ML19329E324
| ML19329E324 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 02/17/1978 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19329E320 | List: |
| References | |
| NUDOCS 8006120632 | |
| Download: ML19329E324 (11) | |
Text
Q NRC STAFF C0! GENTS ON INSERVICE PUl'P AND VALVE TESTING PROG?,AM5 AND RELIEF REQUESTS The NRC staff", after reviewing a number of pump and valve testing programs, has determined that further guidance might be helpful to illustrate the type and extent of informatien we feel is necessary to expedite the review of these programs.
We feel that the Licensee can, by in:orporating these guidelines into each program submittal, reduce considerably the staff's review time and time spent by the Licensee in responding to NRC staff requests for additional information.
The pump testing program shculd include all safety related* Class 1, 2 and.3 pumps which are installed in water cooled nuclear pcwar plants and which are provided with an emergency power source.
The valve testing program should include all the safety related valves in the following systems excluding valves used for operating convenience only, such as manual vent, drain, instrument and test valves, and valves used for maintenance only.
~ PWR a.
High Pressure Injection System b.
Low Pressure Injection System c.
Accumulater Systems d.
Containment Spray System e.
Primary and Secondary System Safety and Relief Valves f.
Auxiliary Feedwater Systems
' g.
Reactor Building Cooling System h.
Active Components in Service Water and Instrument Air Systems which are recuired to support safety system functiers.
i.
Containment Isol.atier. Valves required to chance position to isolate containment.
J.
Chemical & Volu. e Control System k.
Other key components in Auxiliary Systems which are required to directly suoport plant shutdown or -safely systr m fuhetien.
- Safety related - necessary to safely shut down the plant and mitigate the censequences of an accident.
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1.
Residual Haat Removal System m.
a.
High Pressore Core Infection System b.
Low Pressure Core Injection System Residual Haat Removal System (Shutdown Cooling System) c.
d.
Emergency Condenser System (Isolation Condenser System) e.
Low Pressure Core Spray System f.
Containment Spray System g.
Safety, Relief, and Safety / Relief Valves h.
RCIC (Reactor Core Isolation Cooling) System 1.
Containment Cooling System j.
Containment isolation valves required to change positien to isolate containment
.k.
Standby liquid control system (Soron System)
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1.
Autc=stic Depressurization System (any pilot or control valves, associated hydraulic or pneumatic systems, etc.)
m.
Control Rod Drive Hydraulic System (" Scram" function) n.
dther key ce;moonents in Auxiliary Systems which are required to directly suoport plant shutdown or safety system function.
o.
Reactor Coolant System Inservice Pumo and Valve Testing procram l
l
'I.
Information required for i!RC Staff Review of the Pump and Vaive Testing Program A.
Three sets of F&ID's, wiiich include all of the systems listed above, with the code class and system boundaries clearly marked.
The drawings should include all of the ccmponents present at the time of submittal and a legend of t.je P&ID symbols.
B.
Identification of the applicable ASME Code Editien and Addenda C.
The period for which the program is applicable.
D.
Identify the component code class.
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E.
For Pump testing:
Identify l.
Each pump recuired to be tested (nanc and nunte~r)
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2.
The test parameters to be measured 3.
The test frequency F.
For valve testing:
Ident).y 1.
Each valve in ASME Section XI Categories A & S that will be exercised every thnte months during nomal plant operation (indicate whether partial or full stroke exercise, and fcr power operated valves list the limiting value for stroke time.)
2.
Each valve in ASME Section XI Category A that will be leak,
tested during refueling cutages (Indicate the leak test procedure ycu intend to use) 3.
Each valve in ASME Section XI Categories C, D 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 cnly be exercised during cold shutdown or refueling outages.
II. Additional Information That Will Be Helpful in Speeding Up the Review Process A.'
Include the valve locatien coordinates or other aopropriate location information which will expedite our locating the valves on the P& ids.
B.
Provide P&ID drawings that are large and clear enough to be read easily.
C.
Identify valves that are provided with an interlock to other components and a brief description of that function.
Relief Recuests frem Section XI Recuircrents The largest area of concern for the MRC staff, in the review of an inservice valve and pump testing program, is,in evaluating the basis for justifying relief frem Sectica XI Require =ents.
It has been our ex;drience l
A
. that many requests for relief, submitted in these programs, do not provide adequate descriptive and detailed technical informatien. This explicit information is necessary to provide reasonable assurance that the burden imposed on the licensee in complying with the coce requirements is not justified by the increased level of safety cbtained.
Relief requests which are submitted with a justification such as
" Impractical", " Inaccessible", or any other categorical basis, will require additional information, as illustrated in the enclosed examples, to allcw our staff to make an evaluation of that relief request. The intention of this guidance is to illustrate the content and extent of infor=ati6n required
. by the NRC staff., in the request for relief, to make a proper evaluation dnd adequately document the basis for that relief in our safety evaluatien report. The.HPC staff feels that by receiving this information in the program submittal, subsequent requests for additional information and delays in completing our review can be considerably reduced or eliminated.
