ML20058N641

Guidelines for Inservice Testing at Nuclear Power Plants. Draft Report for Comment

ML20058N641
Person / Time
Issue date:	11/30/1993
From:	Campbell P Office of Nuclear Reactor Regulation
To:
References
NUREG-1482, NUREG-1482-DRFT, NUREG-1482-DRFT-FC, NUDOCS 9312220172
Download: ML20058N641 (200)

Text

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Guic eines for Inservice Tes~:ing a:

1 Nuclear Power PLarr:s Draft Report for Comment

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U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation P. Cmnpbell R Pfu

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AVAILABILITY NOTICE l

i Availabi!:ty of Reference Materia!s Cded in NRC Publications

.I Most documents cited in NRC publications will De available from one of the following sources:

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The NRC Public Document Room, 2120 L Street, NW, Lower Leve!, Washington, DC i

20555-0001 l

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The Supenntendent of Documents, U S. Government Printing Office, Mail Stop SSOP, Washington, DC 20402-9328 3.

The National Technical Information Service, Springfield, VA 22161 A!though the 1: sting that fo!!ows represents the majonty of documents cited in NRC publica-tions, it is not antended to be exhaustive.

Referenced documents available for inspection and copying for a fee from the NRC Public Document Room include NRC correspondence and internal NRC memoranda: NRC bulletins, circulars. inf ormation notices, inspection and. investigation notices: licensee event reports; vendor reports and correspondence; Commission papers: and applicant and licensee docu-monts and correspondence.

The fol owing documents in the NUREG series are available for purchase from the GPO Sales Program: formal NRC staff ano contractor reports, NRC-sponsored conference proceedings, mternatronal agreement reports, grant publications, and NRC booklets and brochures. Also i

asanab!e are regulatory gu des. NnC regulations in the Code of Federal Regulations, and Nu-i c! ear Regulatory Commission issuances.

Documents avacable from the Nabonal Technical information Service include NUREG senes reports and technicai reports prepared by other Cederal agencies and reports prepared by the Atom.c Energy Commission, forerunner agency to the Nuclear Regulatory Commission.

Documents avadab'e from public and spectai technical libraries include a!! open literature items, such as books. Journal art;cles, and transactions. Federal Register notices, Federal and State legisf ation and congressional reports can usually be obtained from these libraries, 1

Documents such as theses, dissertations, f ore;gn reports and trans!ations, and non-NRC con-i f erence proceedings are avacabte f or purchase from the organization sponsoring the pub!ica-tion cited.

S,ng'e copies of NRC draf t reports are available free, to the extent of supply, upon written raca to tne Office of Adminrstration, Distribution and Mail Services Section, U.S. Nuclear Regutaicry Commission, Washington, DC 20555-0001.

Copies of industry codes and standards used in a substantive manner in the NRC regulatory process are ma:ntained at the NRC Library,7920 Norfolk Avenue, Bethesda, Maryland, for use by the public. Cooes and standards are usually copynghted and may be purchased from the originating organization or, if they are Amencan National Standards, from the American Na-tional Standards Institute,1430 Broadway, New York, NY.10018.

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i NUREG-1482 Guidelines for Inservice Testing at Nuclear Power Plants 1

I Draft Report for Comment i

Manuscript Completed: November 1993 Date Published: November 1993 f

P. Campbell Division of Engineering Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 p"' %,,

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ABSTRACT

'l In this report, the staff gives licensees guidelines for developing and implementing programs for the inservice testing of pumps and valves at commercial nuclear power plants. The report includes U.S. Nuclear Regulatory Commission (NRC) guidance and recommendations on inservice testing issues. The staff discusses the regulations, the components to be included in an inservice testing program, and the preparation and content of cold shutdown and refueling outage justifications and requests for relief from the American Society of Mechanical Engineers Code requirements. The staff also gives specific guidance on relief acceptable to the NRC and advises licensees in the use of this information for application at their facilities.

The staff discusses the revised standard. technical specifications for the inservice testing program requirements and gives guidance on the process a licensee may follow upon finding an instance of noncompliance with the Code.

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CONTENTS Abstract.........................................................................................

iii A bb r ev i at io ns.......................................................................................

xi Ex ecu tive S u mm ary.............................................................................

xiii Foreword.........................................................................................

xv 1

Introduction.......

1-1 2

Developing and Implementing an Inservice Testing Program......................

2-1 2.1 Compliance Considerations.................................................

2-1 2.2 Criteria for Selecting Pumps and Valves for the IST Program............

2-3 2.3 Code Class Systems Containing Safety-Related Pumps and Valves......

2-4 2.4 IST Program Document.......

2-4 2,4.1 Pumps................................................................

2-4 2.4.2 Valves...............................................................

2-5 2.4.3 Piping and Instrument Diagrams....................................

2-6 2.4.4 B as es Docu m ent.........................................................

2-7 2.4.5 Deferring Valve Testing to Cold Shutdown or Refueling Outages................................................

2-7 2.5 Relief Requests and Proposed Alternatives....................................

2-7 2.5.1 J ustifications for Relief................................................

2-7 2.5.2 Categories of Relief Requ ests........................................

2-8 2.5.3 Content and Format of Relief Requests..............................

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3 General Supplemental Guidance on Inservice Testing...............................

3-1 3.1 Inservice Test Frequencies and Extensions....................................

3-1 3.1.1 Deferring Valve Testing to Each Cold Shutdown or Refueling Outage.......................

3-1 3.1.2 Entry into a Limiting Condition for Operation to Perform Testing.....................................

3-5 3.1.3 Scheduling of Inservice Tests......................................

3-7 3.2 Start cf the Time Period in i

Techt ical Specification ACTION Statements...............................

3-8 3.3 120-Month Updates Required By 10 CFR 50.55a(f)(4)(ii)...............

3-10 3.3.1 Extension of Interval..............................................

3-10 3.3.2 Concurrent Intervals.........................................

3-11 3.3.3 Implementation of Updated Programs..............................

3-12 3.3.4 General Comments on Inservice Testing Intervals.................

3-13 3.4 Skid-Mounted Components and Component Subassemblies................

3-14 3.5 Testing in th e As-Found Co nd ition...........................................

3-14 4

Supplemental Guidance on Inservice Testing of Valves...........................

4-1 4.1 Ch eck Valves...................................A.

4-1 i

4.1.1 Closure Verification for Series Check Valves Without Intermediate Test Connections...........................

4-1 4.1.2 Exercising Check Valves With Flow..............................

4-3 4.1.3 Extension of Test Interval to Refueling Outage for Check Valves Verified Closed by Leak Testing...................

4-4 4.2 Power-Operated Valves.........

4-5 4.2.1 Increased Frequency of Testing for Valves That Can Be Tested Only During Cold Shutdown Outages......................

4-5 4.2.2 Stroke Time Measurements for Rapid-Acting Valves............

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4.2.3 Measurement of Valve Stroke Time..................................

4-6 4.2.4 Main Steam Isolation Valves.........................................

4-7 4.2.5 Verification of Remote Position Indication for Valves by Methods Other Than Direct Observation..........

4-8 4.2.6 Requirements for Verifying Position Indication..................

4-8 4.2.7 Stroke Time Measurements Using Reference Values..............

4-9 4.2.8 Solenoid-Operated Valves..............................................

4 4.2.9 Control Valves with a Fail-Safe Safety Function..................

4-10 4.3 Safety and Relief Valves...............................

4-11 4.3.1 S cope................

4-11 4.3.2 OM-10 Reference to OM-1......................................

4-11 4.3.3 Test Supervisor Qualifications....................................

4-11 4.3.4 Frequency and Method of Testing Automatic Depressurization Valves in Boiling-Water Reactors............

4-13 4.3.5 Jack-and-Lap Process............................................

4-14 4.3.6 Safety / Relief Valve Setpoint Adjustments.........................

4-15 4.3.7 Setpoint As-Found Value..........................................

4-15 4.3.8 Vacuu m Rel ief Valves................................................

4-15 4.4 M iscellaneous Valves.....................................................

4-16 4.4.1 Pressurizer Power-Operated Relief Valve Inservice Testing....

4-16 4.4.2 Post-Accident Sampling System Valves............................

4-17 4.4.3 Multiple Containment Isolation Valve Leak-Rate Testing........

4-18 4.4.4 Post-Maintenance Testing Following Stem Packing Adjustments...........................................

4-19 4.4.5 Leak-Rate Testing Using OM-10 Requirements....................

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4.4.6 M anu al Val ves............................................................

4-21 5

Supplemental Guidance on Inservice Testing of Pumps.............................

5-1 5.1 General Pump Inservice Testing Issues......................................

5-1 5.1.1 Frequency of Inservice Tests - Comparison of the American Society of Mechanical Engineers Code to Technical Speci fications...............................................

5-1 5.1.2 Continued Measurement of Parameters Deleted from OM-6.....

5-2 5.2 Use of Variable Reference Values for Flow Rate and Differential Pressure During Pump Testing............................

5-3 5.3 Allowable Variar.ce from Reference Points.............................

5-4 5.4 Monitoring Pump Vibration in Accord with OM4...................

5-6 5.5 Pump Flow Rate and Differential Pressure Instruments.................

5-7 5.5.1 Range and Accuracy of Analog Instruments......................

5-7 5.5.2 Range and Accuracy of Digital Instruments....................

5-8 5.5.3 Use of Tank or Bay Level to Calculate Differential Pressure....

5-8 5.5.4 Accuracy of the Flow Rate Instrument Loop..

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5.6 Operability Limits of Pumps..............................................

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5.7 Use of OM-6 Table 3b Ranges for Hydraulic Parameters.......

5-10 5.8 Du ration o f Tes ts................................................................ 5-10 6

Revised Standard Technical Specifications.........................................

6-1 6.1 I ntrod u ct ion.....................................................

6-1 6.2 History.........................................................

6-1

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6.3 D is cuss io n...................................................................

6-3 7

Identification of Code Noncompliance..............................................

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8 References...............................................................................

