ML19210A635
| ML19210A635 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/10/1978 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19210A633 | List: |
| References | |
| NUDOCS 7910300668 | |
| Download: ML19210A635 (12) | |
Text
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NRC STAFF GUIDANCE FOR FREPARING PUMP AND VALVE TESTING PROGRAM DESCRIPTIONS AND ASSOCIATED RELIEF REQUESTS PURSUANT TO 10 CFR 50.55aIq)
The guidance provided in this enclosure is intended to illustrate the type and extent of information that should be provided in proposed pump and valve testing program descriptions and to support associated requests for relief from ASME Code requirements.
By utilizing these guidelines, licensees can significantly reduce the need for having to respond to additional information requests from the NRC staff.
I.
Pumo and Valve Testina Progra.m Descriotion A.
Scope of the Program:
1.
The pump testing program should include all safety related*
Class 1, 2 and 3 pumps that are provided with an emergency power source.
2.
The valve testing program should be limited to the safety related* valves. All such valves must be addressed in the program and should include, as a minimum, those in the following systems. Valves in these systems which are used for operating convenience only - such as manual vent, drain, instrument and test valves, and valves used for maintenance only should be excluded.
For PWR's:
e a.
High Pressure Injection System b.
.s Pressure Injection System c.
Accumulator Systems d.
Containment Spray System e.
Primary and Secondary System Safety and Relief Valves f.
Auxiliary Feedwater Systems
- Safety related are those cumps and valves necessary to safely shut down the plant or mitigate the consequences of an accident.
149; 244
" 7910800 Q p
. Reactor Building Cooling System g.
Active Components in Service Water and Instrunent h.
Air Systems which are required to support safety system functions Containment Isolation Valves that are required to i.
change position on a containment isolation signal J.
Chemical and Volume Control System Other key valves in Auxiliary Systems which are k.
required to operate to directly support plant shutdown or safety system function; such as, emergency diesel starting air valves, component cooling water supplies, etc.
1.
Residual Heat Removal System Reactor Coolant System m.
For BWR's:
High Pressure Coolant Injection System a.
b.
Low Pressure Coolant Injection System Residual Heat Removal Systen (Shutdown Cooling System) c.
Emergency Condenser System (Isolation Condenser System) d.
Low Pressure Core Spray System e.
f.
Containment Spray System Safety, Relief, and Safety / Relief Vaives g.
RCIC (Reactor Core Isolation Cooling! Syster h.
- i. Containment c.coling S3stre muired t-char; e J.
Containment isolation <alves that ar-position on a containrrent isolation. i g n.1 ;
1492 245
_3_
k.
Standby liquid control system (Soron System)
Automatic Depressurization System (any pilot or control 1.
valves, associated hydraulic or pneumatic systems, etc.)
Control Rod Drive Hydraulic System (" Scram" function) m.
Other key valves in Auxiliary Systems which are required to operate to directly support plant shutdown n.
or safety system function; sud, u, emergency diesel starting air valves, component cooling water supplies, etc.
o.
Reactor Coolant System The following information should be provided for NRC staff review B.
of the Pump and Valve Testing Programs:
Three sets of P&ID's, that are large and clear enough to 1.
be read easily, and which include all of the systems listed above, with the ASME code class and system The drawings should include boundaries clearly marked.
all of the components present at the time of submittal and a legend of the P&ID symbols.
Identification of the applicable ASME Code Section XI 2.
Edition and Addenda.
The period for which the program is applicable.
3.
Identification of the component ASME Section HI Code 4.
Class.
5.
For Pump testing, identification of:
Each pump required to be tested (name and number; a.
b.
The test parameters to be measured c.
The test frequency 1492 246
_a_
For valve testing, identification of:
6.
Each valve in ASME Section XI Categories A and B that will be exercised every three months daring nonnal a.
plant operation (indicate whether partial or full stroke exercise, and for power operated valves list the limiting value for stroke time).
Each valve in ASME Section XI Category A that will b.
be leak tested during refueling outages (indicate the leak test procedure you intend to use).
