ML20039G929

Reg Guide 1.68.3,Revision 1, Preoperational Testing of Instrument & Air Control Sys

ML20039G929
Person / Time
Issue date:	07/31/1981
From:	NRC
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Shared Package
ML20039G922	List: ML20039G921 ML20039G929
References
TASK-OS, TASK-RS-709-4 REGGD-01.068.03, REGGD-1.068.03, NUDOCS 8201190316
Download: ML20039G929 (5)

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4 SCHEMATIC REPRESENTATION OF NEW REQUIREMENTS REVIEW Ge eric Issues roposed Operational Experience Requirement Reg. Guides Bulletins & Orders Proposed Rules y

Etc.

Cost / Benefit Industry A

7 Prioritization Input V

A Revise or Drop CRGR Review r

Y Further Review

/.CD.S Commission V

Licensees k

PMs, Work With Input Licensees A.

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Schedule Agreed-Upon Plant L _.- - - -

Specific Implementation Schedule e

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-f U.S. NUCLEAR REGULATORY COMMISSION July 1981'

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M hl@d REGULATORY GUIDE 1.68.3 (Task RS 7094) ce % orvence p e.

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.l FREOPERATIONAL TESTING OF INSTRUMENT AND CONTROL AIR SYSTEMS

.i A. INTRODUCTION Because of tse drrersity ofloadsnormally surptied, there is a possibility for unsafe interactions. Therefore, h is impor-General Design Criterion 1, " Quality Standards and tant that testing be done to verify proper functioning during I Records," of Appendix A, " General Design Criteria for normal opy.stion and to determme the effects of totalloss, l

Nuclear Power Plants," to 10 CFR Part 50, " Domestic reduction, orincrease of the pressuremithin the entire instru-i Licensms of Production and Utilization Facilities," requires ment and control air distribution system and portions thereof.

that structurcs, systems, and creponents important to safety be tested to quality standards ccmmensunte with It is essential that testing verify that the rystem will the importance of the safety function to be performed.

respond appropriately to both normal operation of the Criterion XI, " rest Contrc!," of Appendix B, " Quality plant and upset, faulted, or emergency conditions with Assurance Criteria for Nuclear Power Plants and Fuel consideration being given to (1) complete and sudden loss of Reprocessmg Plants," to 10 CFR Part 50 requires that a pressure resdting from such postulated events as inadver-test program be established to ensure that all testing, tent valve operation in the supply system, severance of a j

including preoperational testing, required to demonstrate system pipe, loss of offsite electric power, loss of d.c.

that structures, systems, and components wiIl perform power, and component malfunction;(2) partial or gradual satisfactorily in service is identiGed and performed. Instrn-loss of system pressure to the entire distribution system or i

ment and control air systems supply pressurited air to portions thereof resulting from such events; and (3) increases operate various loads, including ccmponents and systems in pressure due to component malfunction or failure.

that are required to perform functionsimportant to safety.

This guide, which replaces Regulatory Guide 1. 80, describes Air-operated valves and other air operated components are a method acceptable to the NRC staff for complying with normally designed to respond in a given manner,I.e., fail open, the Commmion's regulations with respect to preoperational fail closed, ot fail as is, if the mstrument and control air testing to verify that instzument and contral air systems' supply is lost or its pressure is reuuced or increased. Verifica-I and the loada they supply will operate properly at normal tion of system response to a losMf-air-pressure event is an l

system presnres and to ensure the operability of functions essential part of testing at the preoperationalstage, at which important to safety in the event that system pressure is lost, time it can be accomplished with a mimmum risk to power I

reduced below normal operating level, or inceased above plant equipment and personnel. Testing' also provides a I

the design pressure of the system components.

means for determming the adequacy of operating and emergency procedures for coping with a loss of air supply.

Preoperational testing of the instrument and control air I

last:ument and control air systems typically furnish system following construction of the plant andinstallation pressurized air to a wide variety of equipment in nuclear of the instrument and control air system will help enst.re power plants. The extent to which such air systems are used that the air supply equipment (compressors and associ-jl varies with different designs of both the nuclear and the ated controls and backup air supplies) and the equipment jl balanctrof-plant portions of the facility, provided to maintain the quality of air supplied (e.g., filters and dryers) will function within design requsrements.

