ML19309B043
| ML19309B043 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 01/10/1978 |
| From: | Reid R Office of Nuclear Reactor Regulation |
| To: | Mattimoe J SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| References | |
| TAC-10816, TAC-11288, NUDOCS 8004020518 | |
| Download: ML19309B043 (15) | |
Text
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January 10, 1978 DISTRIBUTION:
.y Docket f o.:
50-312 ORB #4 Rdg RReid RIngram L01shan x=-
TJCarter Sacranento Nnicipal Utility District JWetmore ATTH: Mr. J. J. Itattimore Attorney, OELD Assistant General Manager OI&E (3) and Chief Engineer DEisenDut
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6201 S Street TBAbernathy 7.;
mm P. O. Dox 15830 JRBuchanan Sacramento, California 95813 ACRS (16)
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Gray File Gent 1emen:
n;:au 17, 1976, we sent you a docunent
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Sy letter dated Hovec:ber
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entitlec "MC Staff Guidance for Complying with Certain Provisions of 10 Cr?. 50.55a(g), Inservice Insucction Requirements".
In addition to clarifying the proper nethods for complying with the regulation, this
==
guidance provided a general outline of the type of infornation that the rd.C staff would need to review inservice inspection and testing g=g;.. -
programs, and to evaluate requests for relief fron AS"E Code requirements F"' 'i;k:_
that are determined to be inpractical for a facility.
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After reviewing a number of submittals relating to s50.55a(g) requireaants from various licensees, we have concluded that additional guidance would
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be useful to all licensees to aid in the preparation of these submittals, and to expedite the NRC staff review and approval of the proposed programs and any requests for relief from certain ASiiE Code recuircrents. The need for this guidance is particularly evident for the puop and valve
,_... ll.T testing requiren:ents.
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!EH=Et Enclosed for your use..; the "HRC Staff Guidance for Preparing PU::p and f"""""
Valve Testing Progran Descriptions and Associated Relief Requests Pursuant to 10 CFR 50.55a(g)". This enclosure defines the required scope of a pump and valve testing progran, iterizes the specific
......;;;7 infomation needed for staff review, and provides guidelines for
== = =r sut mitting infomation to support recuests for relief from any ASME
-~...... ll Code r equirecents found to.be impractical for a facility. The same EEE:
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infornation is being sent to all nuclear power plant licensees and is intended to complenent and expand on the guirlance we provided to y
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!!ir you in our previous letter. Although the enclosure specifically addresses pump and valve testing requirements only, the same level
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of detailed infomation identified in this guidance should also be
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provided in inservice inspection prograa subnittals.
We request that you follow the enclosed cuidance to the greatest extent possible when subattting proposed inservice inspection and
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testing programs and requests for relief from ASitE Code requirements.
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and when responding to additional inforaation requests from the staff.
I:?---- a Your adherence to this guidance will minimize the !!RC staff review tine needed to approve your proposed programs and associated relief
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ZG requests.
If 'you have any questions regarding implementation of 10 CFR 50.55a(g)
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at your facility, please contact us.
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' ZZ-Sincerely,
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Robert W. Reid, Chief Operating Reactors Branch #4 Division of Operating Reactors
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Enclosure:
7 NRC Staft Guidance
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',Sacramentor::;nicipal Utility District ~
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< cc:' David S. Kaplan, Secretary and
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General Counsel Z-
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6201 S Street
. Post Office Box 15830
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":j Sacramento,~ California 95813 Business and Municipal Department Sacramento City-County Library
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NRC STAFF GUIDANCE FOR PREPARIt:G PUMP AND VALVE TESTING PROGRAM DESCRIPTIONS AND ASSOCIATED
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RELIEF REQUESTS PURSUANT T0 10 CFR 50.55a(g)
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...$.N The guidance provided in this enclosure is intended to illustrate 21
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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
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respond to additional information requests from the NRC staff.
I.
Pump and Valve Testing Program Description
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A.
Scope'of the Program:
1.
The pump testing program should include all safety related*
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Class 1, 2. and 3 pumps that are provided with an emergency power source.
