ML17206A960

Finds Proposed Cycling Test for Check Valves of Valve Test Program Unacceptable.Forwards NRC Position on Cycling Test Program.Requests Position Be Reviewed & Accepted or That Util Demonstrate That Full Stroking Valves Impractical

ML17206A960
Person / Time
Site:	Saint Lucie
Issue date:	07/16/1979
From:	Reid R Office of Nuclear Reactor Regulation
To:	Robert E. Uhrig FLORIDA POWER & LIGHT CO.
References
NUDOCS 7908140477
Download: ML17206A960 (7)

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ACRS (16) g'(,,'RBuchanan TERA Gray Fi1e Docket No. 50-335 Please respond to this request-within 30 days of the receipt of this.letter.

Sincerely, DIS y 6 1979

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Box 529100 JNi1 1 er Nfamf, Florida 33152 RReid PErickson

Dear Dr. Uhrfg:

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On September 16, 1977. as revised September 8, 1978 you submitted a valve test program for St; Lucfe Unit 1.

As discussed with your staff, your proposed cycling test for check valves has been reviewed and found to be unacceptable.

Me have completed our review of the St. Lucfe Untt 1 fnservfce testing program and we need to resolve this outstanding issue fn order to comp'tete our Safety Evaluation.

Enclosed fs the HRC position on the cycling test for check valves.

You are requested to review our posftifon and indicate that you will accept ft or else demonstrate to us that ft fs impractical to-full-stroke these valves.

Enclosure:

Staff Position of FPL Inservfce Valve Testing Program cc w/enclosure:

See next page 1i in'.i siiln Roget"t W. Refd, Chief Operating Reactors Branch ¹4 Division of Operating Reactors orrIcs~

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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 July 16, 1979 Docket No. 50-335 Dr. Robert E. Uhrig Vice President Florida Power 5 Light Company Advanced Systems Im Technology P.'.

Box 529100 Miami, Florida 33152

Dear Dr. Uhrig:

On September 16, 1977 as revised September 8,

1978 you submitted a valve test program for St. Lucie Unit 1.

As discussed with your staff, your proposed cycling test for check val.ves has been reviewed and found to be unacceptable.

We have completed our review of the St. Lucie Unit 1 inservice testing program and we need to resolve this outstanding issue in order to complete our Safety Evaluation.

Enclosed is the NRC position on the cycling test for check valves.

You are requested to review our positiion and indicate that you will accept it ot else demonstrate to us that it is impractical to full-stroke these valves..

Please respond to this request within 30 days of the receipt of this letter.

Sincerely,

Enclosure:

Staff Position of FPL Inservice Valve Testing Program cc w/enclosure:

See next page Robert W. Reid, Chief Operating Reactors Branch 84 Division of Operating Reactors

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V 4'Florida Power 5 Lig Company CC:

Robert Lowenstein, Esquire Lowenstein, Newman, Reis 5 Axelrad 1025 Connecticut

Avenue, N. W.

Mashington, 0.

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20036 Norman A. Coll., Esquire McCarthy,'teel, Hector 5 Davis 14th Floor, First National Bank Building Miami, Florida 33131 Mr. Jack Shreve Office of the Public Counsel Room 4, Holland Bldg.

7allahassee, Florida 32304 Indian River Junior College Library 3209 Virginia Avenue Fort Pierce, Florida 33450

5t Enclosure NRC St-ff Position on the FPL Inservice Yalve Testing Program Paragraph IMV-3520 in Section XI of the ASME Code (1974 Edition) establishes re-quirements for check valve tests.

Subparagraph IMV-3520(a) deals with test frequency and subparagraph IMY-3520(b) and its sub-subparagraphs 3520(b)(1) and 3520(b)(2) deal with the exercising procedure.'he latter two sub-subparagraphs

'also expand on the procedures for additional testing of normally o'en and normally closed check valves, respectively.

~In IMV-3520(b) the ASME Code makes it clear that full stroking of check valves is a requirement.

The Code states,

".Check valves shall be exercised to the position required to fulfilltheir function unless such operation is not practical during plant operation.

If only limited operation is practical during plant operation the check valve shall be part-stroke exercised during plant operation and full-stroked during each cold shutdown."

The NRC Staff communicated these ASME Code requirements to FPL technical personnel in Nay, 1968.

We noted that IWY-3520(b) provides the broad require-ments that must be met for all check valves and that any other specific re-quirements such as those in IWY-3520(b)(1) and (b)(2) are in addition to IWY-3520(b).

We also described an acceptable means to demonstrate that a check valve has been full-stroked if the disk does not have position indication.

Specifically if the valve allows design flow, as used in the Safety Analysis Report (SAR) to pass through the valve, then it may be assumed that the valve "moved to a position to fulfill its function."

We accept this test as full-stroking.

Any less flow is considered as part-strokdd unless it could be demonstrated that less flow will place the valve disk in the same position as the flow in the plant's safety analysis.

We have determined that flow is acceptable for demonstrating check valve disk -

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position because:

(1) The ASME Code recognizes flow rate (or lack thereof) as an established method for indirect evidence of disk position.

(2) The majority of the plants have flow measuring devices installed in the lines containing these check valves.

(3) The tests continue to verify that the check valves will permit flow rates used in the SAR.

(4) Plants have the means readily available wigh HPSI,

LPSI, RHR, etc.

pumps to provide the necessary flows for these flow tests.

't is our position that the exercising requirements in sub-subparagraph IMV-3520(b)(l) (for normally open valves) and IWV-3520(b)(2) (for normally closed valves) refer to how promptly the disk responds and moves toward (or away from) its seat when flow is suspended (or initiated) and that these requirements are in addition to those for full-stroking (IMY-3520(b)).

Therefore full. stroke testing of check valves is a requirement of-the ASME Code.

The NRC position is that full stroke testing of check valves is required regardless of interpretation of Code.

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