ML19339B316

NRC Staff Guidance for Preparing Pump & Valve Testing Program Descriptions & Associated Relief Requests Per 10CFR50.55a(g)

ML19339B316
Person / Time
Site:	Yankee Rowe
Issue date:	01/13/1978
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML19339B314	List: ML19339B313 ML19339B316
References
TAC-07099, TAC-7099, NUDOCS 8011060728
Download: ML19339B316 (12)

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NRC STAFF GUIDANCE FOR PREPARING PUMP AND VALVE

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TESTING PROGRAM DESCRIPTIONS AND ASSOCIATED RELIEF REQUESTS PURSUANT TO 10 CFR 50.55 M

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s;s c The guidance provided in this enclosure is intended to illustrate the type and extent of information that should be provided in proposed 7.==

pump and valve testing program descriptions and 'o support associated p==-

requests for relief from ASME Code requirements.

By utilizing these guidelines, licensees can significantly reduce the need for having to BM respond to additional information requests from the NRC staff.

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1.

Pump and Valve Testing Program Description A.

Scope of the Program:

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1.

The pump testing program should include all safety related*

Class 1, 2 and 3 pumps that are provided with an emergency 7

n power source.

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2.

The valve testing program should be limited to the safety related* valves. All such valves must be addressed in the

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program and should include, as a minimum, those in the j

following systems. Valves in these systems which are used for operating < convenience only - such as manual vent, drain, instrument and test valves, and valvas

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used for maintenance only should be excluded.

O For PWR's:

a.

High Pressure Injection System b.

Low Pressure Injection System

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Accumulator Systems d.

Containment Spray System

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e.

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Auxiliary Feedwater Systems

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• 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 Active Components in Service Water and Instrument

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Air Systems which are required to support safety system functions 5"

i. Containment Isolation Valves that are required to change position on a containment isolation signal J.

Chemical and Volume Control System p

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Other key valves in Auxiliary Systems which are

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emergency diesel starting air valves, component cooling water supplies, etc.

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Residual Heat Removal System m.

Reactor Coolant System 2m p+:

For BWR's:

a.

High Pressure Coolant Injection System b.

Low Pressure Coolant Injection System Residual Heat Removal System (Shutdown Cooling System) z me c.

d.

Emergency Condenser System (Isolation Condenser System) e.

Low Pressere Core Spray System f.

Containment Spray System g.

Safety, Relief, and Safety / Relief Valves h.

RCIC (Reactor Core Isolation Cooling) Systen i.

Containment Cooling S stem 3

j. Containment isolation valves that aro required to change jf.

position on a containment isolation signal

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Standby liquid control system (Boron System) 1.

Automatic Depressurization System (any pilot or contrci

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valves,' associated hydraulic.or: pneumatic systems,

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etc.)-

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Control Rod Drive Hydraulic System (" Scram" function)

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Other key valves ih Auxiliary Systems which are

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required to operate. to directly. support plant shutdown

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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.

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B.

The fo11 :wi information sho01d bb provided for NRC staff review P"F of the. amp.and Valve-Testing Programs:

1.

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 L"

-listed above, with the ASME code class and system boundaries clearly marked. The drawings should include E

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.

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3.

The period for which the program is applicable.

4.

Identification of.the component ASME Section III Code Class.

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For Pump testing,' identification of:

a. ~ E1'ii puinp rh'quifed to be tbsted (name'and number)

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The test parameters to be measured c.

The test frequency

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For valve testing, identification of:

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Each valve.in ASME Section XI Categories A a'nd B.that

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will be exercised every three months during nomal' plant operation (indicate whether partial or full

.;;.JF stroke. exercise,.and for power operated valves list the limiting value for stroke time).

b.

Each valve.in AS'ME Section XI Category A that will be leak tested during refueling outages (indicate.the leak' test procedure you intend to use)..,,

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Each valve in ASME Section XI Categories C and 0 c.

M that_wi,ll 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

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d. Each Valve in'ASME Section XI Category 'E 'that will I2 %

be operationally checked.

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The 'foll~owing. additional information, if practicali e.

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The valve location coordinate!, or other e

appropriate locatior. infonnation which will expedite locating the valves on the P& ids.

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Identification of all valves that are provided with an interlock to other components and a brief description of that function.

II. Requests for Relief from Certain Pump or Valve Testing Requirements It har been the staff's experience that many requests for relief b

from testing gequirements.,, submitted by licensees, have not een supported by adequate de~scriptive and detailed technical in' formation.

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This detailed information is necessary to document why the burden imposed on the licensee in complying with the code requirements

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is not justified by the increased level of safety obtained from y

the testing.

Z Relief requests which are submitted with a justification sucn as

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" impractical", " inaccessible", or any other categorical basis, require additional information to allow the staff to make an evaluation of that relief request. The intention of the guidance u

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l set forth below is to illustrate the extent of the information E=i that is required by the NRC staff to make a proper evaluation and to adequately document the basis for granting the relief in the 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 infonnation required for NRC review of requests for relief from testing requirements:

1.

Identification of the component for which relief is requested:

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Name and number as given in FSAR liik]

b.

Function

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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 AStiE Code requirement that i

t-has been determined to be impractical for each component, 3.