8-1 APPENDICES A

Generic Letter 89-04 Positions and Questions / Answers With Guidance on Current Considerations B

Valve Tables C

Relief Requests D

Safety Evaluation TABLES 2.1 Typical systems and components in an inservice testing program for a pressurized-water reactor................

2-10 2.2 Typical systems and components in an inservice testing program for a boiling-water reactor........................

2-13 2.3 Example d ata table for pumps...................................................

2-16 2.4 Use ful abbreviations for valve data tabl es........................................

2-17 3.1 Required tests and test frequencies for pumps and valves.....

3-16 EXAMPLES 3.1 Cold shutdown j usti ficatio n CSJ-4..................................................

3 3.2 Cold shutdown j ustification RBC-1....................................................

3-17' 3.3 Refu eling outage justi fication........................................................

3-18 j

l 3.4 Refueling outage justification ROJ/SI-4..........................................

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ABBIEVIATIONS ADS automatic depressurization system ALARA as low as reasonably achievable ANSI American National Standards Institute ASME American Society of Mechanical Engineers BWR boiling-water reactor BWST borated water storage tank CFR Code ofFederal Regulations CIV containment isolation valve CSJ cold shutdown justification ECCS emergency core cooling system FT 110w test GE General Electric Company GL generic letter HPCI high-pressure coolant injection IN information notice IP inspection procedure ISI inservice inspection IST inservice testing LCO limiting condition for operation LOCA loss-of-coolant accident MSIV main steam isolation valve NIT nonintrusive techniques NRC U.S. Nuclear Regulatory Commission 4

OM Operations and Maintenance PASS post-accident sampling system PD positive displacement P&ID piping and instrument diagram PORV power-operated relief valve PTC Performance Test Code PWR pressurized-water reactor RCIC reactor core isolation cooling RCS reactor coolant system RG regulatory guide RHR residual heat removal RPM revolutions per minute RWST refueling water storage tank l

RWT refueling water tank SAR safety analysis report SBLC standby liquid control SI safety injection SOV solenoid +perated valve SR surveillance requirement TI temporary instruction TS technical specifications xi NUREG-1482

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EXECUTIVE

SUMMARY

The U.S. Nuclear Regulatory Commission (2)

To give guidance on information that (NRC) is issuing this report to assist the industry needs to be included in relief requests in eliminating unnecessary requests for relief and for prompt staff approval.

to give approval of an alternate method of inservice testing (IST) if that method is in accord (3)

To clarify a number of issues that have with the latest edition of industry Codes and been identified in NRC inspections, from standarJs approved by the NRC. These Codes licensees' telephone calls or meetings, and standards are found in the American Society and through NRC staff participation on of Mechanical Engineers (ASME) Roller and the OM committees.

Pressure Vessel Code and the ASMEIAmerican National Standards Institute Operations and (4)

To indicate the acceptability or the need Maintenance (OM) Standards, Part 6, " Inservice for cautions in applying certain Testing of Pumps in Light-Water Reactor Power ASME/OM interpretations.

Plants," (OM-6) and Part 10, " Inservice Testing of Valves in Light-Water Reactor Power Plants" (5)

To consolidate a number of references to (OM-10). If the guidance in this report is used, various documents that are applicable to it will assist the industry in establishing a IST.

consistent IST approach, but implementation of the new guidance is strictly voluntary. No (6)

To issue guidance on the information to backfit is intended or approved in connection be included in an IST program, the with issuance of this document. This report lists format for relief requests and cold portions of OM-6 and OM-10 that licensees may shutdown / refueling outage justifications, partially implement if the related requirements and the scope of IST programs.

stated in the applicable recommendation are met.

(7)

To clarify certain ASME Code or NRC This document was developed to accomplish the regulatory issues.

following purposes:

(1)

To approve portions of OM-6 and OM-10 that the staff has determined are acceptable to implement pursuant to the Code of Federal Regulations, Title 10, Section 50.55a(0(4)(iv).

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FORFAVORD The guidance provided in this report is not intended to convey any new requirements or positions on inservice testing (IST). Where the requirements of NRC regulations or the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (the Code), as incorporated into the regulations, are discussed, the terms shall, must, requires, or requirements are used consistently to indicate their mandatory nature. [The term must is also used in another manner in the context of implementing guidance (not requirements), as discussed below.]

Where only guidance on IST is intended, the terms NRC or stag recommendation, recommends, acceptable to the staf, acceptable, or licensee may or typically would are used to denote staff preferences, or practices that have been determined by the staff to be acceptable means of implementing requirements of the regulations or the Code.

The term must is used in connection with some provisions of the guidance herein to indicate that, if a licensee chooses to implement the guidance of a section, such provisions in that section are to be 4

followed without deviation in order for the licensee to be credited with satisfactorily meeting the guidance of that section. Where a recommendation is made, the licensee may choose whether or not to follow the guidance. The discussion of previous guidance ;ssued in Generic Letter 89-04 or other NRC documents does not convey new requirements.

NRC is considering publishing this report in final form to give guidance on IST issues. Any interested party may submit comments on this report for the staff to consider. To be considered, comments on this report must be received by the due date published in the Federal Register notice. Comments received after the due date will be considered to the ;xtent practual. Comments should be sent to the Chief, Rules Review and Directives Branch, Division of Freedom of Information and Publications Services, Mail Stop P-223, U. S.

Nuclear Regulatory Commission, Washington, DC 20555. Further technical information can be obtained from Ms. Patricia Campbell, Office of Nuclear Reactor Regulation, Mail Stop OWFN 7-E-23, U. S. Nuclear Regulatory Commission, Washington, DC 20555. Ms.

Campbell can be reached at (301) 504-1311.

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f 1 INTRODUCTION i

Regulatory Basis testing. The Commission is authorized to evaluate the relief requests and may grant relief Section 50.55a of Title 10 of the Code of or impose alternative requirements, considering Federal Regulations (10 CFR 50.55a) defines the the burden upon the licensee that could result if requirements for applying industry codes and the requirements were imposed on the facility, standards to boiling or pressurized water-cooled The Commission may also authorize alternatives nuclear power facilities. Each of these facilities to the Code requirements pursuant to is subject to the conditions in paragraphs (a), (f),

10 CFR 50.55a (a)(3)(i) and (a)(3)(ii) if the and (g) of 10 CFR 50.55a for inservice alternatives ensure an acceptable level of quality inspection and inservice testing (IST). By and safety or the requirements present a hardship rulemaking effective September 8,1992 (see without a compensating increase in the level of Federal Register Vol. 57, 34666), the U.S.

quality and safety, Nuclear Regulatory Commission (NRC) established paragraph (f) to separate the IST Paragraph (f)(4)(iv) in 10 CFR 50.55a specifies requirements from the inservice inspection that inservice tests of pumps and valves may requirements in paragraph (g). The American meet the requirements in subsequent editions and Society of Mechanical Engineers (ASME) Boller addenda that are incorporated by reference in and Pressure Vessel Code (the Code), Section paragraph 50.55a(b), subject to the limitations XI, Subsections IWP and IWV, specify the IST and modifications listed in paragraph 50.55a(b),

requirements for pumps and valves. The 1989 and subject to Commission approval. Portions edition of Section XI was incorporated by of editions or addenda may be used if all related reference into paragraph 50.55a(b) by the requirements of the respective editions or rulemaking effective September 8,1992. The addenda are met. The Commission resolved 1989 edition specifies that the rules for the IST various issues by approving OM-6 and of pumps and valves are stated in the OM-10 as discussed herein. Licensees may ASME/ ANSI Operations and Maintenance (OM) implement the later Code editions, or porticas Standards, Part 6, " Inservice Testing of Pumps thereof, pursuant to paragraph 50,55a(f)(4)(iv) in Light-Water Reactor Power Plants " and Part without relief, based on the approval as indicated 10, " Inservice Testing of Valves in Light-Water in Sections 3,4, and 5, provided the IST Reactor Power Plants." An exception to OM-10 program includes documentation of was taken for leakage testing of containment implementation of the later requirements in isolation valves.

accordance with the new guidance herein.

Licensees are required to prepare IST programs Regulatory IIistory which specify the components included in the program, and the testing and test frequencies for The NRC previously issued guidance for these components, and to implement the ruram implementing IST requirements. After in accordance with the Code. The regulations publishing the rule which established the allow that where a test requirement of the Code requirements for IST (Federal Register notice of is determined to be impractical for a facility, the February 27,1976), NRC sent letters to notify licensee may submit requests for relief from the operating licensees of the new rules. In Code with information to support the November 1976, after receiving inquires from determination. Relief requests generally detail licensees regarding acceptable methods for the reasons for deviating from the Code complying with the regulation, the NRC issued requirements and describe proposed alternative letters to licensees which transmitted "NRC Staff 1-1 NUREG 1482

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Guidance for Complying with Certain Provision NRC Recommendations or New of 10 CFR 50.55a(g), ' Inservice Inspection Guidance Requirements.'"

The guidance and positions presented in GL 89-In an effort to eliminate the backlog of IST 04 are supplemented by the recommendations program reviews for operating nuclear power presented herein. Appendix A is a compilation plants, on August 3,1989, NRC issued Generic of the 11 positions in GL 89-04, Attachment 1, Letter (GL) 89-04, " Guidance on Developmg with questions and answers from the meeting Acceptable Inservice Testing Programs," which minutes, and a discussion of the curre '

included 11 techmcal positions used by the staff applicability of each position and the jplication m reviewmg IST program relief requests and of GL 89-04 to OM-6 and OM-10.

describmg alternatives to the Code requirements acceptable to the staff. In GL 89-04, the staff The guidance included herein may be used for also approved six of these positions (1,2,6,7, requesting relief. In evaluating such requested f

9, and 10) pursuant to 10 CFR 50.55a (g)(6)(i) relief, the NRC will use the guidance in the with the provision that the licensee perform the recommendations herein. The NRC may alternative testing delmeated in the applicable reference a recommendation herein in future position. The staff approved these alternatives safety evaluations and grant relief or authorize upon recognizing the impracticality in t

the alternative if the licensee has addressed all of performmg the required testmg and the burden if the aspects included in the applicable section the requirements were imposed.

herein. The document also discusses OM-6 and OM-10, which may be implemented by licensees The staff held four pubh.c meet.mgs to discuss pursuant to 10 CFR 50.55a (f)(4)(iv). This GL 89-04 and summarized the quest,ons and document gives the requisite approval for answers from these meetmgs m a letter of 10 CFR 50.55a (f)(4)(iv) as discussed in the i

October 25,1989,

• Minutes of the Pubhc positions for the following issues.

