ML19332K079
| ML19332K079 | |
| Person / Time | |
|---|---|
| Site: | Monticello, Prairie Island  |
| Issue date: | 11/24/1976 |
| From: | Ziemann D Office of Nuclear Reactor Regulation |
| To: | Mayer L NORTHERN STATES POWER CO. |
| References | |
| NUDOCS 9106190430 | |
| Download: ML19332K079 (12) | |
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Docket WoGO-2W 50-306 1
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Northern States Power Company ATTV:
Mr. L. G. Nayer, Manager Nuclear Support Services 414 Nicollet Mall - 8th Floor tdinneapolis, Minnesota 55G1 Gentlemen:
RE: MONTICELLO NUCLEAR GENERATI+1G PLANT, LICENSE O. D?R-22 PRAIRIE ISLA!;D KUCLEAR GENERATINC PLANT UNIT L'O. 2, LICE 4SE a'O. OR-60 l
Earlier this year we sent letters to licensees of operating nuclear pouar plants notifying tnen of a revision to 10 CFR Part 50, Section 50.5Sa which was published in the Federal Register on February 12, 1976 (41 FR 62561.
The revised regulation changed the inservice inspection and testinq require-i ments for nuclear power plant components contained in raragrapn (c) of 150.55a.
A letter regarding this subject was sent to you on April 23, 1976.
Since that time, the NRC has receiver! a number of inquiries froa licensaes recarding acceptable methods for complying with tne reg'Jlation.
In eenerrl, the inquiries have Deen directed toward three major areas relative to compliance with the regulation:
1.
The determination of which ASME Boiler and Pressure Vessel Code Edition and Addenda are applicable for any updated inservice inspection or testing program, 2.
The requirement to conform tne Technical Specifications to a revisrc progran, and 3.
The process of obtaining relief f rom ASME Code requiremnts found to be impractical.
Consequently, we are transmitting for your use, Enclosure 1:
"hPC Staff @idance For Couplying with Certain Provisions of 10 CFR 50.55alg), Inservice Inspection Requirements". This enclosure describes the najor provisions of the revised regulation, addresses the areas of licensee concern listed above, and pro-l vides guidance on infor9ation which tne tJRC staff will need to review inservice inspection and testing progratps and to evaluate requests for relief fron ASME Code requirements that are detencined to be impractical. We believe this r theyr) r
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Northern States Power Company NOV a 1976 i
We reiterate our previous request that you submit proposed Technical Specification changes to incorporate standard language referencing i
I 50.55a(g), at least 6 months before the start of the next 40-month inspection period for your facilities. Also, as discussed in Enclosure 1 you should submit a description of your planned inservice inspection and testing programs, as well as any request for relief from ASME Code requirements detemined to be imoractical for your facilities, as far
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in aavance as possi'>le ef, but at least 90 days before, the start of any c0-month inservice inspection period, or 20-month pump and valve testing perf oc.
In aodition, wc would like to cr.phasize an it'portant point regardinc tne ASHE Code Section XI requ{rements to test selected pumps and valves, that are now incorporated in s50.55a(g):
The AS"E Code Section XI recuirements apply coly to selected valves and punos that can De tested without placing the plant in an unsafe condition. You should exercise care in planning your testing procrans to ensure that no test will be conducted while the plant is in an operating mode that would make it vulnerable to a test error or a test failure. Particular attention should be directed toward the valve exercising (cycling) tests.
In this regard, some basic guidelines for excluding exercising (cycling) tests of certain valves durino plant operation are contained in Enclosure 2.
Valve leakace tests and other valve and pump tests required by the ASME Code, should be reviewed for each component, relative to each plant operating F.oce, to ensure that no test will have an adverse impact on plant safety.
If you have any f urther questions reoarding implementation of 10 CFR 50.55a(g) at your facilities, please contact us.
Sincerely, ps m al Sirned bye p,Jnts L. Liceann Dennis L. 7temann, Chief Operating Reactors Branch #2 Division of Cperating Reactors DISTRIBUTION
Enclosures:
Docket (2)
RPSnaider TBAbernathy 1.
