ML19326C310
| ML19326C310 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 01/16/1978 |
| From: | Desiree Davis Office of Nuclear Reactor Regulation |
| To: | Cavanaugh W ARKANSAS POWER & LIGHT CO. |
| References | |
| NUDOCS 8004220862 | |
| Download: ML19326C310 (15) | |
Text
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a Occket lio. 50-313 JAn 161978 p
Arkansas Power & Light Company ATTli:
Hr. William Cavanaugh, III i
Executive Director, Generation THis DOCUMENT CONTAINS and Construction P. O. Box 551 POOR QUAUTY PAGES --
Little Rock, Arkansas 72203 Gentlecen:
'tC: ARY.tdlSAS h0 CLEAR ONE, UNIT 1 By letter dated Hovember 24, 1976, ve sent ycu a document entitled
"!RC Staff Guidance for Complying v:1tn Certain Provisions of 10 CFR 50.55a(g), Inservice Inspection Renuirements".
In addition to clarifyinc the proper nothods for cocplying with the regulation, this guidance provided a general outline of the type of iafornation that the IRC staff would need to review inservice inspection and testing programs, and to evaluate requests for relief from ASME Code requirenents that are deternined to be impractical for a facility.
Af ter reviewing a number of subnitrals relating to s50.55a(g) recoirements y
frca various licensees, we have concluded that additicnal guidance would
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be useful to all licensers to aid in the oreparation of these subnittals, ti-and to expedite the IRC staff review and approval of the proposed prograas and any requests for relief frem certain AStiE Code requirer,rnts. The need for this guidance is particularly evident for the pump and valve
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testing requirements.
Enclosed for your use is the "f 9.C Staff Guidance for Prenaring Pu.mp and
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Valve Testing Prr.gran Descriptions and Associated Relief Recuests
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Pursuant tc 10 CFR 50.55a(g)". This. enclosure defines the receired i
scope of a ptrrp anc valva testing progran, itemizes the specific
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infomation needed for staff revim, and provides guideltres for i
submittine infornation to support requests for relief tro, any AS1E J
Coce requirenents found to be iveractical for a facility. The sme f
infocation is being sent to all nuclear ocwer plant licensees and is intended to ccMplecont and expan'J on the guidance U0 provided to h'/k f 6D
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. +.5 JAN 161978 Arkansas Power & Light Conpany :...
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you in our previous letter. Alth'ough the enclosure specifically y?9:
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addresses pump and valve testing requirements only, the saree level E=
of detailed infomation identified in this guidance should also be E
provided in inservice inspection progran submittals.
We request that you follN the enclosed guidance to the greatest h.
extent possible when submitting proposed inservice inspection and testing programs and requests ter relief from ASitE Code requirements, a
and when responding to additional infomation requests from the staff.
Your adherence to this guidance will minimize the f.'RC staff review, time needed to approve your proposed prograns and associated relief r==
requests.
If you have any questions regarding implementation of 10 CFR 50.55a(g)
IE st your facility. please contact us.
Sincerely, Don K. Davis, Acting Chief Operating Reactors Branch #2
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Division of Operating Reactors
Enclosure:
DISTRIBUTION:
liRC Staff Guidance Docket
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NRC PDR Local PDR cc w/cnclosure:
See ne.<t page ORB-2 Reading DEisenhut Attorney, OELD l
I&E (3)
RPSnaider JWetmore Rf1Diggs TJCater JRBuchanan TBAbernathy ACRS (16)
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NRC FODI 318 (9 76) NRCM 0243 W u; s. oovenmusu, pamtmo orrics. iero -one.e 4
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3-JAN 161978
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Arkansas Power & Light Coapany
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Phillip K. Lyon, Esquire
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Ilouse, Holms & Jewell 1550 Tower Building.
Little Rock, Arkansas 72201
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!!r. Daniel 11. Willians
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H.inager, Licensing
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Arkansas Power & Light Company
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Post Office Box 551 Little Rock, Arkansas 72203
!!r. John F. Anderson, Jr.
h Plant Superinten<ient Arkansas !!uclear One F
Post Office Oox 608 Russellville, Arkansas 72801
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Arkansas Polytechnic College Russellville, Artansas 72801 e
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C NRC STAFF GUIDANCE FOR PREPARING PUMP AND VALVE TESTING PROGRAM DESCRIPTIONS AND ASSOCIATED RELIEF REQUESTS PURSUANT TO 10 CFR 50.55a(g)
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.