Meetings on Gener,ic Letter 89-04." This letter t

contained information useful in applying the 3.1.1 Deferring Valve Testing to Cold guidance m GL 89-04 and included discussion of Shutdown or Refueling Outage issues of interest to licensees who attended the public workshops. In a letter of September 16' 3.3.2 Concurrent intervals (in part) 1991, the staff issued " Supplement to Minutes of the Public Meetings on Generic Letter 89-04" to 4.1.3 Extension of Test Interval to address a question on stop-check valve testmg.

Refueling Outage for Check Valves Verified Closed by Leak Testing S.mce issumg GL 89-04, the NRC has incorporated the 1989 edition of the Code in 10 4.2.5 Verification of Remote Position CFR 50.55a(b). The 1989 edition of the Code incorporated OM-6 and OM-10, which melude Icdication for Valves by Methods Other Than Direct Observation rules for IST that were written with the recognition of the maturity of the nuclear 4.2.7 Stroke Time Measurements Using industry. Certam tests and measurements Reference Values required by previous editions of the Code were eliminated or changed in these standards.

4.3.3 Test Supervisor Qualifications 4.3.4 Frequency and Method of Testing Automatic Depressurization Valves in Boiling Water Reactors NUREG-1482 1-2

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4.4.3 Multiple Containment Isolation Valve Synopsis of Report Leak-Rate Testing Section 2 identifies existing requirements on 4.4.5 Leak-Rate Testing Using OM-10 IST, discusses the scope of the IST program, Requirements and describes guidance for presenting information in IST programs, including cold 5.1.2 Continued Measurement of shutdown justifications, refueling outage l

Parameters Deleted from OM-6 justifications, and relief requests. The section.

includes a sample list of plant systems for -

5.3 Allowable Variance from Reference boiling-water reactors (BWRs) and pressurized-

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(for fixed resistance systems) water reactors (PWRs) that typically contain Code pumps or vaiva that perform a safety 5.4 Monitoring Pump Vibration Per function. The section also includes information OM-6 needed for licensees to establish the tests and test frequencies proposed for pumps and valves in an 5.7 Use of OM-6 Table 3b Ranges for IST program.

Hydraulic Parameters Section 3 describes NRC recommendations and 5.8 Duration of Tests I

their bases for several general aspects of IST.

Section 4 describes recommendations on valve If a licensee chooses to implement this guidance, issues. Section 5 describes recommendations on -

deviations from the provisions of the guidance pump issues. Section 6 discusses the revised require a relief request. If a licensee implements standard technical specifications. Section 7 any or all of these recommendations, it must discusses the process for licensees to follow discuss the use of each recommendation in the when a Code nonconformance is found.

IST program document.

In the appendices, the staff consolidates and Other Information updates the information from GL 89-04 and other sources related to IST programs, and Other information on IST can be found in NRC provides examples of relief requests that have-inspection procedures (IPs) and temporary been submitted for evaluation and review.

instructions (tis) as follows:

Throughout Sections 3,4, and 5, the staff IP 73756, " Inservice Testing of Pumps and discusses issaes for which plants have requested Valves," March 16, 1987 relief and g ves guidance on the type of I

i information that would typically (or in some TI 2515/110, " Performance of Safety-Related cases must, be included in relief requests for Check Valves, November 19,1991 these issuos. It also discusses Code and l

regulatory issues and gives recommendations.

TI 2515/114, " Inspection Requirements for The discussions of issues and recommendations i

Generic Letter 89-04, ' Acceptable Inservice do not imply additional requirements beyond the Testing Programs,'" January 15, 1992 Code or the regulations and do not represent backfits; however, some of these discussions address existing requirements of the Code or the regulations and are intended to be clarifying.

t The guidance provided in this report is not intended to convey any new requirements or i

positions on IST. Where the requirements of 1

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NRC regulations or the American Society of The term must is used in connection with some Mechanical Engineers Boller and Pressure provisions of the guidance herein to indicate Vessel Code (the Code), as incorporated into the that, if a licensee chooses to implement the regulations, are discussed, the terms shall, must, guidance of a section, such provisions in that requires, or requirements are used consistently to section are to be followed without deviation in indicate their mandatory nature. [The term must order for the licensee to be credited with is also used in another manner in the context of satisfactorily meeting the guidance of th;t implementing guidance (not requirements), as section. Where a recommendation is made, the discussed below.]

licensee may choose whether or not to follow the guidance. The discussion of previous guidance Where only guidance on IST is intended, the issued in Generic Letter 89-04 or other NRC terms NRC or staf recommendation, -

documents does not convey new requirements, recommends, acceptable to the staf, acceptable, or licensee may or typically would are used to denote staff preferences, or practices that have been determined by the staff to be acceptable means of implementing requirements of the regulations or the Code.

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2 DEVELOPING AND IMPLEMENTING AN INSERVICE TESTING PROGRAM Licensees may use the following guidance for Code,Section XI, in its entirety ce for certain developing and implementing inservice testing portions, for IST programs.

(IST) programs. This guidance is supplemental to existing requirements and previously approved The regulations include the upper tier guidance on IST.

requirements for IST. The requirements of tha ASME Code, as incorporated by reference into i

2.1 Compliance Considerations the regulation, have the force of law. The technical specifications include general and specific requirements for IST and other Code of Federal Regulwions, Title 10, Section surveillance testmg of pumps and valves. The 50.55a (10 CFR 50.55a), " Codes and Standards " states requirements for IST of play sa ey ap lyses include information on the design limitations and functional requirements certain safety-related pemps and valves. These f r the performance of pumps and valves for a components are to be rested according to the facility. The IST program, includ,mg relief requirements of Section XI of the American mquests and data analysis methods, describes the Society of Mechanical Engineers (ASME) Boiler

• **"' '*' ""P ** *"' '"E * * **A *

• I and Pressure Vessel Code (the Code),

P n 3 ro s

u o est tier e i sting is ntend t

ss e ati n i on T elemets, readiness of components. He tests conducted during the initial and successive 120-month agulat.ons am m au 13 govemkg 6e j

intervals are to be based on the requirements in implementation of the varicus IST requirements.

the applicable edition and addenda of the Code, ere m, w n a kensee Onds a wnmet to the extent practical, within the limitations of between the regulations and any of the lower tier design, geometry, and materials of construction, as described in 10 CFR 50.55a(f)(4).

'*9"'".ments (pmgram r pmc dums), dm regulations must be met. The staff's response to Question 69 (see Appendix A) gives guidance on Paragraph 50.55a (f)(4)(ii) requires that IST.m cases where the licensee modifies its plant in a each 120-month interval following the mitial ht h h his k a Miht b mterval be conducted m compl,ance with the i

previously been granted. Similarly, if a licensee requirements of the latest edition and addenda of has obtained approval of an alternative pursuant the Code mcorporated by reference in to 10 CFR 50.55a (a)(3)(i) or (ii), the licensee 10 CFR 50.55a(b), m effect 12 months before need not use the alternative if it determines that the start of the m, terval. Pursuant to continued compliance with the Code 10 CFR 50.55a(f)(4)(iv), IST may meet the requirements is warranted or necessary for requirements of subsequent editions and addenda particular circumstances that may preclude i

mcorporated by paragraph (b) or portwns of a implementation of the alternative method. When revised edition of Section XI. The licensee must an implementing procedure is revised, the receive the Commission's approval before licensee typically ensures that the IST program conductmg these tests. When port,ons of a reflects the required testing before or while the i

revised edition are used, all related requirements implementing procedure is revised and that the of the respective editions or addenda must be revision does not conflict with any upper tier met. This document gives approval for licensees requirements' to implement the 1989 Edition of the ASME 2-1 NUREG-1482

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When a system, subsystem, or component is

• Section 50.5Fa (a)(3)(ii) allows the NRC to modified according to 10 CFR 50.59, or when authorize an alternative if " compliance [with an operating or test procedure or valve the Code requirement] would result in alignment is changed under Section 50.59, the hardship or unusual difficulty without a licensee typically reviews the IST requirements compensating increase in the level of quality for new or affected components for any required and safety." The NRC may approve an changes to the program, alternative pursuant to this provision if, although the proposed alternative testing does Standard Technical Specincation 4.0.5 and the not comply with the Code, the increse in corresponding technical specification for each overall quality and safety at the plant wwld plant, state that IST of ASME Code Class 1,2, not compensate for the difEculty of and 3 pumps and valves shall be performed in compliance.

accordance with Section XI of the Code and Applicable Addenda as required by

• Section.50.55a(f)(6)(i) states:

10 CFR 50.55a. According to the regulation, if a revised IST program conflicts with the The Commission will evaluate technical speci0 cations for the facility, the determinations... that Code licensee shall apply to the U.S. Nuclear requirements are impractical. The Regulatory Commission (NRC) to amend the Commission may grant such relief and technical specifications to conform with the.

may impose such alternative revised program, or otherwise meet the requirements as it determines is requirements of the technical specifications and authorized by law.. giving due 10 CFR 50.55a (see 10 CFR 50.55a (f)(5)(ii)).

consideration to the burden upon the This pro 'ision in the rule specides actions to be licensee if the requirements were taken by a licensee when a revised inservice imposed on the facility.

inspection (testing) program for a facility conflicts with the technical speci0 cations (see 41 The NRC may grant relief pursuant to this Federal Register 6256, " Statements of provision if the licensee demonstrates that the Consideration," published February 12, 1976).

design or access limitations make the Code requirement impractical and may impose -

The NRC may authorize alternatives to coa alternatives. The burden ofimposition of the testing requirements submitted as relief requests.