4RC Staff Guidance for Complying NRC PDR (2)
PW0'Connor JRBuchanan with Certain Provisions of Local PDR MGrotenhuis ACRS (16) 10 CFR 50.55a(g)
ORB #2 ReadingEAReeves 2.
Guidelines for Excludin9 VSTello JWetmore Exercising (Cycling) Tests TJCarter OELD - Stewis/GLEwis/ Riddle ;
of Certain Valves Durin9 DLZiemann 01&E (3) x y
Plant Operation m ov u,,,,e nri c a,,+
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Forms AEC 338 (Rev. 9 53) AECM C240 W u. a. oovan=ws=T Panaviae or asees isu.ese. nee i
1 Northern Dates Power Company '
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cc w/ enclosures:
Gerald Charnoff, Esquire Shaw, Pittman, Potts and Trowbridge 1800 M Street, N. W.
Washington, D. C.
20036 Arthur Renquist, Esquire Vice President - Law Northern States Power Company 414 Nicollet Mall Minneapolis, Minnesota 55401 Howard J. Vogel, Esquire Legal Counsel 2750 Dean Parkway Minneapolis, Minnesota 55416 i
I Mr. Steve J. Gadler 2120 Carter Avenue St. Paul, Minnesota 55108 Mr. Kenneth Dzugan Environmental Planning Consultant Office of City Planner Grace Building 421 Wabasha Street St. Paul, Minnesota 55102 j
Sandra S. Gardebring, Esquire Special Assistant -Attorney General Minnesota Pollution Control Agency 1
1935 W. County Road B2 Roseville, Minnesota 55113 Anthony Z. Roisman, Esquire 1
Roisman, Kessler and Cashdan 1025 15th Street, N.
W., 5th Floor Washington
.D.
C.
20005 i
The Environmental Conservation Library Minneapolis Public Library l
300 Nicollet Mall Minneapolis, Minnesota 55401
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l ENCLOSURE 1
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WRC STAFF GUIDANCE FOR COMPLYING WITH CERTAIN PROVISIONS OF 10 CFR 50.55a(g) *1NSERVICE INSPECTION REQUIREENTS"
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INTRODUCTION 12, 1976 Paragraph 50.5Sa(g) of 10 CFR Part 50 was revised on February j
(41 FR 6256). Since then, a number of licensees have requested that the NRC clarify several key provisions contained in the revised regulation.
i (1) the requirements to periodically l
These key provisions relate to:
i update the inservice and testing programs to comply with :
Specifications to a revised inservice inspection or testing progra:
Code requirements that the licensee considers to be impractical for i
The purpose of this document is to briefly summarize his facility.
the major provisions of the revised 550.55a(g) and to provide general The document is in no way intended guidance in these three key areas.to encompass all aspects of attaining com II.
SUMMARY
OF REGULATION The revised 550.55e(g) contains provisions that require inservice inspec-tion and testing of ASME CoJe Class 1, 2, and 3 nuclear power plant com-ponents (including supports) to be perfomed in accordance with Section XI For of the ASME Boiler & Pressure Vessel Cede and apr3fcable Addenda.
operating facilities whose Operating ticense (Gi
- vas issued before March 1,1976, these provisions of the regulatioi apply at the start of the i
The next regular 40-month inspection period af ter September 1,1976.
start of the 'next 40-month period is detemined by measuring a series of For i
such periods beginning at the start of facility commercial operation.
i facilities that received OL's on or after March 1,1976, these provisions of the regulation apply at tha start of commercial operation.
i As a result of the February 1976 amendment, 550.55a(g) now specifies inservice inspection and testing requirements for all operating plants, e
including those that received a Construction Pemit (CP) before January 1, l
1971.. Since planc designs and access provisions for inservice inspections -
l have progressed over the years, the regulation provides recognition of i
this fact by grouping design requirements for component inspectability The regulation further specifies l
based on a facility's CP issuance date.
