ML17228B551
| ML17228B551 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 07/02/1996 |
| From: | Hebdon F NRC (Affiliation Not Assigned) |
| To: | Jerrica Johnson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| TAC-M95274, TAC-M95275, TIA-96-007, TIA-96-7, NUDOCS 9607150019 | |
| Download: ML17228B551 (7) | |
Text
CATEGORY 2
REGULATO INFORMATION DISTRIBUTION a STEM (RIDS)
ACCESSION NBR:9607150019 DOC.DATE: 96/07/02 NOTARIZED: NO FACIL'.50-335 St. Lucie Plant, Unit 1, Florida Power
& Light Co.
50-389 St. Lucie Plant, Unit 2, Florida Power
! Light Co.
AUTH.NAME AUTHOR AFFILIATION HEBDON,F.J.
RECIP.NAME JOHNSONFJ.R.
RECIPIENT AFFILIATION Region 2 (Post 820201)
NOTES:
SUBJECT:
Forwards TAR TIA 96-007, "Regulatory Acceptability of Lubricating Valves Prior to Surveillance Testing".
3 DISTRIBUTION CODE:
DFOID COPIES RECEIVED:LTR / ENCL /
SIZE: 5 TITLE: Direct Flow Distribution:
50 Docket (PDR Avail)
DOCKET 05000335 05000389 RECIPIENT ID CODE/NAME INTERNAL ILE CENTER 01 EXTERNAL: NOAC COPIES LTTR ENCL 1
1 1
1 RECIPIENT ID CODE/NAME NUDOCS-ABSTRACT NRC PDR COPIES LTTR ENCL 1
1 1
1 NOTE TO ALL "RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE!
CONTACT THE DOCUMENT CONTROL DESK, ROOM OWFN 5D-StEXT. 415-2083)
TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUIRED:
LTTR 4
ENCL 4
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t UNITED STATES NUCLEAR REGULATORY COMMlSSION WASHINGTON, O.C. 20555-0001 July 2, 1996 MEMORANDUM TO:
Jon R. Johnson, Acting Director Division of Reactor Projects, RII FROM'UBJECT:
Frederick J.
Hebdon, Director Project Directorate I'I-3 Division of Reactor Projects I/II, NRR TECHNICAL ASSISTANCE RE(VEST (TIA 96-007)
REGULATORY ACCEPTABILITY OF LUBRICATING VALVES PRIOR TO SURVEILLANCE TESTING (TAC NOS.
M95274 AND M95275)
In a memorandum dated April 12,
- 1996, as a result of valve stroke timing practices at the St.
Lucie Plants, you requested NRR assistance in evaluating the acceptability of lubricating valves prior to the performance of stroke time testing.
You also asked NRR to resolve a question as to whether the purpose of the stroke time testing was to demonstrate current and past operability of a valve, current and future operability of a valve, or both.
The Mechanical Engineering Branch (EMEB),
- NRR, has completed its review of these issues.
A discussion of these issues and NRR's response to your questions is contained in the attached memorandum dated June 24, 1996.
Docket Nos.:
50-335 and 50-389
Attachment:
As Stated cc w/attachment:
R. Cooper, RI W. Axelson, RIII J. Dyer, RIV
Contact:
L. Wiens, NRR(PDII-3 415-1495 96071500i9 960702 PDR ADOCK 05000335, lI, P
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REGULATORY ACCEPTABILITY OF PRE'UBRICATING VALVES PRIOR TO SURVEILLANCE TESTING (TIA 96-007)
In a oeaer anduw dated April 12, 1996, Ellis M. Herschoff, Director, Division of Reactor Projects, Region II, discussed the determination by Region II inspectors that the licensee of the St. Lucie nuclear power plant had lubricated a containwent spray flow control valve prior to performing stroke-tim testing under Section XI of the ASHE Boiler and Pressure Vessel (BKPV)
Code.
The Region II inspectors considered this pre-lubrication to result in a nonrepresentative test of valve capabilities.
Therefore, Region II requested a response to the following questions:
l.
Is the pract1ce of lubricating a valve prior to stroke-time testing acceptable under the regulations?
2.