Code requirements on the licensee is considered Section 50.55a includes the following provisions in the staff's evaluation.

for accepting alternatives or granting relief:

The NRC periodically issues revisions to

• Section 50,55a (a)(3)(i) allows the NRC to Regulatory Guide (RG) 1.147, " Inservice authorize alternatives if "the proposed Inspection Code Case Acceptability ASME alternatives would provide an acceptable level Section XI Division 1," which lists the ASME.

of quality and safety." The NRC will Code cases fbund suitable for use (see footnote 6 normally approve an alternative pursuant to of 10 CFR 50.55a). Without obtaining further this provision only if the licensee proposes a NRC review, the licensee may implement the method of testing that is an equivalent Code cases listed in RG 1.147 for IST programs, method, or an improvement, to the Code if the Code cases are used in their entirety, with method, or if the testing will comply or is any supplemental conditions specified in the consistent with later Code editions approved regulatom guide. The following Code cases are by NRC in Section 50.55a(b).

liste.1 m Revision 10 of RG 1.147:

NUREG-1482 2-2

N-415 " Alternative Rules for Testing Assurance Criteria for Nuclear Power Plants and Pressure Relief Devices" Fuel Reprocessing Plants." Changes to the scope, test methods, or acceptance criteria are N-427 " Code Cases in Inspection Plans,"

subject to the requirements of Section 50.59, which describes how an owner may use a

" Changes, Tests, and Experiments."

Code Case in an inspection or testing program. This case is acceptable with the The technical specifications for most plants sentence for paragraph (b)(1) replaced with include IST requirements which are more the following: " Code Cases that were restrictive than the regulations. Section 6 superseded with revised Code Cases and had describes how licensees may amend their been approved for use in accordance with (a) technical specifications requirements for IST to may continue to be used."

better address the regulations as the governing requirements.

N-465 " Alternative Rules for Pump Testing,"

which references the 1987 Addendum of OM-2.2 Criteria for Selecting Pumps 6 is referenced. However, the correct and Valves for the IST Program reference is OMa 1988, Part 6, since no 1987 Addenda were issued.

Subsections IWV-1100 and IWP-1100 of Section ine e SmPC e

Pmgram for, 1

N-472 "Use of Digita! Readout and Digital i excepu ns &gned in l

pumps an va w

Measurement Devices for Performing Pump IWP-1200 and IWV-1200 Both Section XI and Vibration Testing" 10 CFR 50.55a(f) specify that the IST program include pumps and valves in Code Classes 1,2, Subsections IWP and IWV of the ASME Code requ to perform a spg safety have been replaced in the 1988 Addenda and the uncu.m. W W86 don of Secuon M 1989 edition of Section XI, by Parts 6 and 10 of to,npuh valves i

s po the ASME Operation and Maintenance (OM)

• E *" '.

E"

"*'E'***"' E"

1. I*"* ** # I' Standard, " Operation and Maintenance of rela class systents, subsystems, and

+

Nuclear Power Plants, ASME/ ANSI [ American mmpments.

arts 6 and m oW M88 National Standards Institute) OM-1987" (1988a to ge MEM e um a

addenda of OM-6 and OM-10).

OM-1987 Standard, " Operation and Maintenance of Nuclear Power Plants " and Subsections ISTB The OM Standard was rewritten, though n 1.1 and ISTC 1.1 in the ASME OM Code, also sigmficant techmcal changes were made, and defme the scope of the IST program for pumps was approved by the Board on Nuclear Codes and valves. However, the scope of the OM and Standards m 1990 as the " Code for Standards and Code has been expanded to Operation and Maintenance of Nuclear Power include all safety-related pumps and valves in the Plants, ASME OM Code-1990." The OM Code IST program. Until the scope of 10 CFR 50.55a includes pump, valve, and snubber IST is changed, the scope of the IST ri: gram will requirements. While OM-6 and OM-10 have continue to include those comp ^nents within the been mcorporated into the regulation through the Code classes. In future rulen aking, the NRC 1989 edition of ASME Section XI, the NRC has will consider expanding the cope to include all not yet mcorporated the OM Code int safety-related pumps and valves. However, if 10 CFR 50.55a.

licensees elect to consolidate testing for pumps and valves, the IST program (designating any An IST progrnm, m.elud.mg implement.mg non-Code components as such) rr ay be procedures, is subject to the requirements of 10 CFR Part 50, Appendix B, " Quality NUREG-1482 2-3

acceptable for meeting other testing requirements Waste-Containing Components of Nuclear Power for safety-related pumps and valves. Relief Plants."

requests for non-Code components may be implemented without NRC evaluation and 2.4 IST Program Document approval.

The following discussion applies to both pumps The current scope defined by the Code includes and valves and describes the information pumps and valves required to achieve and generally needed to prepare the IST program.

maintain cold shutdown. If the plant was licensed for a safe shutdown condition of hot 2 A.1 Pugs standby or hot shutdown rather than cold shutdown, the IST program document will Section XI of the Code includes the rules for stipulate that the plant was not designed and inservice inspection (ISI) and IST of nuclear licensed for a safe shutdown condition of cold power plant components. Subsection IWA shutdown. In discussions with ASME Code includes general requirements for the inservice committee members, the NRC informed the nspection of components, and Article IWA-6000 committee members that many early plants were licensed to operate with a " safe" shutdown of that subsection addresses records and reports required for these inspection programs.

condition of hot standby or hot shutdown, and were not required to achieve cold shutdown after IWA-6210(a) states that the owner shall prepare plans and schedules for inservice examinations a design basis accident. For such plants, and tests to meet the requirements of Section XI.

comp (ments and systems necessary to achieve IWA-6220(a) states that examination, test, cold shutdown may not, therefore, be safety-replacement, and repair records shall be related or subject to quality assurance requirements. 'These components are not prepared in accordance with the requirements of respective articles of Section XI. However, credited to achieve " safe" shutdown m plant Article IWP-6000 includes minimal guidance for safety analyses. Recognizing the discrepancy the information that could be included in the IST-between the Code requirements and the licensing basis for such plants, the ASME Code committee program for pumps that perform a safety recently revised the scope to " safe" shutdown function. Licensees have found that pump tables are a convenient format for the information.

rather than " cold" shutdown.

The pump table is a convenient format for 2.3 Code Class Systems Containing identifying pumps and testing requirements. The Safety-Related Pumps and tables typically include enough information to Valves allow for NRC inspectors to evaluate if the testing complies with the Code requirements for The plant safety analysis report (SAR), technical test method and frequency and note applicable specifications (TS), and other ' documents list the NRC positions or recommendations for each systems and components that must function to

pump, support the safe operation and shutdown of the plant. Tables 2.1 and 2.2 list systems and In preparing pump tables, the licensee could comp (ments typically in the IST programs for consider the following information, which pressurized-water reactors (PWRs) and boiling _

includes headings and a description of the text water reactors (BWRs). For information on that could be included under each heading, as quality group and Code classifications, see RG depicted in Table 2.3.

1.26, " Quality Group Classifications and i

Standards for Water, Steam, and Radioactive _

7Ytle: List the applicable plant and unit.

NUREG-1482 2-4 f

. _=..

l' l'

Page number Include the page number and exempted according to IWP-4300 (not total number of pages in the program or required by OM Pan 6).

program section.

(c)

Pump bearings are of the permanently Pragmm revision or revision date: List the sealed and lubricated design; therefore, this program or page revision number and date on pump is exempt from the requirement to each page. List the revision number for each observe lubricant level or pressure (not program change submitted.

required by OM Part 6).

System: List the plant system in which the The previous notes can be used where Code pump is located or briefly describe the service of testing would otherwise be required. A relief th pump.

request is not required in these cases because the

.I test requirement is exempted by the Code or Pump identification: List a unique identifier for because the pump design makes the pump each pump to be used consistently in all bearing lubricant level or pressure a parameter documentation for the IST program and design which cannot be observed.

information such as system piping and instrument diagrams (P&lDs), test procedures, Reliefrequest(s): List any applicable relief and relief requests.

requests in the pump table.

Piping and instrument diagram number: List 2.4.2 Valves the P&ID or figure showing the pump in the system.

Section XI of the ASME Code and OM Part 10 list the requirements for the IST of valves at Dmwing coordinates: List the coordinates nuclear power plants. A valve table is a which locate the pump on the piping and convenient format for identifying valves and instrument diagrams, testing requirements for IST. The tables typically have included enough information to Test pammeters: List each of the seven evaluate if the testing complies with the Code inservice test quantities in Section XI, Table requirements and with NRC's positions.

IWP-3100-1, or the five parameters in Table 2 of OM Part 6, for each pump. A column or a 7Ytle: List the applicable plant and unit.

footnote is typically used to identify factors affecting testing. List a relief request number Page number: Include the page number and where the testing cannot be performed as total number of pages in the program or required.

program section.

Examples of notes often used with pump testing Pmgram revision orpage revision date: List j

tables are as follows:

the program or page revision number and date on each page. List the revision number for each (a) The pump is directly coupled to a constant program change submitted.

speed synchronous or induction-type j

driver, and measurement of rotative speed System: List the plant system in which the

)

is exempted according to IWP-4400.

pump is located or briefly describe the service of the valve.

i (b) The pump bearings are located in the main flow path of the working fluid, and Valve identification: List a unique identifier for measurement of bearing temperature is each valve in a consistent manner in all IST and 2-5 NUREG-1482

j i

design documents, including system P&lDs, test Testfrequency: If performing the test at the procedures, and relief requests.

frequency specified in the Code is impractical or burdensome, reference cold shutdown or Piping and instrument diagram number: List refueling outage justifications (OM-10), or relief the P&lD or figure showing the valve in the requests for test frequency. List the actual test system.

frequency.