I.
Information Recuir2d for NRC Feview of Relief Recues_ts A.
Identify ccmponent for which relief is requested:
1.
Name and number as given in FSAR 2.
Function
- 3. 'ASME Section III Code Class 4.
For valve testing, also specify the ASME Section XI valve
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category as defined in IWV-2000 B.
Specifically identify the ASME Code requi,rement that har been determined to be impractical for each ccmponent.
C.
Provide information to support the determination that the requirement in (B) is impractical; i.e., state and explain the basis'for requesting relief.
D.
Specify the inservice testing that will be performed in lieu of the ASME Code Section XI requirecents.
E.
Provide the schedule for implementation of the proceduro(s)
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3.
. Examples to Illustrate Several Foss'ible Amas Where Relief May Be II.
Granted and the Extent and Content of Information Necessary to Make An Evaluation A.
Accessibility: The mgulatica specifically grants relief from the code requirement because of insufficient access pro-However, a detailed discussion of actual physical visions.
arrangement of the component in question to illustrate the insufficiency of space for conducting the required test is necessary.
Discuss in detail the physical arrangement of the component I
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in question to demonstrate that there is not sufficient space
'to perform the code required inservice testing.
What alternative surveillance means which will provide an' acceptable level of safety have you considered and why are these means not feasible?
Environmertal Conditions (e.g., High radiation level, High B.
temperature, High humidity, etc.)
?
Although it is prudent to maintain occupation radiatien exposure for: inspection personnel as low as practicable, the request for relief frem the code requirements cannot be granted solely en the basis of high radiation levels alone. A balanced judgment
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between the hardships and compensating increase in the level of safety should be carefully established.
If the health and safety of the public dictates the necessity of inservice testing, alternative neans or even decontamination of the plant if necessary should be provided or develepad.
Pro' vide ad'diticnal information regarding the radiaticn levels at the required test location. What alternative testing technicues which will provide an acceptable level of assurance of the integrity of the c mpenent in question have you considered ar.d*
why are these techniques determined to be impractical?
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C.
Instrumentation is not originally provided Provide infomstion to justify that compliance with 'the code requirements would result in undue burden or hardships withcut a compensating increase in the level of plant safety. What alternative testing methods which will provide an acceptable level of safety have you considered and why are these methods determined to be impractical?
D.
Valve Cycling During Plant Operation Could Put the Plant in i
an Unsafe Condition The licensee should explain in detail why exercising t'ests -
during plant operation could jeopardize the plant safety.
E.
Valve Testing at Cold Shutdown or Refueling Irtervals in 1.ieu of the 3 Month Kequired 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 indicaced, explain in detail why each valve cannot be exercised during cold shutdown intervals.
III. Acceptance Criteria for Relief Racuest The Licensee must 50ccessfu11y demonstrate that:
1.
Compliance with the code requirements would result in hardships or unusual difficulties without a compensating increase in the level of safety and concompliance will provide an acceptable levei of quality and safety, or 2.
Proposed alternatives to the code requirements or portions thereof will provide an acceptable level of quality and safety.
Standard Format A standard format, for the valve portion of the pump and valve testing program and relief requests, is included as an attachment to this Guidance.
l The NRC staff believes that this standard format will reduce the tim spent l
by both the staff in our review and by the licensee in their preparatien.
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s' of' the pump and valve testing program and submittals. The standard femat includes examples of relief requests which are intended to illustrate the application of the standard format and are not necessarily a specific plan-relief request.
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<s Relief Recuest Basis System: Auxiliary Coolant System, Ccmponent Cooling 1.
Valve:
717 Category:
C Class:'
3 Function:
Prevent backficw 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 uasafe mode of operation.
Alternative This valve will be exercised for operability Testing:
during cold shutdowns.
2.
Yalva:
834 Category:
B-E Class:
3 Function:
Isolate the primary water frca the compenent cooling surge tank during plant ope, ration.
It is, normally in the cicsed position, but routine operat.icn 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 requirgd to change positien during plant operation to acccmplish its saft:y functicn. Exercising this valve will increase :ne possibility of surge tankline contaminaticn.
Alternate Verify and record valve positien befcre and Testing:
and after each valve. operation.
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Yalve:
7448 Category:
A Class:
2 Function:
Isolate the residual heat exchangers from the ccid leg R.C.S. backflow and accumulatier backflew.
Test Requirements: Seat leakage test Basis for This valve is 1ccated in a high radiation field Relief:
(2000 mr/hr) which would make the required seat leakage test hazardous to test personnel. We intend tn seat leak te:t two other valves (3?53 and 876B) which are in series with this valva and v;ill also prevent backflow. We feel
- that by complying with the seat leakage requirerents we will not achieve a compensatory increase in the level of safety.
Alternative No alternative seat leak testing is proposed..
Testing:
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