Pump and Valve Testing Program Description 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 eressure Injection System b.
Low Pressure Injection System c.
Accumulator Systems d.
Containment Spray System e.
Primary and Secondary System Safety and Reliaf Valves f.
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 h.
Active Components in Service Water and Instrument Air Systems which are required to support safety system functions 1.
Containment Isolation Valves that are required to change position on a containment isolation signal J.
Chemical and Volume Control System i
k.
Other Ley valves in Auxiliary Systems which are requirad 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 m.
Reactor Coolant System For BWR's:
a.
High Pressure Coolant Injection System b.
Low Pressure Coolant Injection System i
c.
Residual Heat Removal System (Shutdown Cooling System) d.
EmergencyCondenserSystem(IsolationCondenserSystem) e.
Low Pressure Core Spray System f.
Containment Spray System g.
Safety, Relief, and Safety / Relief Valves h.
RCIC (Reactor Core Isclation Cooling) Systen 1.
Containment Cooling System J.
Containment isolation valves that aro required to change position on a containment isolation ".ignal l
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Standby liquid control system (Boron System) i i
1.
Automatic Depressurization System (any pilot or control valves, associated hydraulic or pneumatic systems, etc.)
m.
Control Rod Drive Hydraulic System (" Scram" function) n.
Other key valves in Auxiliary Systems which are required to operate to directly support plant shutdown or safety system function; such as, emergency diesel starting air valves, component cooling water supplies, etc.
o.
The following information should be provided for ND, staff review of the Pump and Valve Testing Programs:
1.
Three sets of P&ID's, that are large and clear enough to be read easily, and which include all of the systems listed above, with the ASME code class and system boundaries clearly marked. The drawings should include all of the components present at the time of submittal and a legend of the P&ID symbols.
2.
Identification of the applicable ASME Code Section XI Edition and Addenda.
3.
The period for which the program is applicable.
4.
Identification of the component ASME Section III Code Class.
5.
For Pump testing, identification of:
a.
Each pump required to be tested (name and number) b.
The test parameters to be measured c.
The test frequency i
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For valve testing, identification of:
a.
Each valve in ASME Section XI Categories A and 8 that will be exercised every three months during nonnal plant operation (indicate whether partial or full stroke exercise, and for power operated valves list the limiting value for stroke time).
b.
Each valve in ASME Section XI Category A that will be leak tested during refueling outages (indicate the leak test procedure you intend to use).
c.
Each valve in ASME Section XI Categories C and D that will be tested, the type of test and the test frequency. For check valves, identify those that
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will be exercised every 3 months and those that will only be exercised during cold shutdown or refueling
- outages, d.
Each valve in ASME Section XI Category E that will be operationally checked.
e.
The following additional information, if practical:
1.
The valve location coordinates or other appropriate location infonnation which will expedite locating the valves on the P& ids.
11.
Identification of all valves that are provided with an interlock to other corrponents and a brief description of that function.
II. Requests for Relief from Certain Pump or Valve Testing Requirements 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 are submitted with a pst fica'. ion such as 4
" impractical", " inaccessible", or any othec categorica! basis, require additional information to allow the stuff to make an I
evaluation of that' relief request. The intention of the guidance i
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set forth below is to illustrate the extent of the information s
that is required by the NRC staff to make a proper evaluation and to adequately document the basis for granting the relief in the i
safety evaluation report. The NRC 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.
A.
Specific information required fo.r NRC review of requests for relief from testing requirements:
1.
Identification of the 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, also specify the ASME Section XI valve category as defined in IWV-2000 2.
Specific identification of the ASME Code requirement that has been determined to be impractical for each component.
1 3.
Information to support the determination that the requirement in (2) is impractical; i.e., state and explain the basis for requesting relief.
4.
Specification of the inservice testing that will be performed 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:
i 1.
" Accessibility":
The regulation allows relief to be granted from code requirements because of insufficient access provisions.
However, a detailed discussion of actual physii.al arrange-ment of the component in question to illustrate the insufficiency of space for conducting the required test d
is necessary.
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, In addition, discussion of the alternative surveillance techniques that have been considered should be provided.
If these alternative techniques have been determined to be impractical, the basis for this detennination should t
be provided.
2.
