Document(s) used to confirm Criteria:

Comment:

3. Parameters A. Visual inspections of internal surfaces of plant components Consistent with GALL AMP: Yes No Monitored/ are performed during maintenance or surveillance activities. Document(s) used to confirm Criteria:

Inspected Parameters monitored or inspected include visible evidence of corrosion to indicate possible loss of materials.

Comment:

4. Detection of A. Periodic inspections provide for detection of aging effects Consistent with GALL AMP: Yes No Aging Effects prior to the loss of component function. For painted or coated Document(s) used to confirm Criteria:

surfaces, degradation of steel surfaces cannot occur without the degradation of the paint or coating. Confirmation of the integrity of the paint or coating is an effective method for managing the effects of corrosion on the steel surface. The applicant should Comment:

identify and justify the inspection technique used for detecting the aging effects of concern. Locations should be chosen to include conditions likely to exhibit these aging effects.

Inspection intervals are established such that they provide timely detection of degradation.

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. Maintenance and surveillance activities provide for monitoring and trending of aging degradation. Inspection intervals are dependent on component material and environment, and take into consideration industry Comment:

and plant-specific operating experience. Results of the periodic inspections are monitored for indications of various corrosion mechanisms and fouling. The extent and schedule of inspections and testing assure detection of component degradation prior to loss of intended functions.

XI.M38 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components 2

Program Auditable GALL Criteria Documentation of Audit Finding Element

6. Acceptance A. Indications of various corrosion mechanisms or fouling that Consistent with GALL AMP: Yes No Criteria would impact component intended function are reported and will Document(s) used to confirm Criteria:

require further evaluation. The acceptance criteria are established in the maintenance and surveillance procedures or other established plant procedures. If the results are not acceptable, the corrective action program is implemented to Comment:

assess the material condition and determine whether the component intended function is affected.

7. Corrective A. Site corrective actions program, quality assurance (QA) Consistent with GALL AMP: Yes No Actions procedures, site review and approval process, and Document(s) used to confirm Criteria:

administrative controls are implemented in 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 Comment:

actions, confirmation process, and 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. Inspection of internal surfaces during the performance of Consistent with GALL AMP: Yes No Experience periodic surveillances and maintenance activities have been in Document(s) used to confirm Criteria:

effect at many utilities in support of plant components reliability programs. These activities have proven effective in maintaining the material condition of plant systems, structures, and components. Comment:

The elements that comprise these inspections (e.g., the scope XI.M38 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components 3

Program Auditable GALL Criteria Documentation of Audit Finding Element of the inspections and inspection techniques) are consistent with industry practice and staff expectations. However, because the inspection frequency is plant-specific and depends on the plant operating experience, the applicants plant-specific operating experience or applicable generic operating experience is further evaluated for the extended period of operation. The applicant is to evaluate recent operating experience and provide objective evidence to support the conclusion that the effects of aging are adequately managed XI.M38 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components 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.M38 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components 5