Information Notice 1997-16, Preconditioning of Plant Structures, Systems, and Components Before ASME Code Inservice Testing or Technical Specification Surveillance Testing
II
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
WASHINGTON, D.C. 20555-0001
April 4,1997
NRC INFORMATION NOTICE 97-16: PRECONDITIONING OF PLANT STRUCTURES,
SYSTEMS, AND COMPONENTS BEFORE ASME
CODE INSERVICE TESTING OR TECHNICAL
SPECIFICATION SURVEILLANCE TESTING
Addressees
All holders of operating licenses or construction permits for nuclear power reactors.
Purpose
The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice to alert
addressees to the potential for maintenance activities performed before surveillance testing
('preconditioning" or "grooming") to adversely affect the validity of the surveillance test results
for structures, systems, and components (SSCs or equipment). It is expected that recipients
will review the information for applicability to their facilities and consider actions, as
appropriate, to avoid similar problems. However, suggestions contained in this information
notice are not NRC requirements; therefore, no specific action or written response is
required.
Background
The NRC has had a longstanding concern about unacceptable preconditioning or grooming of
various SSCs before the performance of Technical Specification (TS) surveillance tests or
testing required by the American Society of Mechanical Engineers Boiler and Pressure
Vessel Code (the ASME Code) and the adverse effect such activity might have on the validity
of the test results.
Description of Circumstances
In recent years, inspection findings and notices of violation have revealed that licensees are
performing unacceptable preconditioning activities. The following examples are summaries of
inspection findings; additional details on each example can be found in the referenced
inspection reports.
Circuit Breakers
NRC Inspection Report (IR) 50-298/94-16 (Accession No. 9409150141) for Cooper Nuclear
Station identified that electrical loads were removed from a number of 480-volt circuit
breakers before surveillance testing was.performed. The NRC staff identified this as an
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IN 97-16 April 4, 1997 example of unacceptable preconditioning, a concern addressed in NRC Confirmatory Action
Letter issued on July 1, 1994. This concern formed part of the basis for a Severity Level IlIl
violation of 10 CFR Part 50, Appendix B, Criterion Xl, 'Test Control," issued on
December 12, 1994 (Accession No. 9412140006). In addition, IR 50-298/94-16 discussed a
surveillance procedure that contained instructions requiring technicians to inspect, clean, and
lubricate several breakers before performing the "as-found" testing of several breaker
functions. Since these functions (e.g., trip force of the operating mechanism, undervoltage
trip, time delay attachments, etc.) could have been affected by the cleaning and lubrication, the test results did not represent the as-found condition of the breakers.
In NRC IR 50-298/94-31 (Accession No. 9506280604) for Cooper station, the NRC staff
evaluated the effectiveness of the licensee's corrective actions in response to the
preconditioning issues identified in IR 50-298/94-16. In order to address this violation, the
licensee had reviewed over 6,400 procedures, including maintenance procedures, and found
approximately 168 procedures that contained potential preconditioning activities. The
inspectors verified that the licensee had revised these procedures to address these concerns.
Emergency Diesel Generators
NRC IR 50-315/316-95010(DRP) (Accession No. 9511280025) for D.C. Cook identified that
the licensee's policy was to use the air start system to turn over (roll) the emergency diesel
generator (EDG) crankshafts with the cylinder petcocks open to purge (blow down) any
accumulated water or oil before the surveillance test was performed. Since this activity was
performed to prevent potential damage caused by hydrolocking during the surveillance test
starts, the safety benefit of rolling the diesels outweighed the benefit of testing in the
as-found condition. However, the staff was concerned that air start valves were used
(unnecessarily) to roll the EDGs when this activity could have been performed manually by
"barring over" the crankshaft. Barring over the crankshaft would have avoided the possibility
of preconditioning the air start valves and would have ensured that they were being tested in
an as-found condition. NRC IR 50-315/316-95013(DRP) (Accession No. 9602200321)
identified the practice of using the air start system to roll the EDGs prior to surveillance
testing as a failure to test safety-related equipment under suitably controlled conditions and in
accordance with design and licensing bases. This failure was cited as a violation of 10 CFR
Part 50, Appendix B, Criterion II, "Quality Assurance Program."