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2.
The valve testing program should be limited to the safety
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related* valves. All such valves must be addressed in the program and should include, as a minimum, those in the "E
following systems.
Valves in these systems which are
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used for operating convenience only - such as manual vent, drain, instrument and test valves, and valves
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used for maintenance only should be excluded.
For PWR's:
a.
High Pressure Injection System b.
Low Pressure Injection System
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Accumulator Systems
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d.
Containment Spray System
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Primary and Secor.dary System Safety and Relief Valves
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Auxiliary Feedwater Systems
- Safety related are those pumps and valves necessary to safely shut' down the plant or mitigate the consequences of an accident.
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Reactor Building Cooling System
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9 Active Components in Service Water and Instrument h.
Air Systems which are required to support safety system functions
==.,==.4 Containment Isolation Valves that are required to c;.j i.
change position on a containment isolation signal
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- j. Chemical and Volume Control System t:gj==
Other key valves in Auxiliary Systems which are z.=:d
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required to operate to directly support plant shutdown or safety system function; such as, emergency diesel starting air valves, component
==i cooling water supplies, etc.
1.
Residual Heat Removal System
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Reactor Coolant System For BWR's:
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High Pressure Coolant Injection System a.
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b.
Low Pressure Coolant Injection System
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Residual Heat Removal System (Shutdown Cooling System) c.
Emergency Condenser System (Isolation Condenser System) d.
Low Pressure Core Spray System e.
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Containment Spray System
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. l Safety, Relief, and Safety / Relief Valves g.
RCIC (Reactor Core Isolation Cooling! Systen
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- i. Containment Cooling 5.sstem-Containment isolation valves that ar" required te chance J.
x; position on a containment isolation 3igndi 3
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Standby liquid control system (boron System) 5#"'.;=G k.
Automatic Depressurization System (any pilot or control-1.
valves, associated hydraulic or pneumatic systems, etc.)
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Control Rod Drive Hydraulic System (" Scram" function)
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Other key valves in Auxiliary Systems which are required to operate to directly support plant shutdown n.
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or safety system function; such as, emergency diesel starting. air valves, component cooling water supplies,
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etc.
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Reactor Coolant System The following information should be provided for NRC staff review
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of the Pump and Valve Testing Programs:
Three sets of P&ID's, that are large and clear enough to
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be read easily, and which include all of the systems listed above, with the ASME code class and system
,.67 The drawings should include boundaries clearly marked.
all of the components present at the time of submittai and a legend of the P&ID symbols.
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Identification of the applicable ASME Code Section XI 2.
Edition and Addenda.
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=ieg The period for which the program is applicable.
==.q 3.
Identification of the component ASME Section III Code 4.
Class.
5.
For Pump testing, identification of:
Each pump required to be tested (name and number) a.
The test parameters to be measured
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b.
c.
The test frequency
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6.
For valve testing, identification of:
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a.
Each valve in ASME Section XI Categories A and B that
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will be exercised every three months during nonnal
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plant operation (indicate whether partial or full
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stroke exercise, and for power operated valves list
...T. "5 the limiting value for stroke time).
Each valve in ASME Section XI Category A that will
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be leak tested during refueling outages (indicate the
==g.j leak test procedure you intend to use).
- 1 Each valve in ASME Section XI Categories C and D
~~ :
~q that will be tested, the type of test and the test c.
For check valves, identify those that frequency.
will be exercised every 3 months and those that will j], ;"
only be exercised during cold shutdown or refueling outages.
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Each valve in ASME Section XI Category E that will d.
be operationally checked.
The following additional information, if practical:
==
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The valve location coordinates or other i.
appropriate location information which will expedite locating the valves on the PF. ids.
Identification of all valves that are provided ii.
.r with an interlock to other conponents and a 7.7M1 brief description of that function.
"rs... s.,
Requests for Relief from Certain Pump or Valve Testing Require! rents
=.,
II.