II I The recommendations of this st:ide should also be appiled to-(1) compressed sus systems that, althoush not deasnated as instru-D.c applicant is respodsible for developing a suitable ment and control air systemf. supply loads that could arfect the i

overen safety and performance of the ptant. (a) compressed saa preoperational test program for the instrument and control systems that su pty icus only to specsfc systems that are important to safety, and 3) systems important to safety snat nas compressed

, air system. This includes preparing adequate procedures for sases other than asr.

carrymg out the program, properly conducting the preopera-USNRC REGut.ATGMY CUfDir$

Cr.rmments shou 6d be sent to the Secretary of the Commissio e.

U.s. NucJear etegulatory Commiss6cn. Wasnington. Q.C. 20:55, Requietory Guides are issued to desertoe and make avaniante to t-.

Attention Doesietine and service erancri, puDeic metnocs acceptacle to tne NRC staff of impeementing speciflC Darts of tne Cornmission's regulations, to de61neate tech.

, Tne guides are iss.aed in tfie fortowing ten broad divisionsa n80ues used DY the staff in evaluating specific proOlems or Dostu-lated accioents or to Drovide guidance to SOOl6 cants. Requiatory

1. Power Atactors

6. Products Guloes are nod suBStltutes for regulations. and Compilance witn

2. Aesearch and Test Aeactors

7. Transportation tnam is not recWred. Methods and sosutions different fit m tnese set-

3. Puess and Matettats Facilittet

a. Cccupational >*ealth out in tfie guadas ws!! De aCCoot4049 if theY prowice a i.sasis for the 4 Environmentes and $lting

9. Antitrust and Financial Review n ngs is ne issuance or continuance cf a perm 6t or

s. Materials and plant protection 10. General Cooles of Issued guides may be saurenased at the current Covernment Tnts gulae was Issued afterConsideration of ComrMents received from Printing OfflCe DrtCo. A suoscriotton serv 6ce for future queces in sDe=

the DuDeic. Comments and suggestions for im0rovements in these cific dives &ons is avaalable tnrougn the Government Printing Off6ce.

guides are encouracea at all times, and guaces will De revised. as infor tation on the suoscrtetton service and current G*O ortces may amoroortate, to acccrnrpodate comments and to re

• lect new enforme-De co"tained by writing the U.S. Nuclear Regulatory Commess6on, tion or emperience.

Wasnington. O.C. 20:5s. Attentions publications Sales Manager.

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tion-1 tests, and establishms the validity of the test results tion of) portions of the farihty important to safety respond by adeqt. ate aview and approval in accordance with design to a loss of air pressare. Testing H

should be effisantly comprehensive to determas the-I!

C. REGUI.ATORY POSITION response of loads to complete loss of system presnare, both ll

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adden and gradual, and to parnal reductions in system i!

As part of the initial preoperational testing program and pressure. The tests should verify the adequacy of deegn also after major modificatic.us or repaus to the instrument requuements telating to system pressures at which mapplied and control air system or portions thereof (e.A where loads change state (e.k fail open, fail closed, fail as is, fail air-Gow-rate requirements are d-ah ly altered or upscals, fait downscale, or fail to perfore other requzred t

!i where opened systems are mbject to cone====einn), the functions). Testing should also verify that the backup ji system and loads should be, tested as described below to supplies for the piutected loads supplied by the system, i

verify that all components function properly at normal e.g., accumulators and backup bottled gas supplies, will

.rressures and following porible presure increases and that maintain sufficient. air pressure to pernut these bads to the systems respcmd as designed to aloss of-sar-pressus event.

perform their design function.

1. The test program for the instrument and control air As part of the above testing, loss of-air supply tests should l

syste:n and assocsated' equipment should include the be conducted on all branches of the instrument and control applicable prerequisite checks, verifications, and tests air system simultanecusly, if practicable, or on the largest provided in SectioriC.2 of Regulatory Guide 1.68, " Initial number of branches of the system that can be adequately Test Programs for WaterCooled Nuclear Power Plants."