Is the purpose of stroke-time testing under ASHE Section XI to demonstrate the current and past operability of a valve, the current and future operability of a valve, or both?
Qih The NRC regulations in 10 CFR 50.55a require that nuclear power plant licensees provide valves and pwaps within the scope of Section XI of the ASHE BRPV Code with access to enable the performance of inservice testing of those valves and pumps for assessing operational readiness as set forth in Section XI of the ASHE 84PV Code.
Criterion XI, "Test Control," of Appendix B
to 10 CFR 50 requires that testing be performed under su1table environmental conditions.
The current Inservice Testing (IST) Programs at St. Lucie Units I and 2 are based on the requirements of Section XI of the ASHE BSPV Code, 1986 Edition, with approved relief to certain requirements.
Article IVV-1000 of ASHE BLPV Code (1986 Edition),Section XI, states that it provides the rules and requirewents for inservice testing to assess operational readiness of certain Class I, 2, and 3 valves in nuclear power plants, which are required to perform a specific function in shutting down a reactor to the cold shutdown condition, in aitigating the consequences of an accident, or in providing
'verpressure protection.
Subarticle INI-3I17 of the 1986 ASHE ELPV Code states that, if a valve fails to exhibit the required change of valve stea or d1sk position or exceeds its specif1ed liwiting value of full-stroke time by this testing, the licensee shall initiate corrective action iaaediately with the valve declared inoperative if the condition 1s not corrected in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Generic Letter (GL) 89-04, "Guidance on Developing Acceptable Inservice Testing Programs,"
in Position 8 indicates that, rather than delaying 2l hours, the licensee should make a dec1sion on operability when the data is recognized as being within the required action range.
GL 91-18, "Information to Licensees Regarding Two NRC Inspection Hanual Sections on Resolution of Degr aded and Nonconforming ATTACHHENT
Conditions and on Operability," provides similar guidance on the timeliness of operability decisions based on test results.
IWV-3417 also requires that the test frequency be increased if a significantly longer stroke time is observed since the last test.
- Finally, IWV-3417 requires that any abnormality or erratic action be reported.
The St. Lucie IST Program Plan identifies no differences in interpretation of the NRC regulations or ASHE Code when stating that the inservice testing in the plan is to be performed specifically to verify the operational readiness of pumps and valves which have a specific function in mitigating the consequences of an accident or in bringing the reactor to a safe shutdown.
Hore recent ASHE codes and standards have repeated and amplified the importance of evaluating the oper ability of valves during inservice testing.
For example, Subsection ISTC, "Inservice Testing of Valves in Light-Water Reactor Power Plants,'f the ASHE Operation and Haintenance (OHc) Code states that it establishes requirements for inservice testing to assess the operational readiness of certain valves and pumps used in nuclear power plants.
Subsection ISTC 4.2.9 requires that the valve be iaeediately declared inoperable if the valve exceeds the limiting values of full stroke time.
Subsection ISTC 4.2.4 also requires that any abnormality or erratic action be
'ecorded and that an evaluation be made regarding the need for corrective action.
The NRC regulations, and ASHE codes and standards, clearly indicate that the purpose of the inservice testing programs is to "assess" the operational readiness of the valves and pumps.
Article IWA-9000, "Glossary," of ASHE BSPV Code (1986 Edition),Section XI, defines "assess" as determining 'by evaluation of data compared with previously obtained data such as operating data or design specifications."
Hore generally, Webster's II New Riverside University Dictionary defines "assess" as 'to appraise or evaluate."
If maintenance is performed prior to inset vice testing that ensures, the capability of a valve or pump to operate properly, the licensee's IST program would be unable tO evaluate the operational readiness of the component.
This is reinforced by the requirement in the ASHE Code that, if the stroke-time limits are exceeded, the condition be corrected or the valve be considered inoperable.
The St. Lucie IST Prograj>> Plan intent "to verify the operational readiness" is more specific regarding the purpose of the. testing to determine the capability of the valves to perform their safety function.
The ASHE Code recognizes that routine preventive maintenance will be performed by licensees.
In some instances, this maintenance may occur shortly before a
scheduled test required by a licensee's IST program.
The effect of this maintenance on the validity of the test to assess operational readiness should be evaluated.