Information to support the determination that the requirement p

in (2) is impractical; i.e., state and explain the basis

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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

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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:

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" Accessibility":

s The regulation allows relief to be granted from code H

requirements because of insufficient access provisions.

However, a detailed discussion of actual physical arrange-ment of the component in question to illustrate the insufficiency of space for conducting the required test

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is necessary.

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In addition, discussion of the alternative surveillance 1=

techniques that have been considered should be provided.

If these alternative techniques have been detemined to M::-

be impractical, the basis for this detemination should

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be provided.

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2.

" Environmental Conditions Prohibitive" (e.g., high radiation level, high temperature, high humidity, etc.):

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Although it is prudent to maintain occupation radiation exposure for inspection personnel as low as practicable, the request for relief from code requirements cannot

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A balanced judgment between the hardships and compensating increase in the level of safety must be explicitly justified.

,_r.:s Therefore, detailed infomation 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 F

techniques have been determined to be impractical, the

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3.

" Instrumentation Not Originally Provided":

Information to justify that installation of the needed 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.

Alternative testing techniques that have been considered

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should be discussed.

If these alternative techniques have been determined to be impractical, the basis for this determination 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 during plant operation could jeopardize the plant safety. Examples of the type of valve that the staff considers to be in this valves whose failure in a non-conservative

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category are:

position during the cycling test would cause a loss of total

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system function; valves whose failure to close during the eq E:

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cycling test would cause a loss of containment integrity; and valves, which when cycled, could subject a system to,

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A plant pressures in excess of their design pressures.

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specific explanation must be provided.

" Valve Testing at Cold Shutdown or Refueling Intervals

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in lieu of the 3 Month Required Interval":

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The licensee should explain in detail why each valve Also, for cannot ce exercised during ncnnai operation.

the valves where a refueling interval is indicated, the licensee should explain in detail why each valve cannot

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be exercised during each cold shutdown.

The following acceptancs criteria for granting relief are

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utilized by the staff:

The licensee must-succebsfully demonstrate with documented

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information that:'

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g Compliance with the code requirements would result in hardships or unusual difficulties without a compensating 1.

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increase in the level of safety, and noncomoliance will I

provide an acceptable level of quality and safety, or g.- -

h Proposed alternatives to the code requirements or portions thereof will provide an acceptable level of quality and 2.

safety.

Standard Format for Valve Testing Submittals III.

A recommended standard format, for the valve portion of the pump and valve testing proaram and relief requests, is included as anThe N attachment to this Guidance.

of this standard format would reduce the time spent The standard the pump and valve testing program submittals.

format includes examples of relief requests which are intended to illustrate the application of the standard format only and g.

are not necessarily applicable to any specific plant.

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Q ATTACtiMENT RECOMMENDEO STANDARD FORMAT FOR VALVE INSERVICE TESTING PROGRAM SUBMITTALS

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LEGEt40 FOR VALVE TESTitiG EXAMPLE FORMAT _

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- Exercise valve (full stroke) for operability every (3) months g

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- Valves are leak tested per Section XI Article IWV-3420 E

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- Stroke time measurements are taken and compared to the stroke

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MT time limiting value per Section XI Article IWV 3410

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- Exercise check valves to the position required to fulfill their

='i CV function every (3) months SRV - Safety and relief valves are tested per Section XI Article g.

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- Test category D valves per Section XI Article IWV-3600 3'r DT

- Verify and record valve position before operations are performed and after operations are completed, and verify that valve is ET locked or sealed.

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- Exercise valve for operability every cold shutdown p.-

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- Exercise valve for operability every reactor refueling RR e

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RELIEF REQUEST BASIS h

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System: Auxiliary Coolant System, Component Cooling

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1.

Valve:

717

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C Class:

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Prevent backflow from the reactor coolant pump cooling coils Test Requirement:

Exercise valve for operability every three

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months Basis for relief:

To test this valve would require interruption of cooling water to the reactor coolant g5=..g l

pumps motor cooling coils. This action could result in damage to the reactor coolant pumps and thus place the plant re-

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in ah unsafe mode of operation.

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Alternate Testing:

This valve will be exercised for operability during cold shutdowns i

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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 routine operation of this valve will occur during refueling and cold shutdowns.

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Test Requirement:

Exercise valve (full stroke) for operability every three (3) months.

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Basis for Relief:

This valve is not required to change position during plant operation to accomplish its

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safety function. Exercising this valve

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will increase the possibility of surge tank

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line contamination.

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Alternate Testing:

Verify and record valve position before and is:

after each valve operation.

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Valve:

7448 Category:

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'EFF Function:

Isolate the residual heat exchangers from f

the cold leg R.C.S. backflow and accumulator backflow.

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Test Requirements: Seat leakage test g'

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Bases for relief:

This valve is located in a high radiation FF field of mr/hr which would make the required seat leakage test hazardous to

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test personnel.

The estimated yearly man-rem exposure associated with perfonning F-=

the required seat leakage test is b;g:-

We intend to seat leak test two other valves (875B and 866B) which are in series with this valve and which also prevent

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backflow. We feel that by complying

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the seat leakage requirements for 744B we will not achieve a compensatory increase in the level of safety.

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Alternate Testing: No alternative seat leak testing is

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proposed for 744B.

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