~ ~ --d For each test, the valves to be tested should be placed in their normal operating position, and the rest of

2. Compressors, aftercoolers, oil separator units, c the plant should be==tatsmed in as close to aarmal mnrhtiane

_ re.eivers, and pressure-reducing stations should be tests d te as is practicable. (It should be noted that not allvalves can j

verify proper operaticar accordingjo_sys_ tem design _. The_ opera-be placed in the required normal operating position because

_tzn of compressor unloaders, automatic and manualstart and of operating procedure aquirements or pc.sonnel or equip-1

- stop gircuits of standby compressors, high-and low-pressure ment safety factors.)'Its following tasts should be performed:

l alarms, pressure indicators, and temperature indicators j

should be checked. Relief valve settings should be verified,

s. Shut off the instrument and control air system in a I

manner that would amulate a sudden air pipe break and j

3. Air dryer units should be tested for proper function-verify that the affected components respond pro,perly.

j ing, and the units should be operated through at least one i^

regeneration cycle. Acceptable operation at maximum flow

b. Repeat test a., but shut the instrument and cortrol air rates should be renfied. The appropriate differential system off very slowly to simulate a gradualloss of pressure.

prtssures and proper operation of pressun switches, high-and low-pressure alarms, safety and relief valves, bypass

9. Tests should be conducted, as appropriate, to demon-valves, and ahrms and resets should be venfied.

strate that plant equipment designated by design to be sup-f plied by the instrument and control air system is not being [

4. It should be verified by test that the instrument and mapplied by other compressed air supplies (such as service

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control air system will meet specifications relating to flow, air) that may have less restncuve air quality requirements.

pressure, and temperature of the product air.

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10. Plant corsponents requiring large quaitities of j

5. It should be established by appropriate measunments instrument and control air for operation (such as large valve or observations that the total air demand at normal steady-operators) should be operated simultaneously while the state conditions, including leakage from the system, is in system is operating at normal steady-state conditions accordance with design.

(unless it can be shown that simultaneous operation is j

prohibited by interlock or appropriate procedure) to verify j

6. The ability of the system to meet the quahty requne-that pressure tranwnts in the distribution system do not l

ments of ANSI /ISA S7.3-1975, "Quahty Standard for exceed acceptable values.

Inst:ument Air,"' with respect to oil, water,and particulate i

matter coatained in the product air should be verified by

11. Functional testing of instrument and control air j

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'y analyzing the air at the end of each feederline using con-

_ systems important to safety should be performed to en.ure i 1

tinuous flow techniques or by acalyzms a discrete sample.

that credible failures asulting in an increase in the supply I

system pressure will not i:ause peak trannent pressures j

7. When redundant components and air supplies are above the design pressum of the system components.

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provid.d in the facuity design to meet the single-failure criteti:rs for a given safety function,it should be verified by D. IMPI.EMENTATION Except in those,:r.ses in which an[ applicant pro test that the single-fanure criterion is met.

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8. It should be verified by te+ts that the air operated or acceptable' alternative method for complying with speMed air-powered loads that are a part of (or support the opera-portions'of'the' Con-mminn's reguhtions'the =ethod J

i descri}ica in ttfis guide wiII be used-irr"6e evaluation.of'alOl I

application [,,for' operating licenses receiveda#Iune 1, agP"P.07 Box s2NR T gi t,

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s VALUE/IMFACT STATEMENT i

BACKGROUND, for peak loads and increased Isakage that may occur ar the system is used.

i Regulatory Guide 1.80 provides methods for preopera-tional testing of instrument air systems to ensue that the Impact - Although not WS="y mentioned, it has mstrument air systems and components as desisced and been the intent that the tests caued forin this postion be installed will function properly and that they are free from accomplished. The pos%n is stated explicitly to improws-fonign matter that could cause malfunctions dunna opera-guadance. For thos p: acts that were not already attammt tion. The guide also contains provisons for tests to demon-the information, the impact should be mimmal as the dart strate that the systems will respond as expected to a loss of-can be obtained by normal system observations and simple instrument-air accident.