Drawing coontinates: Specify the location of Relief requests and cold shutdown / refueling the valve on the piping and instrument diagrams.

outagejustifications: List any applicable relief request (s) in the valve table. When the testing is Valve type List the valve type (i.e., gate, deferred to cold shutdowns or refueling outages globe, check, relief).

(OM-10), reference the technical justification (cold shutdown justification or refueling outage Valve sir.e: Specify the valve size in inches, justification) for the test frequency.

fractions of an inch, or in metric units.

Remarks: Include pertinent information not Actuator type: List the type of valve actuator stated elsewhere in the table such as notes or a (i.e., motor, solenoid, pneumatic, hydraulic, brief functional description of the valve.

self) with the type and function of the valves to determine the Code category and the required Figures in Appendix B depict excerpts from testing. For example, a motor-operated gate valve tables for IST programs that have been valve could be in Code category A or B. A self-submitted to NRC. Table 2.4 lists common actuated check valve could be in category C or abbreviations used in tables.

A/C.

2.4.3 Piping and Instrument Diagrams Code category: Specify the Code category, as defined in IWV-2100 and paragraph 1.4 of OM-The staff recommends that piping and instrument

10. This determines the applicable subsections diagrams (P&lD.<; or system drawings be of the Code.

included in the 70 gram submittal to assist in identifying the pemps 9nd valves included in the Actire/Passire: State whether a valve is active program. These dn wings should be the latest or passive as defined in Section XI (paragraph revision at the time the program is submitted to IWV-2100 before 1986 edition and paragraph NRC. Inservice inspection boundary system IWA-90001986 edition and later), or OM-10, drawings and isometries, or reduced size paragraph 1.3. Requirements vary based on the drawings are suitable to be included in the function of the valve.

program document, if the reduced drawings are not complete P&lDs, the staff may request a set Safety position: List the safety function of full-size drawings for evaluating relief position (s), specifying both positions for valves requests. A partial submittal of the program that perform a safety function in each of the containing relief requests could include open and closed positions. Valves must be drawings, if applicable, to support the relief exercised to the position (s) required to fulfill requests or to supersede previous IST program their safety function (s),

drawings. Program drawings need not be updated regularly, but if drawings change Tests performed: Specify which tests are to be because of modifications, or if relief requests are performed on each valve, affected, the staff recommends drawings be revised and submitted to NRC in the next periodic submittal of revisions to the program NUREG-1482 2-6 J

document. The staff also recommends licensees Sections 3 and 4 which give guidance on include applicable drawings with relief requests deferring testing.

that are very detailed and are submitted to supplement the IST program.

2.5 Relief Requests and Proposed Alternatives 2.4.4 Bases Document When a relief request is submitted to the NRC The staff recommends that each licensee create a fx rcziew and approval, for relief from bases document for the IST program. A paper requirements of the Code, or for authorization to discussing the creation and management of a use proposed alternatives, the staff recommends bases document is included in NUREG/CP-0123, that the basis for relief address whether (1) the Supplement 1, " Proceedings of the Second proposed alternative gives an acceptable level of NRC/ASME Symposium on Pump and Valve quality and safety, (2) compliance would result Testing." Bases documents typically have in a hardship without a compensating increase in included a description of the methodology used safety, or (3) complying with Code requirements for preparing the IST program, with a listing of is impractical. The justification must include 1

each pump and valve in a system within the adequate information for the staff to determine if boundaries for a Code class, and the basis for the alternative can be authorized or relief can be including or excluding the pump or valve in the granted (e.g., as applicable, damage to IST program and the basis for the testing applied equipment, hazards to personnel, and the to each component.

possibility of a plant trip in the details of the proposed alternative). For those requirements Although not required by the NRC, the bases which have been determined to be clearly document will help the licensee ensure continuity impractical, the licensee may implement the i

of the IST program when the responsibilities of proposed alternative testing while the NRC is personnel or groups change. A bases document reviewing the relief request (see Section 6).

~

will also enable the plant staff to clearly understand the reasons that the components are The staff performs a detailed review of each either in the program or not in the program.

relief request, authorizes an Jternative to the This document is considered a useful reference requirements or grants relief from the for reviews performed under 10 CFR 50.59 requirements, and may impose alternative when changes to a facility are made.

requirements. When granting relief, the NRC considers the burden on the licensee that would 2.4.5 Deferring Valve Testing to Cold result if the requirements were imposed.

Shutdown or Refueling Outages 2.5.1 Justifications for Relief Exercising valves on a cold shutdown frequency is not a deviation from the Code. The Code The NRC considers the merits of the submitted allows for testing during cold shutdown outages technical information when it determines to grant if it is impractical to test quarterly during or deny relief from the Code requirements or to operation. OM-10 allows for a refueling outage authorize alternatives. In requesting relief, the frequency if it is impractical to conduct testing licensee would typically describe the specific quarterly while in operation and during cold relief requested, describe the proposed shutdown. However, the licensee must identify alternative (s), describe the basis for relief or for these valves in the program and include cold the alternative, and clarify the burden that would shutdown justifications or refueling outage result if the requirements were imposed. The justifications for each valve or group of valves affected. This issue is discussed further in 2-7 NUREG-1482

staff has determined in previous safety pump by exercising a valve in the cooling evaluations for plant-specine requests that the tiow path could damage the pump.

following are examples of situations that warrant i

relief or alternatives:

• Failure of a component during testing could disable multiple trains of a reactor safety

• In complying with the Code requirements, the system. For example, a motor-operated licensee would not obtain information more suction valve common to both trains of high useful than the information currently pressure safety injection could not be tested available. For example, installing an analog during power operation because a failure of gauge with a range of three times the the valve results in both trains being out of reference value (or less) to comply with Code service (see Section 3.1.2).

requirements may not yield more accurate reading than the accuracy of the one presently Inconvenience or administrative burden are not, installed (see Section 5.5.1).

alone, adequate justification for deviating from the Code requirements. Entering a TS limiting

• Compliance with the Code is impractical condition of operation (LCO), except when because of design limitations. Imposition of entering the LCO would be prohibited because the Code requirements would require the total system function would be out of significant system redesign and modifications.

service, is also not, alone, adequate justification For example, a flow meter does not meet the for deviating from the Code-specified frequency accuracy requirements of IWP-4110 because (see Section 3.1.2).

the present system configuration does not have a straight section of pipe of sufficient 2.5.2 Categories of Relief Requests length in which to measure flow accurately (see Sections 5.5.1 and 5.5.2).

General: A general relief request is appropriate when the relief being requested is applicable to a

• The required measurements or appropriate broad range of similar components in the observations cannot be made because of program.

physical constraints. Examples include a component located in an area inaccessible Specific: A relief request is specific when the during operation or a pump totally immersed relief being requested applies only to a single in the system iluid.

component or a specified group of similar components in the program.

• The need to keep personnel radiation exposure as low as reasonably achievable 2.5.3 Content and Format of Relief (ALARA) may present an adequate Requests justification. The licensee included information about the general area radiation The staff recommends that each relief request field, local hot spots, plant radiation limits include the following information in the order and stay times, the amount of exposure stated, as a minimum. Appendix C includes personnel would receive in performing the examples of relief requests that have been testing, and the safety significance of submitted by licensees.

deferring testing or performing an alternative method.

Title and relief request number: Entitle and specify a unique identifier for each relief

• Testing as required by the Code could cause request.

significant equipment damage. For example, shutting off cooling flow to an operating NUREG-1482 2-8

1 Page number: List the page number and total for the pump. They will also be full-stroke number of pages in the program or program exercised with flow into the reactor coolant section, such as "Page 15 of 135."

system during refueling outages.

Progmm revision orpage revision date: List

• These valves will be part-stroke exercised the program revision number or page revision during cold shutdown outages using the power date on each page.

operator on the test arm. They will also be full-stroke exercised during refueling outages System and Code class: List the phmt system by means of the full accident-required flow and Code class of the system in which the injected into the reactor coolant system.

component is located.

l

• These valves will be part-stroke exercised Valre category: List the ASME category for during cold shutdowns with flow from the -

valves (i.e., A. A/C, B, C, or D).

residual heat removal system. Their full-stroke capability will be verified during Component identification: List the identification refueling outages. They will be disassembled, number for each component in a specific relief the internal components examined, and the request. In a general relief request, :r.:ch as for valve disk manually stroked. The guidance in all pumps in the IST program, each individual Generic Letter (GL) 89-04, Position 2, will component need not be listed. However, the list be followed for the disassembly and of program comp (ments (pump or valve table) inspection program, including a partial-flow must include the relief request number, test following reassembly.

Componentfunction: Briefly describe the Discuss the proposed alternate in sufficient detail functions of the components and specify the to clearly illustrate that it presents a reasonable function which is the subject of the relief alternative to the Code requirement. State and request.

justify the proposed frequency in the " basis."

The relief request should be self-contained to the AShiE Code test requirement (s): List and extent practical.

describe the Code requirement (s) from which relief is being requested.

Drawings and/or diagrams: If the relief request or alternative testing is complex, or if drawings Basisfor relief Discuss the basis for requesting or diagrams are available for further relief or proposing the use of an alternative clarification, they could be included in the relief including the reasons for which compliance with request or could be referenced and included in the Code requirements is impractical or the the IST program document.

1 proposed alternative is a preferred test. Include justification for the test frequency.

References:

List references to SAR sections, technical specifications, and other pertinent Proposed alternate testing: Clearly and documents (e.g., applicable position of GL 89- -

thoroughly present the proposed alternative.

04). If any document is referenced in the relief request, submit it to the NRC on the plant

'Ihe following are acceptable examples of docket. If a document is not submitted, but introductory statements for this section of the contains pertinent information, the relief request relief request:

should include the information rather than merely referencing the document.