Each valve in ASME Section XI Categories C and C c.
that will be tested, the type of test and the test For check valves, identify those that frequency.
will be exercised every 3 months and those that will only be exercised during cold shutdown or refueling
- outages, Each valve in ASME Section XI Category E that will d.
be operationally checked.
The following additional information, if practical:
e.
The valve location coordinates or other i.
appropriate location infonnation which will expedite locating the valves on the P& ids.
Identification of all valves tnat are provided ii.
with an interlock to other conponents and a brief description of that function.
Recuests for Relief from Certain Pump or Valve Testinn Requirements II.
It has been the staff's experience that many requests for relief from testing requirements, submitted by licensees, have not been supported by adequate descriptive and detailed technical information.
This detailed information is necessary to document why the burden imposed on the licensee in complying with the code requirements is not justified by the increased level of safety obtained from the testing.
Relief requests which arc 2 mite.ec with
- u. ;. ib ti.o s o as
- nasis,
" impractical", "inaccessiale", or any,tw c u.i goric.:
require additional infomation to allow '.ra ita f tc make an The intention of the guidance evaluation of that relief request.
D**D
%T ] $ fj UU ud LU(
a ee 1492 247
. set forth below is to illustrate the extent of the information that is required by the NRC staff to make a proper evaluation and to adequately document the Jasis for granting the relief in the safety evaluation report. The i;RC staff believes that if this infomation is provided in the licensee's submittal, subsequent requests for additional information and delays in completing the review, and granting the relief, can be considerably reduced.
Specific infomation required for NRC review of requests for A.
relief from testing requirements:
1.
Identification of the component for which relief is requested:
Name and number as given in FSAR a.
O O
3 [f dI 9 I oIdl J lb b.
Function
.do c.
ASME Section III Code Class d.
For valve testing, also specify the ASME Section XI valve category as defined in IWV-2000 2.
Specific identification of the AStiE Code requirement that has been determined to be impractical for each component.
3.
Ir, formation to support the determination that the requirement in (2) is impractical; i.e., state and explain the basis for requesting relief.
Specification of the inservice testing that will be performed 4.
in lieu of the ASME Code Section XI requirements, if any.
5.
The schedule for implementation of the procedure (s) in (4).
B.
Examples to illustrate several possible areas where relief may be granted and the type and extent of information necessary to support the granting of relief:
1.
" Accessibility":
The regulation allows relief to be grented f ecr ccde requirements because of insufficient access rrcolitioms.
However, a detailed discussion of actual physii al arrance-ment of the coraponent in question to illustratc tM insufficiency of space for conducting the reau red :e:t is necessary, 1492 248 In addition, discussion of the alternative surveillance tec."niques that have been considered should be provided.
'.f trase alternative techniques have been detemined to ae impractical, the basis for this detemination should be. r rovided.
" Environmental Conditions Drohibitive" (e.g., high radiation 2.
level, high temperature, high numidity, etc.):
Although it is prudent to maintain occupation radiation exposure for inspection personnel as low as practicable, the request for relief from code requirements cannot be granted solely on the basis of high radiation levels.
A balanced judgment between the hardships and compensating increase in the level of safety must be explicitly justified.
Therefore, detailed information regarding the radiation levels at the required test location, along with estimated yearly man-rem exposures associated with the testing, should be provided. Alternative testing techniques that have If these alternative been considered should be discussed.
techniques have been determined to be impractical, the basis for this detemination should be provided.
" Instrumentation Not Originally Provided":
3.
Infomation to justify that installation of the neenedwould instrumentation to comply with the code requirement:
result in undue burden or hardships without a compensating increase in the level of plant safety should be provided.
Alternative testing techniques that have been considered If these alternative techniques should be discussed.
have been detemined to be impractical, the basis for this detennination should be provided.
" Valve Cycling During Plant Operation Could Put tne Plant 4.
in an Unsafe Condition":
A detailed explanation as to why exercising tes ts d aring Examples plant operation could jeopardize the plant safety.
of the type of valve that the staff considers to be in this valves whose failure in a non-censervative position during the cycling test would i ause a loss of total category are:
system function; valves whose failure to close during the 1492'249
cycling test would cause a loss of containment integrity; and valves, which when cycled, could subject a system te A plant pressures in excess of their design pressures.
specific explanation must be provided.
