ML19309A938
| ML19309A938 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 11/17/1976 |
| From: | Reid R Office of Nuclear Reactor Regulation |
| To: | Mattimoe J SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| References | |
| TAC-10816, NUDOCS 8004010692 | |
| Download: ML19309A938 (12) | |
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DISTRIBUTION:
Docket V November 17, 1976 I:RC PDR Local PDR ORB #4 Rdg.
Docket ::o. 5's-312 V. Stello T. J. Carter R. Reid R. Ingram Sacra.iento Municipal Utility District V. Rooney ATTH:
Mr. J. J. l'a ttinoe J. Wetmore Assistant General !!anager Attorney, OELD and Chief Engineer OI&E (3) 6201 S Street D. Eisenhut P. O. Box 15830 T. B. Abernathy Sacramento, California 95813 J. R. Buchanan ACRS (16)
Gentlemen:
Gray File RE:
PATCHO SECO 1:UCLEAR GEtiERATIi!G STATIDH Earlier this year we sent letters to licensees of operating nuclear power plants notifying thea of a revision to 10 CFR Part 50, icction 50.55a which was published in the Federal Pegister on February 12, 1976 (41 FR 6256),
The revised regulation changea the inservice inspection and testing require-nonts for nuclear power plant components contained in paragraph (g) of G,50.55a.
A lettar reCarding this subject was sent to you on April 22,1976.
Since that tiae, the tGC has received a number of innuiries fro, licensees regarding acceptable netnods for co' plying with the regulation.
In general, the inquiries have been directed toward three major areas relative to ccroliance with the regulation:
1.
The determination of which AS'iE Boiler and Pressure 'lessei Code Cuition and Acdenna are applicable for any updated inservice inspection or testing progra :,
2.
The rec:.:irenent tc confora the Technical Specifications to a revised proger, and 3.
The precess of Ontaining ralief frcm ASiiE Coce requirments found to be,1-mrectical.
Cmer;uently, we are transnittino for voor use, Enclosure 1:
"FPC Staff finidance For Corplyiap uito Certain Provisions of 10 CFR 50.55a(g), Insnrvice Insocction P e noi r e-.en ts". This enclosure des:ribes the rajor previsions of the ravised requi ation, adcresses the areas of licensee concern listed 2cve, and pro-vices c:uicance on information v:lich the !!2C staff eill cced to review inservice insraction and testing orograms and to evaluate requests for relief fron
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- S"E Code requirc~ents that are detemined to oe inpractical. lie believe this arclosure will serve tc clarify the arorer netnod(s) for implenentino thn r o.a c [ v.i l a sev:rej 1,.pr ca ni. c y s.
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l 8004010 b S 2 TPIS DOCUMENT CONTAINS POOR QUALITY PAGES
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Sacramento liunicipal Utility 2-
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District He reiterate our previous request that you subait proposed Technical
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$ 50.5.5a(g), at least 6 months before the start of the next 40-month
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inspection period for your facility. Also, as discussed in Enclosure 1, you should submit a description of your planned inservice inspection
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requirenents deterained to be inprac+,1 cal for your. facility, as far
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in advance as possible of, but at least 90 days before, the start of any 40-nonth inservice inspection perioc, or 20-conth pump and valve testing period.
In addition, s;c would like to emphasize an important pof: i. re:;arding the ASt'!. Code Section XI requireaents to test selected puaps and valves, that are now incorporated in6 50.55a(g): The AS",E Code Section XI
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requirenants apply only to selected valves and punps that can be tested uithout olacing the plant in an unsafe condition.
You should exercise
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care in planning your testing prograns to ensure that no test will be conducted wr.ile the plant is in an operating mode that would nake it vulnerable to a test error or a test failure.
Particular attention Es should be directed toward the valve exercising (cycling) tests.
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regard, some basic guicelines for excluding exercising (cycling) tests p
of certain valves during plant operation are contained in Enclosure 2.
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Valve leakage tests and other valve and puap tests required by the AS!!E Code, should be reviewed for each conponent, relative to each plant l
operating ricae, to ensure that no test will have an adverse impact on F
plant safety.
If you have any further questions regarding inplenentation of 10 CFR 50.55a(g) at your facility, please contact us.
i -iiii Sincerely, ceva:s ere t<.!
Robert W. Reid, Chief Operating Reactors Branch v4 Division of Coerating Reactors
Enclosures:
1.