measurements, Experience in using the guide has shown that there have

3. Regulatory Position 9, which calls for tests, measure.

been problemsin applying the guide where there is a relation-monts, and observations to be conducted to demonstrate ship between the instrument air system and the control air that air supplies such as the service air sapply are sot system. Therefore, the scope of Regulatory Guide 1.80 was insdvertently. tied into the instrument and centrcl air expanded to include the control air system because of the systems, was added.

possibuity that it may be associated with systems unportant to safety. However, the expanded guide is being issued as Falue - De tests caued for in this position w D demon-Regulatery Guide 1.68.3 in order to group it with other strate that air systems with poor quality air are not inadver.

guides in the initial test program subseries, and Regulatory tently tied into the systems that supply air to loa <is that are Guide 1.80 is being withdrawn.

important to safety. Since air systems are generally field run, verification of independence by test is enentiaL VALUE/ IMPACT Impact -The impact win be mimm=1 The demonstration

1. De scope of the guide has been expanded to include

.that there are no crosstics frem the service air system can control air systems as wen as instrument air systems, be accomplished by cutting off the instrument and control air source with all other air systems under pressure and Value - This change win make it clear that some testing showing that no air is being introduced into the system.

is needed for an instrument and control air systrro. Some applicants have taken the position that their plants are so 4: Regulatory Position 10, which states that plant designed that failure of the mstrument air system (i.e.,

components requiring large quantities of air for operatzon total loss of pressure) win cause no safety problems The should be operated simultaneously toestablish that pressure instrument airsystem of these plantshasnot been ddanated transients created by such operation do not exceed accept-as important to safety and therefore, by thislogic, Regula-able values, was added.

tory Guide 1.80 is not applicable. His argument ignores the fact that,sithough loss of system pressure may not be Falue - This test wi:1 demonstrate that the maximum serious, malfunction of the air system (e.g., introduction of operating transients on the system are within limits that i

dirt, oil, or moisture also addressed by Regulatory Guide will not adversely affect the operation of leads that are l

1.80) could lead to failure of loads that are important to importnt to safety.

safety. The revised guide makes it clear that the testing applies to JU air systems that mzpply air to loads that are Impact - There should be minimalimpact since the test.

important to safety.

l can be run by simple operational procedures and data observations.

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Impact - There may be some impact if applicants have not been testing because their systems have been identified

5. The regulatory position that provided for a test of the by names different from those used in the guide. However, loss of air with valves placed in other than the failed posi, the staff position has always been that systems important tion was deleted.

to safety should be tested to demonstrate proper speration and to ensure that the functioning of loads important to Falue - An unnecessary system test was deleted. The safety is not jeopardized by failure of associated systems, response of components to a loss of air pressure (when the valves are placed in a position other than the failed position) ll. Regulatory Position 5, which cans forverification by can be venced, where requzred, on anindividual compoosat tests that the total air demand at normal steadydste basis.

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conditions, including leakage from the system,is in accerd-ance with design, was added.

Impact - There is no impact since no new position is imposed.-

Value - The tests caued for by this provimon win verify actual air demands so that air szpply capacity can be

6. The regulatory position cauing for the test results to verified as adequate with the necessary maram to account be included in the startup report was deleted.

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Value - An unnecessary repornns provision was removed.

transient pressures above the design pnsmare of the system

' This prc' vision was inappropriate since pnoperational ccmponents, was added.

testing pncedes the startup test program. ' Die test results should be retained as part cf the plant historical record.

Valus - Operating expenance b ;.. Pilgrim) has shown that pressure transents above the design pressun of some compor.ents can cause those components to malfunction, Impact - There is no impact since no new pontion is which could cause unsafe conditions to exist.

imposed.

Impact - There should be mimm=1 impact, Additic.2al

7. Regulatory Position 11, which provides:for functional testing will be tsquired. However, the test setup should be testing to ensure that credible failuns ressiting in an no different from that needed to conduct theloss of pressue incnase in the supply system pre,wm will not cause peak tests, hence increased test time would be the only ftetor.

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