• These valves will be part-stroke exercised quanerly by way of the minimum flow line 1

2-9 NUREG-1482

Table 2.1 Typical systems and components in an inservice testing program for a pressurized-water reactor Typical safety-related, Code class systons in pressurized-water reactors Typical components In an insenice testing program :

Reactor coolant system and flowpaths for Power-operated relief valves and associated block valves establishing natural circulation Reactor high point and head vents Primary system safety and relief valves (pressurizer Code safety valves)

Valves in any proposed flow path used for long-term core cooling or safe shutdown Pressure boundary isolation valves Valves in lines to pressurizer relief / quench tank Main steam system Main steam isolation valves (MSIVs)

Main steam non-return valves (if applicable)

Secondary system safety and relief valves Atmospheric dump valves Auxiliary feedwater turbine steam supply valves Steam generator blowdown isolation valves liigh-pressure safety injection system High pressure injection pumps and discharge check valves injection valves in injection flowpath Isolation valves t

l Valves for the refueling water storage tank (RWST) borated water storage tank (BWST), refueling water tank (RWT), including vacuum breakers Chemical and volume control or makeup Charging or makeup pumps and discharge check valves l

I system Valves in charging / makeup flowpath l

Boric acid transfer pumps and discharge check valves Valves in emergency boration flow paths Relief valves NUREG-1482 2-10

t Table 2.1 Typical systems and components in an inservice testing program for a pressurized-water reactor (continued)

Typical safety-related, Code class systems in pressurized-water reactors Typical components in an inservice testing program -

1.ow-pressure safety injection system injection pumps and discharge check valves Valves asrxiated with safety injection accumulators and core D.:,od tanks Recirculation flowpath valves, including contaimnent sump isolation valves Isolation valves (high-low pressure interface)

Relief valves Shutdm.a cooling, residual heat removal, Pumps and discharge check valves or decay heat removal systems Valves in flowpath Isolation valves (high-low pressure interface)

Relief valves Containment spray system Containment spray pumps and discharge check valves Valves in flowpaths to spray header Isolation valves Valves in spray additive flowpath Spray additive tank valves, including vacuum breakers Main feedwater system Main feedwater isolation valves Auxiliary feedwater system Auxiliary feedwater pumps and discharge check valves Valves in flowpath to steam generators Valves in suction lines Valves between normal and ultimate heat sink suction sources Relief valves and isolation valves Primary containment system Containment isolation valves (various systems)

Containment combustible gas venting valves Containment atmosphere sampling valves (if within the scope of 10 CFR 50.55a) 2-11 NUREG-1482

Table 2.1 Typical systems and components in an inservico mting program for a pressurized-water reactor (continues *,

w

~ Typical safety-related, Code class systems in pressurized-water reactors'-

Typical comp (ments i:. an inservice testing program Component cooling water system Component cooling water pumps and discharge check valves Valves in letdown cooling water flowpath 1

Valves in reactor coolant pump seal injection and cooling

)

water flowpath Relief valves Spent fuel pool / pit cooling system Spent fuel cooling pumps and discharge check valves Valves in flowpath from ultimate heat sink source supply Service water system Service water pumps and discharge check valves t

Valves in flowpath to auxiliary feedwater system Valves in flowpaths to emergency room coolers Valves in flowpaths to containment emergency coolers Valves in flowpaths to emergency diesel generator heat exchangers Isolation and cross-tie valves Valves in ultimate heat sink source flowpaths Valves in standby or backup service water, if applicable Emergency diesel generator system (within Fuel oil storage and transfer pumps and valves scope of 10 CFR 50.55a)

Diesel generator external cooling (service water)

Engine air start check valves Air receiver relief valves Ventilation systems Pumps and valves in control room emergency cooling water supply flowpath Instrument air system (if within the scope Air supply to containment purge valves of 10 CFR 50.55a)

Air supply to power-operated relief valves (PORVs)

Air supply to MSIVs NUREG-1482 2-12

Table 2.2 Typical systems and components in an inservice testing program for a boiling-water reactor Typical safety-related, Code class systems in boiling-water reactors.

Typical components in an inservice testing program -

Nuclear boiler and reactor recirculation Primary system isolation valves system Excess flow check valves Main steam system MSIVs and actuator valves (pilot valves, accumulator check valves)

Main steam safety and relief valves Main steam safety valve discharge rupture diaphragm valve MSIV leakage valves liigh-pressure core coolant injection (IIPCI)

Pump and discharge check valve system Valves in injection flowpath Isolation valves, including valves in test lines Excess flow check valves 11PCI pump turbine valves, including turbine exhaust vacuum breakers (unless considered skid-mounted) liigh-pressure core spray system Pumps and discharge check valves Valves in injection flowpath Isolation valves, including valves in test lines Reactor core isolation cooling (RCIC)

Pump and discharge check valve system (if safety-related)

RCIC pump turbine valves Excess flow check valves Isolation valves Reactor water cleanup system Containment isolation valves Residual heat removal (RllR) system RilR pumps and discharge check valves Isolation and cross-tie valves Pump suction relief valves RIIR heat exchanger thermal relief valves Valves in injection flowpath Flow control valves Spent fuel pool cooling system Fuel pool pumps and discharge check valves Ultimate heat sink supply valve 2-13 NUREG-1482

l Table 2.2 Typical systems and components in an inservice testing program for a boiling-water reactor (continued) j l

Typical safety-related, Code class systems in boiling-water reactors Typical components in an inservice testing program -

Feedwater coolant injection and isolation Reactor feedwater pumps and discharge check valves condenser system (if applicable)

Condensate pumps and discharge check valves Condensate booster pumps and discharge check valves Emergency condensate transfer pump and discharge check and isolation valve Isolation and bypass valves Vent valves l

Makeup to condenser shell check valves Standby liquid control (SBLC) system SBLC pumps and discharge check valves 1

Relief valves injection line valves Explosively-actuated squib valves Main feedwater system Isolation valves Primary containment system Containment isolation valves including excess flow check valves (various systems)

Containment atmosphere monitoring system valves Containment atmosphere dilution system valves Containment pressure suppression and vents Closed cooling or component cooling water Pumps and discharge check valves system Valves in flowpaths to safety-related coolers Service water system Pumps and discharge check valves Isolation and cross-tie valves l

l Valves in flowpaths to safety-related coolers l

/

Valves in flowpaths to diesel generator coolers Valves in standby or backup service water Valves in flowpath from ultimate heat sink source Valves in residual heat removal service water flowpath r

l l

t l

l

\\

NUREG-1482 2-14

Table 2.2 Typical systems and componenta in an inservice testing program for a boiling-water reactor (continued)

Typical safety-related, Code class

systans in boiling-water reactors.

Typical componen'ts in an inservice testing program -

Control rod drive system (portions within Scram dump valves the scope of 10 CFR 50.55a)

Scram discharge volume vent valves Scram discharge volume drain valves Accumulator rupture disks liydraulic control unit control valves Drive water backflow prevention valves Emergency diesel generator systems (if Fuel oil storage and transfer pumps and valves within the scope of 10 CFR 50.55a)

Diesel generator external cooling (service water)

Engine air start check valves Air receiver relief valves Ventilation systems Pumps and valves in control room emergency cooling water supply flowpath Instrument air system (if within the scope MSIV accumulator check valves of 10 CFR 50.55a)

MSIV pilot valves Automatic depressurization system (ADS) valve accumulator check valves ADS pilot valves Traversing incore probe system (if within Containment isolation valves the scope of 10 CFR 50.55a) 2-15 NUREG-1482

Table 2.3 Example data table for pumps PLANT NAME/ UNIT PUMP TESTING PLAN 4

i Revision: 3 Date: 1-15-92 Page: 1of3 Pump List Parameters J

V SYSTEM PUMP 1.D.

P&ID NO.

COORD 11 P.

dP

.Q (PR-1)

T.

L Residuallleat RHR-01 M-402 Sh. I D-4 (I)

Q Q

Q Q

Y Q

Removal Ril't C M-402 Sh. 2 G-4 (1)

Q Q

Q Q

Q RIIR w M-402 Sh. 2 F-5 (1)

Q Q

Q Q

Y Q

Auxiliary AFW-01 M-408 Sh.1 B-5 (1)

Q Q

Q Q

PR-4 Q

Feedwater AFW-02 M-408 Sh. I B-8 (1)

Q Q

Q Q

PR 4 Q

AFW-03 M-408 Sh.1 B-l1 Q

Q Q

Q Q

PR 4 Q

Service Water SWS-01 M-335 Sh. I F-9 (1)

PR 7 Q

PR-3 PR-2 (2)

(4)

SWS-02 M-335 Sh. 2 D-4 (1)

PR-7 Q

PR-3 PR 2 (2)

(4)

SWS-03 M-335 Sh,3 E-8 (1)

PR-7 Q

PR-3 PR-2 (2)

(4)

SWS-04 M 335 Sh. 4 C-4 (1)

PR-7 Q

PR-3 PR (2)

(4)

Standby SLC 01 M 367 Sh. I D-9 (1)

PR-7 PR-5 PR 6 Q

PR-4 (3)

Liquid SLC-02 M-367 Sh. I D-4 (1)

PR-7 PR-5 PR-6 Q

PR-4 (3)

Control Note (1): Pump is directly coupled to a constant speed synchronous or induction type driver.

Note (2): Pump bearings are located in the main flow path of the working fluid.

Note (3): Pump bearings are of the permanently sealed and lubricated design.