!!;.C Staff Cuidance for Coaplying uit;t Certain Previsions of 10 CP E0.5Sc(p) 2.
Guiuelines for Exclucing Exercising (Cycling) Tests
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of Certain Valves Durinn Plac Goeratico e4r
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General Counsel 6201 S Street
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Post Office Box 15830 E!j.;ll.l;
' Sacramento,. Cali fornia 95813 Business and Municipal'. Department
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Sac.amento City-County Library 828 I-Street Sacramento, California 95814 e
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ENCLOSURE 1 IIRC STAFF GUIDAllCE FOR C0!iPLYING 1IITH CERTAIN
~PRdVISIONS OF 10 CFR 50.55a(g) " INSERVICE INSPECTION REQUIREt1ENTS"
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INTRODUCTION g
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 requested that the !!RC clarify several key provisions contained in the revised regulation.
These key provisions relate to:
(1) the requirements to periodically update the inservice and testing prograns to comply with later editions and addenda to the AS'1E Code, (2) the requirement tc conform the Technical L
Specifications to a revised inservice inspection or testing program, and (3) the procedures for requesting and obtaining relief from AS:1E Code requirements that the licensee considers to be impractical for his facility.
The purpose of this document is to briefly summarize the major provisions of the revised 550.55a(g) and to provide general guidance in these three key areas. The document is in no way intended to encompass all aspects of attaining compliance with 550.55a(g).
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SUll?tARY OF REGULATI0H g
The revised 550.55a(g) contains provisions that require inservice inspec-tion and testing of AS!E Code Class 1, 2, and 3 nuclear power plant ccm-ponents (including supports) to be performed in accordance with Section XI of the ASME Boiler & Pressure Vessel. Code and anplicable Addenda.
For operating facilities whose Operating' License (0L) 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 ooeration.
For facilities that received OL's on or after !1 arch 1,1976, these provisions of the regulation apply at the start of commercial operation.
As a result of the February 1976 anendment, 550.55a(g) now specifies inservice inspection and testing requirements for all operating plants, including those that received a Construction Permit (CP) before January 1, 1971.
Since plant des'gns 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 specifies that new inservice inspection and testing requirements that becone effec-tive in later editions and addruida to the ASME Code, shall apply to all plants to the degree practical. hroughout 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 pumps and valves for opera-tional readiness along with the inseivice inspection requirements.
This means that in addition to a facility's inservice insection program, a
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periodic testing program of selected pumps and valves must also be instituted.
There are now provisions in 550.55a(g) for continued updating of requirements for testing pumps and valves and for inservice inspection. The inservice E
8 inspection program must be updated every 40 nonths while the pump and valve
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testing program must be updated every 20 months.
Furthermore, the regulation..
specifir action to be taken by a licensee when an updated inservice inspec-
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tion or testing program conflicts with the Technical Specifcations, or when j..
a requi contained in a referenced AS!!E Code Edition or Addendun is deemes tical by the licensee due to design, geometry, or material considt.s Other provisions in 550.55a(g) ellow the 11RC to grant relief from ASME Code requirements that have beer. determined to be impractical for a facility 2"
and specifically allow the flRC t3 reauire a licensee to follow an augmented
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inservice inspection program on components for which added assurance of
=g structural reliability is needed.
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A 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 Inspection and Testing Programs
Paragrann bO.65a f g)(4 ):
The inservice inspection program for a facility must be updated at 40 month intervals, while the program for testing pumps and valves for operational readiness must be updated every 20 months. A description of the updated programs should be submitted to the 11RC for review and approval as far in advance as possible of, but at least 90 days before, the start of each period.
The infomation the !!RC will need for its review of updated prograns is identified in Appendix A (attached).
Under F0.55(g)(4), the revised inservice inspection and testing prograas must, to the extent practical, comply with the requirements in editions and addenda to the ASME Code tnat are "in effect" no nore than 6 months before the start of the period for which the updated program is applicable.
The tems "in effect".or "ef fective", as used in 550.55a(g)(4), identify those editions and addenda to the ASME Code that have been published by the AStiE and that are also referenced in paragraph (b) of 550.55a.
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3-e Paragraph (b) of 550.55a is amended periodically to incorporate more recent AStjE Code Editions and Addenda. However, the regulations are not amended until after the published ASME Code Editions and Addenda have been reviewed and endorsed by the !!RC.