Hydrogen Analyzer Calibration
NRC IR 50-416/95-21 (Accession No. 9602290202) for the Grand Gulf Nuclear Station
identified that the containment and drywell hydrogen analyzer calibration surveillance
procedure required technicians to check reagent gas flow before calibration of the analyzer
and to make an adjustment, if necessary, to the previous test value before obtaining the
"as-found" calibration data. Since adjusting the reagent gas flow could change the as-found
condition of the analyzer and invalidate the surveillance test results, the inspectors
IN 97-16 April 4, 1997 determined that the test procedure was inadequate and cited it as a violation of TS 5.4.1.a.,
which requires that specific written procedures be established for surveillance tests as
described in Regulatory Guide 1.33, "Quality Assurance Program Requirements."
Turbine Driven Auxiliary Feedwater Pumps
NRC IR 50-315/316-95013(DRP) (Accession No. 9602200321) for D.C. Cook Units I and 2 identified the practice of operating the turbine-driven auxiliary feedwater pumps immediately
before performing the surveillance tests and the practice of venting the residual heat removal
pumps immediately before performing surveillance tests as examples of unacceptable
preconditioning. The failure to test safety-related equipment under suitably controlled
conditions and in accordance with design and licernsing bases was cited as a violation of
10 CFR Part 50, Appendix B, Criterion II.
High-Pressure Coolant Injection and Reactor Core Isolation Cooling
NRC IR 50-298/95-04 (Accession No. 9505230003) for Cooper Nuclear Station indicated that
plant operators had recognized that performing a series of different high-pressure coolant
injection system and reactor core isolation cooling surveillance tests in sequence, without
allowing sufficient time for the systems to cool down between tests, would constitute
unacceptable preconditioning. However, the operators did not identify nor document the full
extent of the preconditioning concerns, nor did they initiate appropriate corrective actions to
ensure that preconditioning would not be repeated. The failure of the operators to fully
recognize and initiate action to correct preconditioning concerns was cited as a violation of
10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings."
Motor Operated Valves
NRC IR 50-335/96-11, 50-389/96-11 (Accession No. 9609170377) for the St. Lucie reactor
facility identified that the four containment spray flow control valves (two for each unit) were
being unacceptably preconditioned prior to surveillance testing. Specifically, the valve stems
were being lubricated prior to performing stroke time testing. The failure of the licensee's
administrative procedures to ensure that these stroke time tests were performed under
suitably controlled conditions was cited as a violation of 10 CFR Part 50, Appendix B,
Criterion Xl, 'Test Control."
Discussion
As illustrated in the above-mentioned examples, some licensees are continuing to perform
maintenance activities or to take other preconditioning actions that were found to be
unacceptable. When performing technical specification surveillance and ASME Code
inservice testing, the equipment is typically tested in the as-found condition. However, experience has demonstrated that some surveillance testing cannot be performed without
disturbing or altering the equipment (e.g., attachment of test leads, pneumatic or hydraulic
supply lines). For example, circuit breakers may be required to be racked out and installed
on a test rig in order to perform some surveillance tests. However, cycling, cleaning, and
IN 97-16 April 4, 1997 lubrication were not necessary in order to perform the surveillance test. Similarly, other
equipment, such as valves, pumps, and motors may require disconnection, realignment, installation of jumpers, or other alterations in order to perform the surveillance tests.
Any such disturbance or alteration would be expected to be limited to the minimum necessary
to perform the test and prevent damage to the equipment.
In certain cases, the safety benefit of some preconditioning activities may outweigh the
benefits of testing in the as-found condition. For example, the staff has approved the
practice of routine checking of EDG cylinders for water accumulation before performing
surveillance tests in order to prevent the damage caused by hydrolocking. In the previously
described EDG example, the concern was that use of the air start valves was not needed to
roll the EDG and purge the cylinders.
The following guidance has been provided to NRC inspectors:
1.
Inspection Procedure (IP) 61726, "Surveilldnce Operations," directs inspectors to
condu.ct a detailed technical review of the licensee's surveillance procedure and
evaluate its adequacy to demonstrate that the system components will function under
design-basis conditions and that any preconditioning required by the procedure is
acceptable.
2.
IP 62707, "Maintenance Observation," cautions inspectors to verify that preventive
maintenance (PM) activities are not routinely being scheduled to "precondition"
equipment before performing surveillance tests in order to ensure that the test is
passed satisfactorily. It directs inspectors to examine the sequence of PM activities to
determine whether the licensee routinely schedules PM activities before surveillance
tests.