- E It has been-the. staff's experience that many requests for relief sigi from testing requirements, submitted by li:ensees, have not been "FJ supported by adequate descriptive and de'cailed technical information.
"==i TMs detailed information is necessary to document why the burden "25Y imposed on the licensee in complying with the code requirements is not justified by the increased level of safety obtained from the testing.
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Relief. requests which arc '.abaitted with a jun fica'. inn sucn as 7~
" impractical", "inaccessitrie". or any. Othre c>itegorice! basis,
==W require additional infomation to allow tne staff tc m6ke anThe.intentinn of the g
. evaluation of-that relief request.
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T:.1" set forth below is to illustrate :the extent of the infcrmation that is required by the NRC. staff to make a proper evaluation and
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to adequately document the basis for granting the relief in the
-- 12:4 2j safety evaluation report.. The NRC staff believes that if this l
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.
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=====1 A.
Specific infomation required for NRC review of requests for
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relief from testing requirements-
..q Identification of the component for which relief is recuested:
{
1.
Name and number as given in FSAR 3
a.
?55.
.3 b.
Function
.... 4 c.
ASME Section III Code Class d.
For valve testing, also specify the ASME Section XI valve category as defined in IWV-E000 i.=4
- -.1 2.
Specific identification of the AStiE Code requirement that has been determined to be impractical for each component.
3.
Information to support the determination that the requirement in (2) is impractical; i.e., state and explain the basis
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for requesting relief.
Specification of the inservice testing that will be performed
=
4.
in lieu of the ASME Code Section XI requirements, if any.
-e The schedule for implementation of the procedure (s) in 5.
(4).
- r;-
Examples to illustrate several possible areas where relief B.
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 granted from code requirements.because of insufficient access provisions..
= = =
However, a detailed discussion of actual ;)hysical arrange-s==;
ment of the component in question to illustratt the S
n{},D) insufficiency of space for conducting the required te Ug
'is necessary.
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E If these alternative techniques have been detemined to be impractical, the basis for this determination should be provided.
" Environmental Conditions Prohibitive" (e.g., high radiation 2.
level, high temperature, high. humidity, etc.):
Although it is prudent to maintain occupation radiation exposure for inspection person iel as low as practicable, the request for relief from code requirements cannot
- l;;y be granted' solely o,i the basis of high radiation levels.
===4 A balanced judgment between the hardships and compensating
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increase in the level of safety must be explicitly justified.
3erefore, detailed infomation regarding the radiation levels at the required test location, along with estimated
==
yearly man-rem exposures associated with the testing, should E==
be provided. Alternative testing techniques that have
==
If thest 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.
Information to justify that installation of the neerted
==
++7 "i=E instrumentation to comply with the code requirements would result in undue burden or hardships without a compensating increase in the level of plant safety should be provided.
..=E Alternative testing techniques that have been considered If these alternative techniques should be discussed.
Fave been detemined to be impractical, the basis for 7"~ E E, this detemination should be provided.
" Valve Cycling During Plant Operation Could Put the Plant
==F 4.
in an Unsafe Condition":
= =:
A detailed explanation as to why exercising tests d; ring Examples
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plant operation could jeopardize the plant safety.of the ty valves whose failure in a non-conservative
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position during the cycling test would cause a loss of total
.;;;lly; category are:
system function; valves whose iailure to close during the
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a cycling test would cause a loss of containment integrity-
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and valves, which when cycled, could subject a system to
--d A plant pressures in excess of their design pressures.
specific explanation must be provided.
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" Valve Testing at Cold Shutdown or Refueling Intervals
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in lieu of the 3 Month Required Interval":
.
The licensee should explain in detail why each valve "E
.4 cannot be exercised during n. rmal operation. Also, for
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the valves where a refueling interval is indicated, the l.:]
licensee should explain in detail why each valve cannot
=.: 5.j 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
- . =.
ge::
information that:
55 Compliance with the code requirements would result in
=. ll.
1.
hardships or unusual difficulties without a compensating
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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 s=
2.
thereof will provide an acceptable level of quality and
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safety.
