ML20002C557
| ML20002C557 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 11/24/1976 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20002C554 | List: |
| References | |
| NUDOCS 8101100475 | |
| Download: ML20002C557 (9) | |
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ChCLOSURE 1 NRC STAFF GUIDANCE FOR COMPLYING WITH CERTAIN PROVISIONS OF 10 CFR 50.55a(g) " INSERVICE INSPECTION REQUIREMENTS" I.
INTR 0juCTION Paragraph 50.55a(g) of 10 CFR Part 50 was revised on February 12, 1976 (41 FR 6256). Since then, a number of licensees have requested that the NRC clarify several key provisions contained in the revised regulation.
(1) the requirements to periodically These key provisions relate to:
update the inservice and testing programs to comply with later editions and addenda to the ASME Code, (2) the requirement to confom the Technical Specifications to a ravised inservice inspection or testing program, and (3) the procedures for requesting and obtaining relief from ASME Code requirements that the licensee considers to be impractical for The purpose of this document is to briefly summarize his facility.
the major provisions of the revised 550.Sa(g) and to provide general The docue.cnt is in no way intended guidance in these three key areas.
to encompass all mects of attaining compliance with 550.55a(g).
II.
SUMMARY
OF REGULAT!.
The revised 550.55a(g) contains provisions that require inservice inspec-tion and testing of ASME Code 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 Code and applicable Addenda.
operating facilities whose Operating License (0L) was issued before March 1,1976, these provisions of the regulation apply at the start of the The next regular 40-month inspection period after September 1,1976.
start of the next 40-month period is determined by measuring a series ofFor such periods beginning at the start of facility commercial operation.
facilities that received GL's on or after March 1,1976, these provisions of the regulation apply at the start of commercial operation.
As a result of the February 1976 amendment, 550.55a(g) now specifies inservice inspection and testing requirements for all operating plants, including those that received a Construction Pemit (CP) before January 1, 1971. Since plant designs and access provisions for inservice fmections have progressed over the years, the regulation provides recognition of this fact by grouping design requirements for component inspectability based on a facility's CP issuance date. The requiation further specifies that new inservice upection and testing requi*ements 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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' An important part of the revised 50.55a(g) is the incorporation of the ASME Code Section XI requirenents for testing pumps and valves for opera-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. Furthennore, 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 550.55a(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 months. A description of the updated programs should be submitted to the NRC for review anc' approval as far in advance as possible of, but at least 90 days before, the start of each period. The infonnation the NRC will need for its review of updated programs is identified in Appendix A (attachea).
Under 550.55(g)(4), the revised inservice inspection and testing programs must, to the extent practical, comply with the requirements in editinns and addenda to the ASME Code that are "in effect" no more than 6 i.anths before the start of the period for which the updated program is applicable. The terms "in effect" or " effective", as used in 550.55a(g)(4), identify those editions and addenda to the ASME Code that have been published by the ASiiE and that are also referenced in paragraph (b) of 550.55a.
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i 3-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 $50.55a on the date that corresponds to 6 months before the start of the period in question.
If amendments to paragraph (b) of $50.55a become effective on a date that falls between the date that marks 6 months befoFe the start of a inspection period and the start date itself, the licensee is not required to corrply 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 550.55a 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 progran does not 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 $50.55a.
B.
Conforming the Technical Specifications to an Updated Inservice Inspection or Testing Program ----- Paragraph 50.55a(g)(5)(ii):
If a revised (updated) 1.1 service 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 ';pecifications.
In such cases the licensee must propose changes to confunn 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 must 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 regire-ment should be retained as an augmented requirement pursuant to 550.55a( g)(6 )(11).
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4 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 requirments. This should be done at least 6 months before the start of the first 40-month inspection period for which 550.55a(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 550.55a(g), because such referencing will simplify the Technicai 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 asso:iated 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 tre 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 requirments 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 AME Code requirements that he has detemined to be impractical at least 90 day; 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 550.55a(g)(6)(i). Unless a licensee is otherwise notified by the NRC, relief from ASME Code requirements will remain applica.31e until the end of each 120-month period. At that time, the NRC will re-evaluate the basis for the determination that the requirement is impractical, pursuant to 550.55a(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.
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Generally, the licensee will know well in advance of the beginning of any inspection period, whether or not a particular ASME Code requirement will be impractical for his facility. Thus, the licensee should request relief 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 licenstes and determine which ASME Code requirements may be generally impractical for various classes of plants. Early submittals will thereby f acilitate 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-ment will be impractical for his facility.
In cases where, during the process of inspection of testing, certain requirements are found to be impractical due to unforseen circumstances, the licensee may request relief 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 reouirements 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 granting of relief from ASME Code require-by the licensee.
ments will be published in the FFDERAL REGISTFR, but the written relief 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 OF INSERVICE INSPECTION AND TESTING PROGRAMS 1.
Inservice Inspection Programs:
The infomation submitted for NRC review should include *, as a minimum:
Identificction of the applicable ASME Boiler and Pressure Vessel a.
Code Edition and Addenda b.
The period for which the program is applicable Identification of all of the specific components and parts to be c.
examined for each ASME Code Class (i.e., each Quality Group as defined in Regulatory Guide 1.26, " Quality Group Classifications and Standards for Water, Steam, and Radioactive-Waste-Containing Components of Nuclear Power Plants"), and the inspection intervals for each Class or Quality Group d.
Fcr each specific component and part; specification of:
i) The examination category as defined in ASME Section XI ii) The examination method to be used 111) The repair requirements 2.
Pump and Valve Testing Programs The infomation submitted for NRC review should include *, as a minimum:
Identification of the applicable ASME Code Edition and Addenda a.
b.
The period for which the program is applicable c.
For Pump Testing: identify:
- 1) each pump to be tested'(name and number) ii) the test parameters that will be measured iii) the test intervals, i.e., monthly during operation, only during cold shutdown, etc,
- Specific written relief from the NRC is reouired to exclude any ASME Section XI
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Code rcquirements.
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For Valve Testing; identify:
- 1) each valve in ASME Section XI Categories A & B that will be exercised every 3 months during normal p'. ant operation (indicate whether partial or full stroke exercise;.
ii) each valve in ASME Section XI Category A that will be leak tested during refueling outages.
iii) all valves 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 only be exercised during cold shutdown.
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APPENDIX B INFORMATION REOUIRED FOR NRC REVIEW 0F REQUESTS FOR RELIEF FRO ASME CP'at SECTION XI REQUIREMENTS DETERMlHED TO SE IMPRACTICAL 1.
Identify 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 IWY-2000.
Specifically identify the ASME Code requirement that has been determined to 2.
be impractical for component.
Provide information to support the determination that the ret 'irement in (2) 3.
is impractical; i.e., state and explain the basis for request: ng relief.
Specify the inservice inspection (or testing) that will be performed in lieu 4.
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 (CYCLING) TESTS OF CERTAIN VALVES DURING PLANT OPERATION Any valve which when exercised (cycled) ccaid 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 v61ves 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 For category under certain system configurations or plant operating modes.
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 cycile.g test would result in a loss of containment integrity. Valves 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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