ML19308D892
| ML19308D892 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 02/01/1977 |
| From: | Boyd R Office of Nuclear Reactor Regulation |
| To: | Rodgers J FLORIDA POWER CORP. |
| Shared Package | |
| ML19308D893 | List: |
| References | |
| TAC-04548, TAC-4548, NUDOCS 8003191116 | |
| Download: ML19308D892 (12) | |
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rEn 1 1977 ocket File f1RC PDR K. Goller
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F. J. Williams Loc 4 t.o. 50-au2 J. Stolz J. Angelo L. Engle Florida Power Corporation E. Hylton Eni ar. J. T. Roogers ACRS (16)
Assistant Vice President ELD-ano auclear Project danager IE (3)
- e. J. Box 14042 H. Smit'h st. Peterscurg, Florica 337.s3 Gentic.aen:
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J. R. Buchanan,flSIC T. B. Abernathy, TIC RELIrt fici{ Tts MOUIRFIEfrS OF Itid AiG MILER AO PE6dddd VGSSEL COO 6, SCC 2 ION AI (CRISfAL RIVER UilII 3 ddCIZAR JEiiESAII.iG PLNt2) ne nave completea our review of your proposeo inservice inspection ano testing program for Crystal River Unit 3 cascricou in tne enclosure to your letter dateo Decencer 15, 1976, and your request for relief trora tne requirements of tne ASME aoiler ana Pressure vessel Coue, dection XI.
daseo on our review, we have concluoea that your proposeo inservice testing program for,ucps and valves is acceptable for tne limited perica of time from tne issuance or tne facility operating license on Deceauer 3,1976, to the start of facility coarcrcial operation.
In lieu of the surveillance requirements of the A3ad Coce, you snail pertorm tne surveillance progra.a cescrioed in the enclosure to your letter cated Dececoer 15,12, for tne period or tire fro.a tne lasuance of tne facility operating license to the start ot facility co.ac.ercial operation. On tne casis that your proposed pr>Jram is acceptacle ano sna11 oe impleirented for tne perioa of time to start or facility ccx:vercial operation, w nereoy grant relief troo tne A3.id Coue requireaents pursuant to Section 4.0.aa of tne plant Technical specifications.
. vita regard to your request tor reliet from tne iaa. Ccxte requirements irgosea oy Section 4.J.5o of tne plant recanical specifications ter tne periou of tire followiag tne start or facilitf co.;cercial operation, we nave aeteruined that your request uoes not incluae sufficient infor,-
Ration tor us to ;aake a cetermination pursuant to 10 CFx cu.aaa(g)(o)(1) taat.G2 Coue requireicencs are impractical for tne racility witnin tae 11aitations of Jesign, geoic.etry, anu.:.aterials of construction.
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LU Floridab]werCorporation 2-In oroer ror us to maxe an ewiluation of your request for relief pursuant to 10 Cea ou.asa(g)(o)(1) for ene periou of tiae after cae st.ut of racility operation, you will need to provice information to support your oeterminations of enose itema of inspection ano t'esting wnica are oeemea to ce impractical for the racility. The specific.information tnat we will neea nas oeen transmittea to you ny telecopy on cecemoer 14, 1976, and is provicea as Enclosures (1) and (2) of tnis letter.
Wita regard to the request for relief, tne nE has receivec a aut.cer of inquiries from licensees regarding acceptacle aetnoca for co@ lying witn lu CFR 50.55a(g). In general, enese inquirlas have been cirecteo toward tnree ma]or areas relative to co gliance with the regulation:
1.
Tne oetermination of wnica AStE tsoiler aru Pressure Vessel Code doition and Accenda are applicaole for any u Jatea inservice inspection or testing program, 2.. Tae requirecent to conform tne Technical Specifications to a revised program, and J.
Tne process of ootaining relief frora A:AE Code requirements found to be igpractical, faclocure 1, "aK Staff Guidance for Coaplying witn Cartain Provisions ot 10 CFR 50.55a(g), Inservice Inspection Eequirements," uescribes the
.cajor provisions of the revised regulation, addresses the areas of licensee concern listed above, and provides guidance on information which we will neea to evaluate requests for relict froc iniE Codo requireaants tnat are determir.ed to ce impractical.