"EnvironmentalConditionsProhibitive"(e.g.,highradiation level, high temperature, high humidity, 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 been considered should be discussed.
If these alternative techniques have been determined to be impractical, the basis for this detemination should be provided.
3.
" Instrumentation Not Originally Provided":
Information to justify that installation of the needed instrumentation to comply with the code requirementr would 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 should be discussed.
If these alternative techniques have been detennined to be impractical, the basis for this detennination should be provided.
4.
" Valve Cycling During Plant Operation Could Put the Plant in an Unsafe Condition":
A detailed explanation as to why exercising tests d1 ring plant operation could jeopardize the plant safety. Examples of the type of valve that the staff considers to be in this category are: valves whose failure in a non-conservative position during the cycling test would cause a loss of total system functicn; valves whose failure to close during the e
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l cycling test would cause a loss of containment integrity; and valves, which when cycled, could subject a system to pressures in excess of their design pressures. A plant i
specific explanation must be provided.
5.
" Valve Testing at Cold Shutdown or Refueling Intervals 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 the valves where a refueling interval is indicated, the licensee should explain in detail why each valve cannot be exercised during each cold shutdown.
C.
The following acceptance criteria for granting relief are utilized by the staff:
The licensee must successfully demonstrate with documented information that:
1.
Compliance with the code requirements would result in 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 2.
Proposed alternatives to the code requirements or portions thereof will provide an acceptable level of quality and safety.
III. Standard Format for Valve Testing Submittals A recommended 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 this standard format would reduce the time spent by both the staff in its review, and by the licensee in their preparation, of the pump and valve testing program submittals. The standard format includes examples of relief requests which are intended to illustrate the application of the standard format only and are not necessarily applicable to any specific plant, j
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ATTACliMENT I
REC 0m ENDED STANDARD FORMAT FOR VALVE INSERVICE TESTING PROGRAM SUBMITTALS er t
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i SYSTEM NME AUXILIARY COOLANT SYSTEM COMPONENT COOLING P&ID NO.
1045-E-2A PAGE N
D D
g) g REMARKS g
c (Not to be used for relief basis) a
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Valve O
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Valve Category g
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3 3
Number G A
B C
D E g g
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' o 710 3
0-14 X
4 GA M
D-15 X
6 DE NA C
DT 717 3
C-i5 X
16 CK SA CV X
CS 702C 3
C-15 X
16 CK SA CV 707 3
E-14 3
REL SA CV 834 3
D-Il X
X 4
GL M
C Q
X ET MT 60 sec. stroke time 7228 3
B-11 X
8-11 X
A-10 X
B-10 X
0-14 X
10 GA M0 C
Q LT X
MT 30 sec. stroke time i
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LEGEND FOR VALVE TESTING EXAMPLE FORMAT Exercise valve (full stroke) for operability every (3) montns l
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 fulfill their CV function every (3) months SRV - Safety and relief valves are tested per Section XI Article IWV-3510 Test category D valves per Section XI Article IWV-3600 DT Verify and record valve position before operations are performed ET and after operations are completed, and verify that valve is locked or sealed.
Exe'rcise valve for operability every cold shutdown CS Exercise valve for operability every reactor refueling RR
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RELIEF REQUEST BASIS
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System: Auxiliary Coolant Systen, Component Cooling 1.
Valve:
717 Category:
C Class:
3 Function:
Prevent backflow from the reactor coolant pump cooling coils Test Requirement:
Exercise valve for operability every three months Basis for relief:
To test this valve would require interruption 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.
Alternate Testing:
This valve will be exercised for operability during cold shutdowns 2.
Valve:
834 Category:
B-E Class:
3 Function:
Isolate the primary water from the component cooling surge tank during plant operation.
It is normally in the closed position, but i
routine operation of this valve will occur during refueling and cold shutdowns.
Test Requirement:
Exercise valve (full stroke) for operability every three (3) months.
Basis for Relief:
This valve is not required to change position during plant operation to accomplish its safety function. Exercising this valve will increase the possibility of surge tank line contamination.
Alternate Testing:
Verify and record valve position before and after each valve operation.
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Valve:
7448 Category:
A 4
Class:
2 Function:
Isolate the residual heat exchangers from the cold leg R.C.S. backflow and accumulator backflow.
4, 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 r.equired 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 744B we will not achieve a compensatory increase in the level of safety.
Alternate Testing: No alternative seat leak testing is proposed for 744B.
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