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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l An important part of the revised 50.55a(g) is the incorraration of the ASME Code Section XI requirements for testing pumps and valves for opera-1 tional readiness along with the inservice inspection requirements. This means that in addition to a facility's inservice insection program, a 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 inspection program must be updated every 40 months while the pump and valve testing program must be updated every 20 months. Furthemore, 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 Addendum 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 detemined to be impractical for a facility and specifically allow the NRC to require a licensee to follow an augmented inservice inspection program on components for which added assurance of structural reliability is needed.
Selected provisions of the revised regulation are discussed below.
III. General Guidance for Compliance with Three Key Provisions of 150.55a(g):
A.
Updating Inservice Inspection and Testing Programs
Paragraph 50.55a (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 'nonths. A description of the updated programs should be submitted to the NRC 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)(4), the revised inservice inspection and testing programs must, to the extent practical, comply 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 program is applicable. The terms "in ef fect" or "ef fective", as used in 150.55a(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.
Paragraph (b) of 550.55a is amended periodically to incorporate more recent ASME 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 NRC. Therefore, the ASME Code Edition and Addenda that are applicable to any inspection period are those referenced in paragraph (b) of 350.55a 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 required to comply 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 (3) of $50.55a 6 months before the start of the period in question. On the other hand, the regulation 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 n'ot comply with 550.55a(g)(4) if it is based on an ASME Code Edition or Addendum which is not or has not been referenced in paragraph (b) of 550.55a.
B.
Cg isrming the Technical Specifications to an Updated Inservice Inspection y Testing Program ----- Paragraph 50.55aig)(5)(ii):
If a revised (updated) inservice inspection or testing program conflicts with the Technical Specifications for a facility, the licensee must propose changes to the Technical Specifications to confom 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 rehulation (thus the requirements of the updated program) are 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 riust 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 detemine if it is acceptable or whether the existing reqire-ment should be retained as an augmented requirement pursuant to 150.55a(g)(6)(ii).
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In the NRC Staff's view, the most efficient way to eliminate existing or potential conflicts from the Technical Specifications is for licensees to propose Technical Specification changes that would substitute standard language referencing 550.55a(g) in the place of existing inservice inspection and testing requirements. This should be done at least 6 months before the start of the first 40-month inspection period for which 150.55a(g) is applicable. Sample language for this purpose was sent to licensees earlier this year.
The NRC strongly recommends that licensees adopt the approach of referenc-ing E50.55a(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 changes whenever an inservice inspection or testing program is updated. This approach has the added advantage of eliminating the scheduling pressures associated with meeting the 6 months submittal time requirement for Technical Spec-ification changes proposals of 50.55a(g)(2)(ii).
It will also simplify the process by which licensees request, and the NRC grants, relief from ASME Code requirements that have been detemined to be impractical.
This is because license amendments (i.e., Technical Specification changes) will not be necessary to grant relief.
Relief from ASME Code requirements that are deemed impractical for a facility is further discussed below.
C.
Obtaining Relief from ASME Code Requirements Determined to be Impractical -----
Paragraph 50.55a(g)(5)(iii) and (6)(i):
If certain ASME Code requirenents are found to be impractical by the licensee, the regulation requires him to notify the NRC and submit infomation to support his findings. The licensee should submit requests for relief from ASME Code requirements that he has detemined to be impractical at least 90 days before the start of the applicable inspection period. The infomation that is needed by the NRC Staff to evaluate requests for relief from requirements found to be impractical is identified in Appendix B (attached).
The NRC Staff will evaluate licensee requests for relief and will grant relief, if appropriate, pursuant to ISO.55a(g)(6)(1). Unless a licensee is otherwise notified by the NRC, relief from ASME Code requirements will remain applicable until the end of each 120-month period. At that time, the NRC will re-evaluate the basis for the detemination that the recuirement 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.
-5 Generally, the licensee will know well in advance of the beginning of any inspection period, whether or not a particular ASPIE Code requir be impractical for his facility.
from ASME Code requirements as far as possible in advance of, but not Early less than 90 days before, the start of the inspection period.