In Sectioa 3.5, "Testing in the As-Found Condition," of NUREG-1482 (April 1995), 'Guidelines for Inservice Testing at Nuclear Power Plants," the staff stated that the Code does not specifically require testing to be performed for components in the as-found condition except for safety and relief valves, but does not define as-found even in the context of safety and relief valves.
In NUREG-1482, the staff noted its belief that most inservice testing is performed fn a manner that generally represents the condition of a standby component if it were actuated in the event of an accident (i;e.,
no pre-conditioning prior to actuation).
e C
~
In MRC Information Notice 96-24 (April 25, 1996), "Preconditioning of Molded-Case Circuit Breakers Before Surveillance Testing," the staff stated that the lubr practice of preconditioning molded-case circuit break
'f 1
icating pivot points and manually cycling the breaker) defeats the pur ose of the periodic test.
The staff stated that such preconditioning does not confirm continued operability between tests nor does it provide information on the condition of the circuit breaker for trending purposes.
The applicable correct this situation.
licensee planned to revise its procedures before the next su ill e
surve ance test to In ASHE Code Case ON-l, "Alternative Rules for Preservice and Inservice Testing of Certain Electric Hotor Operated Valve Assemblies in LWR Power Plants (OH - Code - 1995 Edition; Subsection ISTC)," the ASHE provides an alternative to the stroke-time testing requirements of the OH Code to assess the operational readiness of aotor-operated valves (HOVs).
The code case uses the same language as the HRC regulations and ASHE Code in stating that inservice testing is intended to assess the operational readiness of valves.
ca abilit of In impleaenting the code case, the licensee is required t d t i
th p
the HOV during inservice testing.
The code case requires HOVs o
e crane e
to be cycled at least every refueling cycle with diagnostic testing conducted on periodic intervals.
The code case allows grouping of HOVs with the information obtained from individual HOV tests applied to other HOVs in the group.
In Section 3.3, the code case specifically states that maintenance activities, such as stem lubrication, shall not be conducted if they sight invalidate the as-found condition for'nservice testing.
The performance of maintenance prior to testing would defeat the ability to deterPine any degradation in the operation of the tested HOV and to apply the test results to other HOVs within the group.
This code case is being endorsed (with certain limitations unrelated to preconditioning) for voluntary use by licensees in a forthcoming generic letter.
In suueary, the performance of maintenance on a component to ensure its proper operation prior to conducting a test negates the validity of the test in assessing the operational readiness of the component.
If the maintenance had not been pertormed, the component may not have been capable of performing its safety function.
Clearly, the conduct of maintenance prevents the licensee froa assessing if the component would perfora as design, should it be called upon.
- Further, important information on trending of operating parameters for evaluating degradation would not be available.
F In response to the specific questions freya Region II:
I.
The performance of maintenance that ensures the capability of a valve to satisfy the stroke-time test r equireaents of the ASHE Code provides a
false indication of the operational readiness of the valve.
Therefore, a licensee activity to lubricate a valve prior to stroke-time testing
" for the principal purpose of satisfying the test criteria at that specific time would not be considered to be within the intent of the HRC regulations under 10 CFR 50.55a or Appendix 8 to 10 CFR 50.
It is recognized that routine preventive maintenance, such
.as valve
lubrication, might coincide occasionally with IST prograw testing.
In those cases, the effect of such maintenance needs to be evaluated to ensure that the ability to assess operat1onal readiness of the valves and to trend degradation in the valve performance are not adversely affected.
2.
The NRC regulat1ons, and ASIDE codes and standards, require licensees to establish IST programs to assess the operational readiness of certain valves and pumps.
If a valve fails its stroke-time test, the licensee is required to declare the valve inoperable.
Therefore, the stroke-time test is intended to demonstrate current operability.
The licensee evaluates past operability since the previous stroke-time test based in part on the most current test results.
The ASIDE Code prescribes comparison of stroke-time test data to previous test data so that licensees may obtain an indication that the valve should remain operable until the next test.
It is recognized that the stroke-time test is limited in its effectiveness
- and, as a result, the ASIDE developed an alternat1ve IST approach for %Vs in AQIE Code Case OHN-1.