3.
NUREG-1482, "Guidelines for Inservice Testing at Nuclear Power Plants," Section 3.5, notes that the as-found condition is generally considered to be the condition of a valve
without pre-stroking or maintenance and that most inservice testing is performed in a
manner that generally represents the condition of a standby component if it were
actuated in the event of an accident (i.e., no preconditioning before actuation).
Related Generic Communications
The NRC staff has addressed the issue of preconditioning in previous generic
communications including Information Notice (IN) 96-24, "Preconditioning of Molded-Case
Circuit Breakers Before Surveillance Testing," and IN 93-63, "Periodic Testing and Preventive
Maintenance of Molded-Case Circuit Breakers."
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IN 97-16 April 4, 1997 This information notice requires no specific action or written response. If you have any
questions about the information in this notice, please contact the technical contact listed
below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.
Thomas T. Martin, Director
Division of Reactor Program Management
Office of Nuclear Reactor Regulation
Technical contact: Charles D. Petrone, NRR
(301) 415-1027 E-mail: cdp@nrc.gov
Attachment: List of Recently Issued NRC Information Notices
14
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Attachment
April 4, 1997 LIST OF RECENTLY ISSUED
NRC INFORMATION NOTICES
Information
Date of
Notice No.
Subject
Issuance
Issued to
97-15
Reporting of Errors
and Changes in Large- Break Loss-of-Coolant
Accident Evaluation
Models of Fuel Vendors
and Compliance with
04/04/97
All holders of OLs
or CPs for nuclear
power reactors and
all reactor fuel
vendors
97-14
97-13
97-12
92-27, Supp. 1
97-11
Assessment of Spent
Fuel Pool Cooling
Deficient Conditions
Associated with Pro- tective Coatings at
Nuclear Power Plants
Potential Armature
Binding in General
Electric Type HGA
Relays
Thermally Induced
Accelerated Aging
and Failure of ITE/
Gould A.C. Relays
Used in Safety-Related
Applications
Cement Erosion from
Containment Subfounda- tions at Nuclear Power
Plants
03/28/97
03/24/97
03/24/97
03/21/97
03/21/97
All holders of OLs
or CPs for nuclear
power reactors
All holders of OLs
or CPs for nuclear
power reactors
All holders of OLs
or CPs for nuclear
power reactors
All holders of OLs
or CPs for nuclear
power reactors
All holders of OLs
or CPs for nuclear
power reactors
OL = Operating License
CP = Construction Permit
I
11* ; .
IN 97-16 April 4, 1997 This information notice requires no specific action or written response. If you have any
questions about the information in this notice, please contact the technical contact listed
below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.
original signed by T.R. Quay
Thomas T. Martin, Director
Division of Reactor Program Management
Office of Nuclear Reactor Regulation
Technical contact: Charles D. Petrone, NRR
(301) 415-1027 E-mail: cdp@nrc.gov
Attachment: List of Recently Issued NRC Information Notices
Tech Editor has reviewed and concurred on 03/09/97
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3/31 /97
OFFICIAL RECORD COP
IN 97-xx
March,
1997 This information notice requires no specific action or written response. If you have any
questions about the information in this notice, please contact the technical contact(s) listed
below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.
Thomas T. Martin, Director
Division of Reactor Program Management
Office of Nuclear Reactor Regulation
Technical contact: Charles D. Petrone, NRR
(301) 415-1027 E-mail: cdp@nrc.gov
Attachment: List of Recently Issued NRC Information Notices
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IN 97-xx
March , 1997 This information notice requires no specific action or written response. If you have any
questions about the information in this notice, please contact the technical contact(s) listed
below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.
Thomas T. Martin, Director
Division of Reactor Program Management
Office of Nuclear Reactor Regulation
Technical contact:
Charles D. Petrone, NRR
(301) 415-1027 E-mail: cdp@nrc.gov
Attachment: List of Recently Issued NRC Information Notices
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IN 97-xx
March , 1997 This information notice requires no specific action or written response. If you have any
questions about the information in this notice, please contact the technical contact(s) listed
below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.
Thomas T. Martin, D ctor
Division of React
rogram Management
Office of Nucde
Reactor Regulation
Technical contact:
Charles D. Petrone, NRR
(301) 415-1027 E-mail: cdpenrc.gov
Attachment: List of Recently Issued NRC Informati Notices
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