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 information received from all lice and determine which ASME Code requirements may be generally icpractical for various classes of plants. Early submittals will thereby facilitate earlier feedback to licensees regarding the acceptability of their requests.
The NRC Staff recognizes that it will not be possible in all cases for a licensee to determine in advance that any particular ASME Code require-In cases where, during the ment will be impractical for his facility.
process of inspection of testing, certain requirements a These occurrences are not expected to be many and are expected at that time.
to result in only minor changes to an inservice inspection or testing program.
All relief from ASME Code requirements that are determined to be impractical for a facility will be granted in the form of a letter within the provisions This written relief should be incorporated into the of 550.55a(g)(6)(1).
document describing the inservice inspection and testing program retained Notice of the grantins of relief from ASME Code require-by the licensee.ments will be published in the FEDERAL REGISTFR, but the written itself will not become an explicit part of the facility license or the Technical Specifications.
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APPENDIX A INFORMATION REQUIRED FOR NRC REVIEW 7
0F INSERVICE INSPECTION AND TESTING PROGRAMS 1.
Inservice Inspection Programs:
The infomation submitted for NRC review should include *, as a minimum:
a.
Identification of the applicable ASME Boiler and Pressure Vessel Code Edition and Addenda j
b.
The period for which the program is applicable c.
Identification of all of the specific components and parts to be i
examined for each ASME Code Class (i.e., each Ouality Group as defined in Regulatory Guide 1.26, " Quality Group Classifications and Standards l
for Water, Steam, and Radioactive-Waste-Containing Components of l
Nuclear Power Plants"), and the inspection intervals for each Class 1
or Quality Group e
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For each specific component and part; specification of:
- 1) The examination category as defined in ASi1E Section XI f
ii) The examination method to be used e
iii) The repair requirements f
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Pump and Valve Testing Programs l
The infomation submitted for NRC review should include *, as a minimum:
a.
Identification of the,:pplicable ASME Code Edition and Addenda I
b.
The period for which the program is applicable
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For Pump Testing: identify:
l i) each pump to be tested (name and number) j ii) the test parameters that will be measured iii) the test intervals, i.e., monthly during operation, only during cold shutdown, etc, j
- Specific written relief from the NRC is reouired to exclude any ASME Section XI Code requirements.
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For Yalve Testing; identify:
- 1) each valve in ASME Section XI Categories A & B that will be exercised every 3 months during nomal plant operation (indicate whether partial or full stroke exercise).
ii) each valve in ASME Section XI Category A that will be leak tested I
during refueling outages.
iii) 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 i
valves, identify those that will be exercised every 3 months and those that will only be exercised during cold shutdown.
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o APPENDIX B INFORMATION REOUIRED FOR NRC REVIEW OF REOUESTS FOR RELIEF FROM ASFE CODE SECTION XI REQUIREMENTS DETERMINED TO BE IMPRACTICAL 1.
Identify camponent for which relief is requested:
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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 IWY-2000.
2.
Specifically identify the ASME Code requirement that has been determined to L
be impractical for component.
3.
Provide information to support the determination that the requirement in (2) is impractical; 1.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 impractical.
5.
Provide the schedule for implementation of the procedure (s) in (4) above.
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NRC STAFF GUIDELINES FOR EXCLUDING EXERCISING TCYCLING) TESTS OF CERTAIN VALVES DUR1HG PLANT OPERATION N,
Any valve which when exercised (cycled) could put the plant in an unsafe condition should not be tested. Below are some examples of the types of valves that should be specifically excluded from exercising (cycling) tests during plant operation *:
1.
All valves whose failure in a non-conservative position during the cycling test would cause a loss of system function should not be exercised. Valves in this category would typically include all non-redundant valves in lines 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 category under certain system configurations or plant operating modes. For 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 loss of containment integrity. Yalves 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 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 high pressure side of the valve to be cycled. Valves in this category would typically include the isolation valves of the residual heat removal /
shutdown cooling system and, in some cases certain ECCS valves.
- All ASME Section XI Category A and B valves should be cycled, as practicable, at each cold shutdown, but need not be cycled more often than once every 3 months.
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