Note (4): The pump bearings are located in the main flow path of the working fluid and are cooled and lubricated by the process

fluid, t

Legend:

H llead T. Temperature, bearings P

Pressure, inlet L Lubrication i

dP Differential Pressure PR Pump Relief Request Q

Flow V

Vibration

' NUREG-1482 2-16

1 i

Table 2.4 Useful abbreviations for valve data tables Parameter Abbrevation Description Valve Type GT Gate valve GB Globe valve CK Check valve RV Relief valve SC Stop check BF Butterfly valve DI Diaphragm valve EX Explosive valve BA Ball valve Actuator Type MO Motor operated SO Solenoid operated AO Air operated 11 0 Hydraulic operated SA Self actuated MA Manual PA Pilot Actuated Safety Position (s)

O Open C

Closed O/C Both open and closed T

Throtded Test (s) Performed FS Full-stroke exercise valve to safety position (s)

PS Part-stroke exercise valve LT Leak-rate test valve to Section XI requirements IJ Leak-rate test valve to Appendix J requirements ST Measure the full-stroke times of the valve FT Observe the fail-safe operation of the valve i

PI Verify the valve remote position indication -

RV Safey and relief valve test EX Explocive valve test Test Frequency Q

Test performed once every 92 days CS Test performed during cold shutdowns but not -

more frequently than once every 92 days RF Test performed each reactor refueling outage 2Y Test performed once every two years RV Test relief valve at IWV or OM-1 schedule SD Disassemble, inspect, and manually exercise one valve from specified group each reactor refueling outage l

1 i

2-17 NUREG-1482

L 3 GENERAL SUPPLEMENTAL GUIDANCE ON INSERVICE TESTING -

1 i

l 3.1 Inservice Test Frequencies and impracticality be documented in the inservice Extensions testing OST) program. The licensee may.

~

implement the portions of OM-10 which allow deferral of the testing in accordance with The American Society of Mechanical Engineers 10 CFR 50.55a(f)(4)(iv) if the fo!!owmg related (MME) Boller and Pressure Vessel Code (the requimments are met:

Code) generally requires quarterly testing of pumps and valves. Subsection IWV of Section Category A and B Valres: OM-10, XI of the Code allows for deferring valve exercising to cold shutdown outage:. if exercising Paragraph 4.2.1., including a partial-l is not practical during plant operation. Part 10 stroke exercise quarterly or durmg e ld shutdown outages, if practical.

of the ASME Operations and Maintenance Standard (OM-10) has additional allowances C"##K8#1 O U## 0410, Paragraph 4.3.2., fmeluding a partial-which are discussed below. He U.S. Nuclear Regulatory Commission (NRC) staff may approve relief for extending a test interval for stroke exercise quarterly or during -

i e ld shutdown outages, if practical.

extenuating circumstances in which (1) compliance would result in hardship or unusual nemf re, although relief is not required, th.is difficult without a compensating increase in the section must be referenced in the IST program.

{

level of quality and safety or (2) the system Examples 3-1 and 3-2 depict acceptable cold design makes compliance impractical. Any shutdown justifications (CSJs), and Examples 3-requested relief would typically include a 3 and 3-4 depict refuel, g outagejustificat, ions m

technical justification for the deferment. Table acceptable m accord with OM-10.

3.1 lists the tests and test frequencies required by the Code' NRC issued guidance in letters to licensees in 1976 which included the following examples of 3.1.1 Deferring Valve Testing to Each valves that should be specifically excluded from t

Cold Shutdown or Refueling exercising (cycling) tests during plant operations:

Outage (1)

All valves whose failure in a non-Exercising valves at each cold shutdown outage conservative position during the cycling

'i is not a deviation from the Code and does not test would cause a loss of system function.

require a relief request. Testing at each Valves in this category would typically refueling outage is a deviation from requirements nelude all non-redundant valves in lines in Subsection IWV of Section XI, but is an such as a single discharge line from the allowable deferral of the testing required by refueling water storage tank or

OM-10. The Code specifies testing at cold accumulator discharge lines in pressurized-shutdowns if it is impractical to test quarterly water reactors (PWRs) and the high during operation. OM-10 specifies full-stroke pressure coolant injection (HPCI) turbine -

exercising at each refueling outage if testing is steam supply and the HPCI pump' impractical both quarterly while in operation and discharge in boiling-water reactors during cold shutdown outages. The Code GWV-(BWRs). Other valves may fall into this 3412, IWV-3522, and OM-10, paragraph 6.2) category under certain' system requires the valves for which testing is deferred he identified and the basis for determining l

l 3-1 NUREG-1482 i

l

l conngurations or plant operating modes.

complete or the plant is ready to return to For example, when one train of a power. For extended outages, testing need not redundant system such as an emergency be commenced in 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> provided all valves core cooling system (ECCS) is inoperable, required to be tested during cold shutdown will non-redundant valves in the remaining be retested before plant startup. However, the train should not be cycled since their licensee need not keep the plant in cold failure would cause a loss of total system shutdown solely to complete cold shutdown function.

testing. All valves tested during cold shutdown outages shall also be tested before startup from (2)

All valves whose failure to close during a refueling outages, unless testing has been cycling test would result in a loss of completed within the previous 92 days. For i

containment integrity. Valves in this outages that extend beyond 92 days, all cold catepry would typically include all valves shutdown testing shall be completed within the in containment penetrations where the last 92 days of the shutdown.

redundant valve is open and inoperable.

Although OM-10 does not include schedules for (3)

All valves, which when cycled, could cold shutdown testing, an acceptable method is subject a system to pressures in excess of for the valves tested in the preceding cold their design pressures. It is assumed for shutdown to be the last valves on the schedule the purpose of a cycling test that one or for the next cold shutdown. The following is a more of the upstream check valves has sample schedule for 15 cold shutdown tests:

failed unless position methods are available for determining the pressure or lack First cold shutdown: Tests 1, 2, 3, 4, 5, thereof on the high pressure side of the and 6 completed.

valve to be cycled. Valves in this category would typically include the isolation valves Second cold shutdown: Tests 7, 8, 9, and of the residual heat removal / shutdown 10 completed.

cooling system and, in some case, certain ECCS valves.

Third cold shutdown: Tests 11,12,13, 14,15,1,2, and 3 completed.

The following sections discuss issues related to valve testing deferrals.

Fourth cold shutdown: Tests 4, 5, 6, and 7 completed.

3.1.1.1 IST Cold Shutdown Testing The staff has determined that Paragraphs Subsection IWV does not include provisions for 4.2.1.2(g) and 4.3.2.2(g) of OM-10 are plant startup from cold shutdown when all IST acceptable for all licensees to implement of valves tested at a cold shutdown frequency _

pursuant to Section 50.55a (f)(4)(iv) of Title 10 has not been completed. However, OM-10 of the Code ofFederal Regulations (10 CFR allows that plant startup need not be delayed to 50.55a(f)(4)(iv)) provided the requirements of complete IST.

Paragraph 6.2 of OM-10 are also met.. If a licensee chooses to implement this guidance, this NRC Recommendation section must be explicitly referenced in the IST program.

In accordance with OM-lG, paragraphs 4.2.1.2(g) and 4.3.2.2(g), valve exercising shall commence within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of achieving cold shutdown, and continue until all testing is NUREG-1482 3-2

l Basisfor Recommendation 10 CFR 50.55a (f)(4)(iv). Therefore, relief is not required provided the licensee meets all The NRC recommendation is consistent with the requirements of these paragraphs and references provisions of OM-10 which specify the most this section in the IST program (also see Section recent requirements for IST of valves approved 3.1.1.1 above).

by NRC in 10 CFR 50.55a and may be applied to plants continuing to use the requirements in Basisfor Recommendation Subsection IWV of Section XI. The technical specifications (TS) govern the restan of the The staff has determined that the guidance of.

plant. The staff has determined that startup need this section is consistent with Paragraphs not depend on the completion of Section XI 4.2.1.2(h) and 4.3.2.2(h) of OM-10 and the TS testing because, if the licensee were required to requirements and is acceptable for meeting those complete all cold shutdown testing before provisions.

restarting the plant, it may have the unneeded burden of extending cold shutdown outages 3.1.1.3 De-inerting Containment of Boiling solely to complete surveillance testing.

Water Reactors to Allow Cold Shutdown Testing 3.1.1.2 Testing at a Refueling Outage Frequency for Valves Tested According, to 10 CFR 50.44, " Standards for During Power Ascension Combustible Gas Control System in Light-s Water-Cooled Power Reactors," each boiling Before beginning power ascension, the licensee water reactor equipped with a Mark I or Mark 11 normally completes the tests of those valves containment must have provisions for an inerted tested at each refueling outage. However, to test containment atmosphere during power operation any valves that can only be tested during power to protect against a burn or explosion of ascension, the licensee may begin raising the hydrogen gas generated by the core metal-water power level and changing modes in accordance reaction after a loss-of-coolant accident (LOCA).

with TS requirements and test the applicable valves when plant conditions allow testing. If Oxygen content in the containment atmosphere is maintenance has been performed on a valve monitored during normal power operation.

during the outage, the licensee is required to Technical specifications specify the maximum consider the valve inoperable until completing oxygen concentrations allowed. Since hydrogen i

post-maintenance testing in accord with the generation is not a concern during cold shutdown operability requirements in the TS.

or refueling outages, the technical specifications allow the containment atmosphere to be de-NRC Recommendation inerted. However, licensees do not routinely de-inert the containment during cold shutdown OM-10 requires that all valve testing schedules outages because of the impracticality of the time for performance during a refueling outage shall needed to de-inert and re-inert and because the be completed before returning the plant to nitrogen used for inerting is lost.

operation, except for valves which must be tested during power ascension for which OM-10 and Section XI of the Code allow the.

technical specification requirements for the licensee to test certain valves located in the valves or the system determine when the valves inerted wntainment during cold shutdown.

are required to be operable. The NRC has outages because it is not practical to test them determined that paragraphs 4.2.1.2(h) and during power operation. Ilowever, access to the 4.3.2.2(h) of OM-10 are acceptable for all licensees to implement pursuant to 3-3 NUREG-1482 -

valve may be required to perform the testing.

enter a de-inerted containment to manipulate The staff has determined that de-inerting the valves, solely to perform tests. Because the test containment at each cold shutdown outage solely interval is allowed to be extended to refueling to perform this testing is impractical.

outages for valves which cannot be tested during power operations or cold shutdowns, it is NRC Recommendation similarly acceptable to extend the test interval for those valves which cannot be tested unless Valves may be tested during refueling outages if the containment is de-inerted.

they would otherwise be tested during cold shutdown outages that require the containment to 3.1.1.4 Stopping Reactor Coolant Pumps l

be de-inerted for performance of this testing.

for Cold Shutdown Valve Testing He NRC staff does not consider that containment de-inerting solely for the purpose of Licensees frequently schedule to test during cold valve testing is warranted and approves the test shutdown outages the valves in support systems deferral pursuant to 10 CFR 50.55a (f)(4)(iv) that perform a function vital to the continued provided the licensee meets all requirements of operability of the reactor coolant pumps, such as Paragraphs 4.2.1, 4.3.2, and 6.2 of OM-10 and component cooling and the supply and return of describes this section in the IST program (also seal water. Exercising these valves when the see Section 3.1.1.1 above).

pumps are operating could result in pump damage. Stopping the reactor coolant pumps Basisfor Recommendation could extend the cold shutdo.vn period and would be burdensome to the licensee.