" Valve Testing at Cold Shutdown or Refueling Intervals 5.
in lieu of the 3 Month Required Interval":
The licensee should explain in detail why each valve cannot be exercised during normal operation. Also, for t'.e valves where a refueling interval is indicated, the licensee should explain in detail why each valve cannot be exercised during each cold shutdown.
The following acceptance criteria for granting relief are C.
utilized by the staff:
The licensee must successfully demonstrate with documented infomation t it:
Compliance with the code requirements would result in 1.
hardships or unusual difficulties without a compensating increase in the level of safety, and noncompliance will provide an acceptable level of quality and safety, or Proposed alternatives to the code requirements or portions 2.
thereof will provide an acceptable level of quality and safety.
Standard Fomat for Valve Testina Submittals III. _
A recomended standard format, for the valve portion of the pump and valve testing program and relief requests, is included as an attachment to this Guidance. The NRC staff believes that the use of 1.his standard fomat would reduce the time spent by both the staff in its review, and by the licensee in their preparation, of The standard the pump and valve testing program submittals.
format includes examples of relief requests which are intended to illustrate the application of the standard fomat only and are not necessarily applicable to any specific plant.
1492 250
ATTACF.ME li RECOMMEllDED STAriDARD FORMAT FUR VALVE INSERVICE TESTI'1G PROGRAM SUBMITTALS 1492 251
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M hG 3 3 3 3 3 3 3 3 2 2 2 E
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0 1
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VN 4N ND.N t
LEGEND FOR VALVE TESTING EXAMPLE FORMAT
- Exercise valve (full stroke) for operability every (3) month Q
- Valves are leak tested per Section XI Article IWV-3420 LT
- Stroke time measurements are taken and compared to the stroke MT time limiting value per Section XI Article IWV 3410
- Exercise check valves to the position required to f.ilfill their CV function every (3) months SRV - Safety and relief valves are tested per Section XI Arti<.le IWV-3510
- Test category D valves per Section XI Article IWV-3600 DT
- Verify and record valve position before operations are performed ET and af ter operations are completed, and verify that valve is locked or sealed.
CS - Exercise valve for operability every cold shutdown
- Exercise valve for operability every reactor refueling RR 1492 253
RELIEF REGUEST BASIS Auxiliary Coolant System, Component Cooling System:
1.
Valve:
717 Category:
C Class:
3 Prevent backflow from the reactor coolant Function:
pump cooling coils Exercise valve for operability every three Test Requirement:
months To test this valve would require interruption Basis for relief:
of cooling water to the reactor coolant pumps motor cooling coils. This action could result in damage to the reactor coolant pumps and thus place the plant in an unsafe mode of operation.
This valve will be exercised for operability Alternate Testing:
during cold shutdowns 2.
Valve:
834 Category:
B-E Class:
3 Isolate the primary water from the component Function:
cooling surge tank during plant operation.
It is normally in the closed position, but routine operation of this valve will occur during refueling and cold shutdowns.
TestR$1rement:
Exercise valve (full stroke) for operability every three (3) months.
This valve is not required to change positicr:
Basis for Relief:
during plant operation to accomolish its safety function. Exercising this alve will increase the possibility of surge tad line contamination.
Alternate Testing:
Verify and record valve position before and after each valve opera tion.
1492 254
t '
3.
Valve:
744B Category:
A Class:
2 Isolate the residual heat exchangers from Function:
the cold leg R.C.S. backflow and accumulator backflow.
Test Requirements: Seat leakage test Bases for relief:
This valve is located in a high radiation field of mr/hr which would make the required seat leakage test hazardous to test personnel. The estimated yearly man-rem exposure associated with performing the required seat leakage test is We intend to seat leak test two other valves (875B and 866B) which are in series with this valve and which also prevent backflow. We feel that by complying the seat leakage requirements for 7448 we will not achieve a compensatory increase in the level of safety.
Alternate Testing: No alternative seat leak testing is proposed for 7448, 1492: 255