Ac discussec in inclosure 1, you should subnit a oescription of your 4
plannea inservice inspection and testing programs, as well as any rel-ier trom AS E Cooe requirecents aetermined to De igractical for tne facility, as car in auvance as possible of the start of any 40,aonta inservice inspection perioo, or 20-monta put.p arm valve testing progra2
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In audition, we woula lixe to empnasize an i@ortant point regaraing tne.Wis Coue Section XI requitements to test selecteo p'2.gs aru valves tnet are now incorporated in lu CFR 50.55a(g): Tne IGZ Code dcction
.s1 ruquirenents apply only to selected valves anu pur@s ena can ce testeo witnout placing tne plant in an unsafe conaition. iou snoule exercise care in planning your testing program to ensure tnat nu test erric s >
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'Jt-Y Dlt Florida Power Corporation H5 1 1977 wil4 oe cormJucted wnile the plant 10 in an operating r. ode tnat would maxe it vulneraule to a test error or a test failure. Particula attention saould ce airectea toward the valve exercising (cycling) tests. In this regaru, saue casic guidelines for excluaing exercising (cycling) tests of certain valves curing plant operation are contained in Enclosure 2.
valve leaxage tests and other valve ano pump testa required oy the AiE Coce snoulu ce reviewed for each cocponent, relative to eacn plant operating ::coe, to assure tnat no test will nave an auverse iirpact on plant safety.
It you nave any furtner questions regaruing iAple;aentation et 10 CFR
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do.55a(9) at your facility, please contact us.
Sincerely, vid @sd BT.
Ecger S. BCid Roger S. Boyd, Director Division of Project swungesunt Office or Huclear Reactor Regulation
Enclosures:
1.
idrc staff Guidance for Cxplying wita Certain Provisions of-lu CFR 50.35a(g) 2.
Guicelines for Excluaing Exercising (Cycling) Tests of Certain valves During Plant b
Operation cc: dr. J. A. Brandimore u.
Vice Presicent and General Counsel P. v. Box IW42 St. Petersourg, Florica.D733 4
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E!JCLOSURE 1
!!RC STAFF GUIDANCE FOR C0 tFLYIrlG WITH CEpTAlti PROVISI0tl50F10CFR50.55aIg)"INSERVICEI?!SPECTIONREQUIREfEllTS" I.
INTRODUCTION l
Paragraph 50.55a(g) of 10 CFR Part 50 was revised on February 12, 1976 (41 FR 6256). Since then, a number of licensees have reouested that the NRC clarify several key provisions contained in the revised regulation.
These key provisions rel.ite to:
(1) the reouirements to periodically l
update the inservice and testing programs to comply'with later editions and addenda to the Astir. Code, (2) the requirement to confom the Technical Specifications to a revised inservice inspection or testing program, -
and (3) the procedu"es for requesting and ootaining relief frem AS:1E Code requirements that the licensee cons'iders to be impractical for his facility.
The purpose of this docunent is to briefly summarize
'the major provisions of the revised 550.55a(g) and to provide Seneral guidance in these three key areas. The document is in no way intended
'to encompass all aspects of attaining compliance with 550.55a(g).
II.
SUf1!1ARY OF REGULATIOH M
The revised 550.55a(g) contains provisions that require inservice inspec-tion and testing of ASME Code Class 1, 2, and 3 nuclear power plant com-ponents (including supports) to be performed in accordance with Section XI of the ASME Boiler & Pressure Vessel Code and apolicable Addenda. For operating facilities whose Operating License (OL) was issued before March 1,1976, these provisions of the regulation apply at the start of the next regular 40-month inspection period af ter September 1,1976.
The start of the next 40-month period is determined by measuring a series of such periods beginning at the start of facility commercial coer'ation.
For facilities that received OL's on or af ter March 1,1976, these provisions of the regulation apply at the sta"t of ccmmercial operation.
As a result of the February 1976 amendment, 150.55a(g) now specifies inservice inspection and testing requirements for all operating plants,e including those that received a Construction Permit (CP) before January 1, 1971. Since plant designs and access provisions for inservice inspections have progressed over the years, the regulation provides recognition of this fact by grouping design requirements for component inspectability based on a facility's CP issuance date.