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 that marks 6 months before the start of a inspection period and the start date itself, the licensee is not re. quired to comply E
with the newly referenced ASME Code Editions and Addenda. Under the regu-lation, the licensee need only comply with the ASME Code Editions and Addenda that were referenced in paragraph (b) of 550.55a 6 months before the start of the period in cuestion.
On the other hand, the regu ation 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 us.ed.
An inservice inspection or testing program does not comply with 550.55a(g)(4) if it is based on an ASME Ccde Edition or Addendum which is not or has not been referenced in paragraph (b) of 550.55a.
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B.
Conforning the Technical Snecifications to 6n Updated Inservice Inscection
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or Testing Program ----- Paragraph 50.Ga(q)(5)(ii):
T If a revised (updated) inservice inspection or testing program conflicts with the Technical Specifications for a facility, the licensee must pro:cse changes to the Technical Specifications to conform then to the updated pro-g..
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 requirenents of the updated program) are nore restrictive than the requirenents 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 progan is less restrictive than a particular Technical Specifi-cation requirement, the licensee must continue to comply with the Technical Specifications until he recuests and is issued a Technical Specification change. The !!RC staff will review such a proposed technical Specification change to determine 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 flRC Staff's view, the most efficient way to eliminate existing or J
potential conflicts from the Technical Specifications is for licensees to propo e. Technical Specification changes that would substitute standard
-language referencing 50.55a(g) in the' place existing inservice inspection and testing requirements.
This should be done at least 6 nonths befo e the start of the first 40-month inspection period for which SC.55a(g) ir applicable.
Sample language for this purpose was sent to licensees earlier this year.
The llRC strongly recomends that licensees adopt the approach of' referenc-ing 50.55a(g), because such referencing will simplify the Technical Specifications by deleting any requirements that are duplicated in the regul ation.
It will also alleviate the need for char.ges whenever an i
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inservice inspection or testing program is updated.
This approach has the added advantage of eliminating the scheduling pressures associated with neeting the 6 months subnittal time requirement for Technical apec-ification changes proposals of 50.55a(g)(2)(ii).
It will also simplify the process by which licensees request, and the !!RC grants, relief from AS!!E Code requirements that have been determined to be impractical.
This is because license amendments (i.e., Technical Specification
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changes) will not be necessary to grant relief.
I Relief from AS!iE Code requirements that are deemed impractical for a facility is further discussed below.
C.
Obtaining Relief from AStiE Code Renuire nts Determined to be Impracti'al -----
Paragraph 50.55a(c)(5)(iii) and (6)(i):
F If certain AS!!E Code requirements are fcund to be inpractical by the licensee, the reguntion requires him to notify the NRC and sub"1it information to suo:crt his findings. The licensee should suomit requests for relief fron AStiE Code requirements that he has detennined to be impractical at least 90 days befora the start of the applicable inspection period.
The information thac is needed by the llRC Staff to evaluate requests for relief from requirements found to be inpractical is ider.tified in Appendix B (attached).
_f The !!RC Staff will evaluate licensee requests for relief and will grant relief, if appropriate, pursuant to 50.55a(g)(6)(i). Unless a licensee is otherwise notified by the ?20, relief from ASilE Code requirements will remain acplicable 4
until the end of each 120-month period.
At that time, tha !!RC will re-evaluate
- t the basis for the detennination that the requireaent is impractical, pursuant to 50.55a(g)(5)(iv).
This re-evaluation will take into account any advances in the state-of-the-art of inservice inspection techniques that may have occurred since the relief was originally granted.
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LU Generally, the licensee will know well in advance of the beginning of any g
inspection period, whether or not a particular ASME Code requirement will be impractical for his facility.
Thus, the licensee should request r elief from ASME Code requirements as far as possible in advance of, but not less than 90 days before, the start of the inspection period.
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submittals are particularly important for the first 40-month inservice inspection and 20-month pump and valve testing period because they will F
enable the !!RC staff to evaluate the information received from all licensees and determine which ASME Code requirements may be generally impractical for various classes of plants.
Early submittals will thereby facilitate earlier feedback to licensees regarding the acceptability of their requests.
The llRC Staff recognizes that it will not be possible in all cases for a p
licensee to determine in advance that any particular ASME Code require-p ment will be impractical for his facility.
In cases where, during the E
process of inspection of testing, certain requirements are found to be impractical due to unforseen circumstances, the licensee may recuest relief at that time.
These occurrences are not expected to be many and are expected
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to result in only minor changes to an inservice inspection or testing progran.