.2..q Standard Fomat for Valve Testino Submittals 35]
Ill.
A reccmended standard format, for the valve portion of the pump "i[j and valve testing program and relief requests, is included as an
=
The NRC staff believes thau the use attacMient to this Guidance.
==
of this standard fomat would reduce the time spent by both the
=
staff in its review, and by the licensee in their preparation, of The standard Il the pump and valve testing program submittals.
fomat includes examples of relief requests which are intended f.~
to illustrate the application of the standard fomat only and
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are.,ot necessarily applicable to any specific plant.
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El:a ATTAQl4ENT E',
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...g RECOMMEtiDED STANDARD FORMAT FOR
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VALVE INSERVICE TESTI!1G PROGRAM'SUBMITTALS h~d.".~..~'.'.
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AUXILIARYC00LAliTSYSTEMC0!FbbEllTCOOLING P&ID H0. 315-E -2A PAGE SYSTEtt HNE I
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REMARKS c
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(Not to be used for relief basis)
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Valve C
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I Valve Number $- $
A B C D L 710 3
D-14 X
4 GA M
D-15 x
6 DE NA-C DT 71 7 3
C-15' X
16 CK SA CV X
CS g
702C 3
C-15 X
16 CK SA CV 707 3
E-14 X
3 REL SA CV 834 3
D-ll X
X 4
GL M
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X ET MT 60 sec. stroke sime 722B 3
B-11 X
j 722C 3
B-ll X
A-10 X
B-10 X
D-14 X 10 GA M0 C
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MT 30 sec. stroke time
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LEGEND FOR VALVE TESTING EXN4PLE FORMAT-geg.g
. Exercise valve (full. stroke) for operability every (3) months
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- Valves are leak tested per Section XI Article IWV-3420 LT MT - Stroke time measurements are taken and compared to the stroke
- ....z;;;;..l5 time limiting value per Section XI Article IWV 3410
- Exercise check valves to the position required to fulfill.their CV function every (3) months SRV - Safety and relief valves are tested per Section XI Article
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. IWV-3510
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.._.1 Of - Test category D valves rer Section XI Article IWV-3600
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- Verify and record valve position before operations are performed ET and af ter operations are completed, and verify that valve is
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locked or sealed.
- Exercise valve ~ for operability every cold shutdown CS
- Exercise valve for operability every reactor refueling
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RELIEF REQUEST BASIS
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Auxiliary Coolant System, Component Cooling 1
System:
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1.
Valve:
717-T..:.
C Category:
Class:
3.
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Prevent backflow from the reactor coolant Function:
pump cooling coils t.........;;;.l
~~a Exercise valve for operability every three
=== =i.d Test Requirement:
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months ac..._....;
=q To test this valve would require interruption
- S"~E3 Basis for relief:
of cooling water to the' reactor coolant pumps motor cooling coils. This action
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l could result in damage to the reactor
==
l coolant. pumps and thus place the plant
~
in an unsafe mode of operation.
This valve will be exercised for operability l
l Alternate Testing:
during cold shutdowns
- 5 2.
Valve:
834 B-E
==f '
l Category:
Class:
3 Isolate the primary water from the component Function:
cooling surge tank during plant operation.
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==
It is normally in the closed position, but T~n routine operation of this valve will occur l
= = =
l during refueling and cold shutdowns.
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=
Exercise valve (full stroke) for operability Test Requirement:
every three (3) months.
This valve is not required to change position
~ ~ ~.
Basis for Relief:
during plant operation to accomplish its l
safety function.
Exercising this valve
=f will increase-the possibility of surge tank g= g.g line contamination.
E.
f Verify and record valve position before end Alternate Testing:
l after each valve operation.
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Valve:
7448 Category:.
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Class:
2
==
Isolate the residual heat exchangers from Function:
the cold leg R.C.S. backflow and accumulator backflow.
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Test Requirements: Seat leakage test
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Bases for relief:
This valve is located in a high radiation
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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
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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 2,....
in the level of safety.
Alternate Testing: No alternative seat leak testing is x=
proposed for 744B.
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