The regulation further s,pecifies that new inservice inspection and testing requirements that become effec-tive in later editions and addenda to the ASME Code, shall apply to all plants to the degree practical throughout their service lives.
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An important part of the revised 550.55a(g) is the incorporation of the
. ASME Code Section XI requirements for testing pu.nps and valves for opera-tional readiness along with the inservice inspection recuirements. This means that in addition to a facility's inservice insection program, a periodic testing progran of selected pumps.ar.d valves must also be instituted.
T.here are now provisions in 55'.55a(g) for continued updating of requirements O
for testing pumps and valves and for inservice inspection. The inservice inspection program must be updated every 40 months while the pump and valve testing program must be upoated every 20 months. Furthermore, the regulation specifies action to be taken by a licensee when an updated inservice inspec-tion or testing program conflicts with the Technical Specifcations, or when a requirement contained in a referenced ASME Code Edition or Addendun is deemed impractical by the licensee due to design, geometry, or material considerations.
Other provisions in 550.55a(g) allow the NRC to' grant relief from ASME Code requirements that have been determined to be impractical for a fccility and specifically allow the NRC to recuire a licensee to follow an augmented inservice inspection program on components for which added assurance of structural reliability is needed.
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Selected provisions of the revised regulation are discussed below.
III.
General Guidance for Compliance with Three Key Provisions of 50. 55a( g):
A.
Updating Inservice Insoection and Testing Programs
P aragraoh 50.65 a ( g )(4 ):
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The inservice inspection program for a facility must be updated at 40 month intervals, while the program for testing pumos and valves for operational readiness must be updated every 20 months. A description i
of the updated programs should be submitted to the HRC for review and approval as far in advance as possible of, but at least 90 days before, the start of each period.
The information the NRC will need for its review of updated programs is identified in Appendix A (attached).
Under 150.55(g)((), the revised inservice inspection and testing programs must, to the extent practical, ccmply with the requirements in editions and addenda to the ASME Code that are "in effect" no more than 6 months before the start of the period for which the updated i
program is applicable. The tems "in effect" or " effective", as used in 550.55a(g)(4); identify those editions and addenda to the ASME Cooe that have been published by the ASME and that are also referenced in paragraph (b) of $50.55a.
'O Paragraph (b) of 550.55a is amended periodically to i' corporate more recent n
ASi1E Code Editions.and Addenda. However, the regulations are not amended until af ter the published ASi1E Code Editions and Addenda have been reviewed 4
and endorsed by the NRC.
Therefore, the ASME Code Edition and Addenda that are applicable to any inspection period are those referenced in paragraph (b) of 550.55a on the date that corresponds to 6 months before the start of the period in question.
If amendments to paragraph (b) of 550.55a become effective on a date that falls between the date thqt marks 6 months before the start of a inspection period and the start date itself, the licensee is not required to comply with the newly referenced ASME Code Editions and Addenda. Under the regu-lation, the licensee need only ccmply with the ASi1E Code Editions cad Addenda that were referenced in paragraph (b) of 550.55a 6 months before the start of the period in question.
On the other hand, the regulat.on does not preclude compliance with the later referenced editions and addenda if the licensee chooses, but the document that describes each new inservice inspection or testing program should state which ASME Code Edition and Addenda will be used.
An inservice inspection or testing program does not comply with 550.55a(g)(4) if it is based on an ASi1E Code Edition or Addendum which is not or has not p.
been referenced in paragraph (b) of 550.55a.
B.
Conforming the Technical Soecifications to an Uodated Inservice Insoection or Testing Program ----- Paragraon 50.55a(g)(5)(ii):
If a revised (updated) inservice insp,ection or testing program conflicts with the Technical Specifications for a facility, the licensee must propo;;e changes to the Technical Specifications to conform them to the updated pro-gram. This must be done at least 6 months before the start of the period in which the program becomes applicable.
Technical Specifications are considered to be "in conflict" only..in cases where the requirements of the regulation (thus the requirements of the updated program) a : more restrictive than the requirements of the Tech-nical Specifications.
In such cases the licensee must propose changes to conform the Technical Specifications to the revised program.