All relief from ASME Code requirements that are determined to be impractical
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for a facility will be granted in the form of a letter within the provisions of 550.55a(g)(6)(i). This written' relief should be incorporated into the document describing the inservice inspection and testing progran retained.
by the licensee.
Notice of.the grant.iag.of relief from ASME Code require-ments will be published in the FEDERAL REGISTER, but the written relief
__.. itself will not become an explicit part of the facility. license or the Technical Specifications.
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APPEf1 DIX A IllFORitATIOff RE0llIRED FOR llRC REVIEW dF IllSERVICE IllSPECT10tl AND TESTIllG PROGRAMS
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Inservice Inspection Programs:
The information submitted for llRC review should include *, as a minimum:
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Identification of the applicable ASME Boiler and Pressure Vessel a.
Code Edition and Addenda J.u E
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The period for which the program is applicable identification of all of the specific compon< ants and parts to bc
- c.. examined for each ASME Code Class (i.e., each Quality Group as defined in Regulatory Guide 1.26, " Quality Group Classifications and Standards for Water, Steam, and Radioactive-Ilaste-Containing Components of fluclear Power Plants"), and the inspection intervals for each Class
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For cach specific component and part; specification of:
i) The examination category as. defined in ASME Section XI ii) The examination method to be used
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iii) The repair requirements r
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Pump and Valve Testing Programs The information submitted for NRC review should include *, as a minimum:
Identification of the applicable ASME Code Edition and Audenda a.
b.
The period for which the program is applicable c.
For Pump Testing: identi fy:
I i) each pump to be tested (name and number) ii) the test parameters that will be measured lii) the test intervals, i.e., monthly during operation, only during cold shutdown, etc,
- Specific written relief from the flRC is required to exclude any ASt1E Section XI Code requirements, 9
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.NRC STAFF GdIDELINES FOR EXCLUDI!!G EXERCISIllG -
(CYCLlHG) TESTS OF CERTAlH VALVES
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DURING PLANT OPERATION
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Any valve which when exercised (cycled) cculd put the plant in an unsafe condition f EE 5
should not be tested.
Below are some examples of the types of valves that should be specifically excluded from exercising (cycling) tests duriag plant operation *:
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w All valv's whose failure in a non-conservative position during the cycling
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e test would cause a loss of systen function should not be exercised. Valves
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in this category would typically include all non-redundant valves in lines
[p such as a single discharge line from 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 mJ For
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category under certain system configurations or plant operating modes.
example, when one train of a redundant system such as ECCS is inoperable,
. :s.;g non-redundant valves in the remaining train should not be cycled since their L
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failure would cause a loss of total system function.
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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 9==:
include all valves in containment penetrations where the redundant valve E
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3.
All valves, which when cycled, 'could subject a system to pressures in excess of their design pressures.
It is assumed for the purpose of a cycling test, 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 P P!E high pressure side of the valve to be cycled.
Valves in this category
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.l shutdown cooling system and, in some cases certain ECCS valves.-
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- All AS!!E Section XI Category A and B valves should be cycled, as practicable, at cach cold snutdown, but need not be cycled nore often than once every 3 nonths.
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i) each valve in ASME Section XI Categories A & B that will be
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.whether partial or full stroke exercise).
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'ii) each valve in ASME Section XI Category A that will be leak tested M,,,-i during refueling outages.
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iii) all valves in ASME Section XI Categories C, D, and E, that will l1. _
be tested, the type of test and the test frequency. For check
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valves, identify those that will be exercised every 3 months and ji ~ ~
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![ "3 those.that will only be exercised during cold shutdown.
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-INFORMATION RE0UIRED FOR !!RC -REVIEW 0F RE0UESTS FOR RELIEF FROM.
E r-AStE CODE SECT 10:1 XI REQUIREMEllTS DETERHit!ED TO BE Il9RACTICAL
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Identify component for which relief is requested:
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Name and number as given in-FSAR E:. 55 b.
Function
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For. valve testing, also specify the ASME Section XI valve category as-j
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Specifically identify the ASME Code requirement that has been determined to be impractical for component.
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Provide information to support the determination that the requirement in (2) is impractical; i.e., state and explain the basis for requesting relief.
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Specify the inservice inspection (or testing) that will be performed in lieu EE
-of the ASME Code Section XI requirements that have been determined to be
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impractical.
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Provide ~ the schedule for implementation of the procedure (s) in (4) above.
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