In cases where the updated progam is less restrictive than a particular Technical Specifi-cation requirement, the licensee must continue to comply with the Technical Specifications until he requests and is issued a Technical Specification change. The NRC staff.will ' review such a proposed technical Specification change to detennine if it is acceptable or whether the existing reqire-ment should be retained as an augmented requirement pursuant to 550.55a(g)(6)(ii).
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In the 14RC Staff's view, the most efficient way to eliminate existing (e potential co.nflicts from the Technical Specifications is for licensees to propose Technical Specification changes that would suostitute standarc language referencing 50.55a(g) in the place of. existing inservice inspection and t.esting requirements.
This should be done at least 6 months before the start of the first 40-month inspection period
.for which 50.55a(g) is applicable.
Sample language for this purpose was sent to licensees earlier this year.
The 11RC strongly reconmends that licensees adopt the approach of referenc-ing 50.55a(g), because such referencing will simolify the Technical Specifications by deleting %ny reauirements that are duplicated in the regul ation.
It will also alleviate the need for changes whenever an inservice inspection or testing program is updated. This approach has l
the added advantage of eliminating the scheduling pressures associated -
with meeting the 6 month s submittal time requirement for Technical Spec-ification changes proposals of 50.55a(g)(2)(ii).
It will also simplify the process by which lisensees request, and the 11RC grants, relief from ASi'.E Code requirr aents that have been determined to be 'npractical.
This is because license amendments (i.e., Technical Specification changes) will not be necessary to grant relief.
Relief from AS1E Code requirements that are deemed impractical for a facility
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is further discussed below.
C.
Obtaining Relief from AS!!E Code Requirements Determined to be Imoractical -----
Paragraph 50.55a(g)(S)(iii) and (6)(i):
If certain ASilE Code requirements are found to be inpractical by the licensee, the regulation requires him to notify the NRC and submit information to succort his findings. The licensee should submi't requests for relief from AS'1E Code requirements that he has detennined to be impractical at least 90. days before the start of the applicable inspection period.
The information that is needed by the llRC Staff to evaluate requests for relief from requirements found to be impractical is identified in Appendix B (attached).
The llRC Staff will evaluate licensee requests for relief and will grant relief, if appropriate, pursuant to 50.55a(g)(6)(i). Unless a licensee is 01.herwtse notified by the f1RC, relief from AS?1E Code requirements will remain aaplicable until the end of each 120-month period. At that time, the HRC will re-evaluate the basis for the determination that the requirement is imoractical, pursuant to 50.55a(g)(5)(ivl. This re-evaluation will take into account any aavances in the state-of-the-a'rt,of inservice inspection techniques that may, have occurred since the relief was originally granted.
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Generally, the licensee will know well in advance of the beginning of any '
inspection period, whether or not a particular ASitE Code requirement will be impractical for his -facility. Thus, the licensee should request relief from ASME Code requirements as far as possible in advance of, but not less than 90 days before, the start of the inspection period.
Early-submittals are particularly important for the first 40-month inservice inspection and 20-month pump and valve testing period because they will enable the NRC staff to evaluate the in' formation received from all licensees and determine which ASME Code requirements may be general.y impractical l
for various classes of pla.nts.
Early submittals will thereby fac;litate
. earlier feedback to licensees regarding the. acceptability of their requests.
The NRC St'aff recognizes that it will not be possible in all cases for a licensee to determine in advance that any particular ASME Code require-ment will be impractical for his facility, In cases where, during the
~ process of inspection of testing, certain requirements are found to be impractical due-to unforseen circumstances, the licensee may request relief at that time..These occurrences are not expected to be many and are expected to result la only minor changes to an inservice inspection or testing program.
All relief from AS1E Code requirenants that are determined to be impractical for a facility will be granted in the form of a letter within the provisions F""
of 550.55a(g)(6)(i). This written relief should be incorporated into the docyment describing the inservice inspection and testing progran retained
.byJ;he_ l i c. ens ee. Notice, of._the granting.o*f _r.elief..from ASME. Code require-ments will be publish. ed in_the, FEDERAL REGISTER, but.the. w_r.itten, relief.....
i.tself_ wil1 not become an explicit part o_f the facility. license or the
- __. Technical Specifications.
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APPEtl0IX A INFORt1ATION REOUIRED FOR NRC REVIEW i
OF INSERVICE INSPECTIOil AND TESTING PROGRAMS t
1.
Inservice Inspection Programs:
The information submitted for NRC review should include *,~ss~a minimum:
Identification of the applicable ASME Boiler and Pressure Vessel a.
Code Edition and Addenda b.
The period for which t6e program is applicable Identification of all of the specific components and' parts to be c.
examined for each ASME Code Class (i.e., each Quality Group as defined in Regulatory Guide,1.26, " Quality Group Classi ficati_o0 Land _ Standards f
for Water, Steam, and Radioactive-Waste-Containing Components of Nuclear Power Plants"), and the inspection interval: for each Class or Quality Group d.
For each 3pecific component and part; specification of:
i) The examination category.as defined in ASME Section XI p
- 11) The examination method to be used iii) The repair requirements 2.
Pump and Valve Testing Programs The information submitted for NRC review should include *, as a minimum:
a.
Identification of the applicable ASME Code Edition ad Addenda b.
The period for which the program is applicable c.
For Pump Testing: identify:
1) each pump to be tested (name and number) 11) the test parameters that will be measured 111).the test' intervals, i.e., monthly during operation, only during col d shutdown, etc,
- Specific written relief from the NRC is required to exclude any ASME Section XI Code requirements,
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For Valve Testing; identify:
1)' each valve 'in ASME Section XI Categories A a-B that will be exercised every 3 months during normal plant operation (indicate whether partial or full stroke exercise).
- 11) each valve in ASME Section XI Category A that will be leak tested during refueling outages.
cifi) all valves in ASME,Section XI Categories C, 0, and E,' that will be tested, the type of test and the test frequency. For check valves, identify those that will be exercised every 3 months and those. that will only be exercised during cold shutdown.
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APPEllDIX B
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INFORtMTION REOUIRED FOR floc REVIEW OF REOUESTS FOR RELIEF FROM ASME CODE SECT 10:1 XI REOUIREMEllTS DETERHit:E0 TO BE IPPRACTICAL 1.
Identify component for which relief is requested:
.a.
Name and number as given in FSAR b.
Function c.
ASME Section III Code Class d.
For valve testing, al o specify the ASME Section XI valve category as defined in IWY-2000.
2.
Specifically identify the ASME Code requirement that has been determined to be impractical for component.
3.
Provide information to support the determination that the requirement in (2) is imprac.tical; i.e., state and explain the basis for requesting relief.
4.
Specify the inservice inspection (or testing) that will be performed in lieu of the ASME Code Section XI requirements that have been determined to be p
impractical.
5.
Provide the schedule for implementation of the procedure (s) ir (4) above.
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, Enclosure 2
.g NRC STAFF GUIDELINES FOR EXCLUDING EXERCISING (CYCLlHG) TESTS OF CERTAlu VALVES DURING PLANT OPERATION Any valve which when exercised (cycled) could put the plant in an unsafe condition Below are some examples of the types of valves that should should not be tested.
be specifically excluded from exercising (cycling) tests during plant operation *:
All valves whose failure in a non-conservative position during the cycling 1.
Valves test would cause a loss of systen function should not be exercised.
' in this category would typically include all non-redundant valves in lines such-as-a-single discharge line frcm the refueling water storage tank, or accumulator discharge lines in PWR's and the HPCI turbine steam supply and the HPCI pump discharge in BWR's. Other valves may fall into this For category under certain system configurations or plant operating modes.
example, when one train of a redundant system such as ECCS is inoperable, non-redundant valves in the remaining train should not be cycled since their failure would cause a loss of total system function.
2.
All valves, whose failure to close during a cycling test would result in a
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loss of containment integrity.
Valves in this category would typically include all valves in containment penetrations where the redundant valve is open and inoperable.
3.
All valves, which when cycled, 'could subject a system to pressures in excess It is asstmed for the purpose of a cycling test, of their design pressures.
that one or more of the upstream check valves has failed unless positive methods are available for determining the pressure or lack thereof on the high pressure side of the valve to be cycled. Valves in this category would typically include the isolation valves of the residual heat renoval/
shutdown cooling system and, in some cases certain ECCS valves.
- All ASilE Section XI Category A and B valves should be cycled, as practicable, at each cold shutdown, but need not be cycled nore often than once every 3 months.
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