Unless the licensee would need to enter the drywell for other reasons, de-inerting the NRC Recommendation drywell during cold shutdown outages to perform testing is impractical because of the Reactor coolant pumps need not be stopped for l

time and effort needed to de-inert, re-inert, and cold shutdown valve testing. The staff l

replace lost nitrogen gas which could delay the recommends affected valves be tested during return to power operation. Most plants with plant outages when reactor coolant pumps are custom TS must reduce the primary containment stopped for a sufficient period of time and on a oxygen content to less than 4 percent within 24 refueling outage schedule, but not more often hours of placing the reactor mode switch in the than once every 92 days. OM-10 allows the test run position. If proper oxygen concentration interval to be extended to refueling outages when cannot be established for any reason, the plant is the tests cannot be practically performed during required to return to the startup mode. Plants power operation or cold shutdown outages. The using the standard technical specifications are staff has determined it is acceptable to also restricted in that the proper oxygen level implement this portion of OM-10 pursuant to l

must be established within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of exceeding 10 CFR 50.55a (f)(4)(iv) as discussed in Section 15-percent thermal power or the plant must enter 3.1.1.1 above. The licensee must reference this an action statement. In either case, the return to section in the IST program.

power can be greatly delayed, which results in lost power generation.

Basisfor Recommendation l

l OM-10 allows for valve testing during refueling The NRC determined that the licensee need not 1

outages if such testing is impractical at quarterly stop and restart reactor coolant pumps at each intervals or during cold shutdown outages. The cold shutdown solely to allow for the testing of applicable BWR licensees would face hardship if certain valves. His requirement would increase required to de-inert, or to require individuals to the wear and stress on pumps, increase the 1

l NUREG-1482 3-4

I number of cycles of plant equipment, and extend it is not intended that the shutdown length of cold shutdown outages. The licensee ACTION requirements be used as an may consider establishing a schedule to account operational convenience which for extended cold shutdown outages which would permits (routine) voluntary removal allow for valve testing when the reactor coolant of a system (s) or component (s) from

)

pumps are stopped for a sufficient length of service in lieu of other alternatives l

time. Valves are to be tested at least each that would not result in redundant refueling outage.

systems or components being

{

inoperable. The specified time limits i

3.1.2 Entry into a Limiting Condition of the ACTION requirements are for Operation to Perform applicable from the point in time it is Testing identified that a Limiting Condition f

for Operation is not met. The time Unless accompanied by other acceptable limits of the ACTION requirements j

rationale, a required entry into a limiting are also applicable when a system or i

condition for operation (LCO) to perform IST component is removed from service would not justify deferring testing until a cold for surveillance testing or shutdown or refueling outage. Guidance on investigation of operation !

three issues regarding the applicability of LCO problems. Individual specifications and surveillance requirements was issued by the may include a specified time limit NRC in Generic Letter (GL) 87-09, " Sections for the completion of a Surveillance 3.0 and 4.0 of the Standard Technical Requirement when equipment is Specifications on the Applicability of Limiting removed from service. In this case, Conditions for Operation and Surveillance the allowable outage time limits of Requirements," as follows:

the ACTION requirements are applicable when this limit expires if (1) unnecessary restrictions on mode changes the surveillance has not been by TS 3.0.4 and inconsistent application of completed.

exceptions to it; In GL 87-09, the NRC stated its position that the (2) unnecessary shutdowns caused by TS 4.0.3 structure of the referenced TS accounts for entry when surveillance intervals are into an LCO to perform surveillance testing. If inadvertently exceeded; and the time allowed for equipment to be out of service is not sufficient to perform a surveillance (3) two possible conflicts with TS 4.0.3 and test, a TS change should be requested to allow 4.0.4:

additional out-of-service time to allow for surveillance if safety is not compromised by the (a)

Surveillance requirements that increased out-of-service time. The NRC issued become applicable due to guidance on the entry into LCO as documented action requirements.

in NRC Inspection Manual Part 9900,

" Technical Guidance - Maintenance - Voluntary (b) Surveillance requirements to Entry into Limiting Conditions for Operation TS 4.0.4.

Action Statements to Perform Preventive Maintenance."

The enclosures to GL 87-09 include the bases for TS 3.0.1 - 3.0.4 which discuss entry into When the licensee removes a train from service LCO, stating that to perform surveillance testing, technical specifications typically require that the other l

l 3-5 NUREG-1482 l

t

train is operable. The probability of a design RWST instead of into the reactor basis accident occurring during the short period coolant system (RCS) until the of time a train is out of service is considered manual valve could be closed. Full-low, while the assurance of component stroke exercising is not feasible operational readiness through surveillance testing during cold shutdown outages provides an increased level of safety. However, because the RHR system is in RCS IST which results in a system being completely recirculation and isolated from the removed from service may not be acceptable for RWST.

safety. Entry into multiple LCO is to be avoided (although the safety analysis may not NRC Evaluation prohibit certain situations and plant configurations).

A full flow test of the valves would require the RHR pumps to inject If a system or subsystem is designed to realign water into the RCS or back to the automatically during testing and, therefore, is RWST. During power operation, not considered out of service, the licensee need pressure from the RHR pump is not enter an LCO. The NRC has approved inadequate to inject into the RCS.

relief requests for situations which would have The licensee stated that pumping required operators to manually manipulate one back to the RWST would place the i

or more valves to restore a system to an RHR system in technical operable status if the system function became specification 3.0.3. which, alone, i

required during IST. An example of such a does not justify deferring the full-situation is as follows:

stroke exercise. However, if the RHR system was aligned to pump Licensee's Requested Relief back to the RWST, it would be unavailable to inject into all four The licensee requested relief from RCS cold legs during an accident full-stroke exercising valve 8958, the until an 8-inch [20.32-cm] valve was check valve for the suction header manually closed to restore flow to for the pump from the reactor water the RCS. The 8-inch [20.32-cm) storage tank (RWST) to the residual manual valve is normally closed and heat removal system (RHR),

is opened only to drain the refueling quarterly or during cold shutdown cavity to the RWST following j

outages. The licensee proposed to refueling. In Information Notice 87-part-stroke exercise the valve 01, "RHR Valve Misalignment quarterly daring pump IST and to Causes Degradation of ECCS in :

full-stroke exercise f " valve during PWRs," the NRC discussed RHR refueling outages. ' a f ull-stroke test configurations which put the exercise this valve 4mg power plant outside the licensing basis operation, the licensee would need to analyses in which all four RCS cold align the RHR system to take suction legs are assumed to be supplied from the RWST and recirculate the water from at least one RHR pump.

water back to the RWST through a manual, normally closed valve. This Therefore, if the licensee chooses the deferral of test lineup would necessitate entering testing from quarterly to cold shutdown, or to technical specification 3.0.3 (for this refueling outages, other justification must be plant). In the event of an accident, included in addition to entry into an LCO. If RHR flow would be diverted to the the deferral is not justified by additional basis, NUREG-1482 3-6

l the licensee must perform tests quarterly with at approximately the same time within each entry into the LCO for IST to be completed quarter. For example, if a test procedure applies within the out-of-service time allowed by TS.

for many valves and thus requires 2 to 3 weeks or more to complete, the licensee would NRC Recommendation typically begin the procedure at approximately the same time in each quarter and include No new guidance or recommendations are directions to perform tests in a specified order to contained in this section. This section discusses ensure that specific valves are tested "at least previously issued guidance and experience.

once per 92 days."

3.1.3 Scheduling of Inservice Tests Each applicable test is required by TS to be i

performed within the specified time interval with Most TS define the test frequencies and intervals a maximum allowable extension not to exceed 25 specified for IST activities in Section XI of the percent of the test interval. However, the ASME Code. Any changes to this test licensee would not extend the test intervals for frequency, such as testing a specific pump every safety and relief valves tested in accordance with 184 days (biannually), would require a technical intervals defined in OM-1 and Paragraphs IWV-specification change and a relief request to 3510 - IWV-3514 and Table IWV-3510-1 of extend the test interval, unless otherwise allowed Section XI, other than to coincide with a by the Code.

refueling outage. If the conjunction and is used in specifying test frequencies such as "once ASME Boiler and Pressure Required frequencies every refueling outage and following i

Vessel Code terminology for for inservice modifications or maintenance," the test is to be inservice testine activities testine activities performed at both specified frequencies. The test is to be performed at either frequency for a At least once per:

schedule such as "once every refueling outage or Monthly 31 days once every 2 years." A 25-percent extension Quarterly or every 3 months 92 days may be applied to the 2 years unless the TS or f,(annuany relief request stipulate "whichever is more e e g outage Two years 24 mouths conservative," or another statement to th,s effect.

i The Code requires performing the tests NRC Recommendation throughout extended shutdown periods for operable equipment. Most equipment must be To remove the ambiguity of the periods as stated tested before being placed into service after

]

in the Code, the staff recommends that the being out of service for an extended period in iicensee use these test frequency definitions even accordance with TS requirements (if applicable).

if the frequencies are not included in TS. For Code requirements (IWV-3416/OM-10, example, paragraph IWV-3411 in Section XI Paragraph 4.2.1.7, and IWP-3400(a)/OM-6, requires Category A and B valves to be Paragraph 5.4) provide that testing be performed

" exercised at least once every 3 months." This after returning an out-of-service component to requirement can be met by testing at the service if the component was not out of service beginning of a 3-month period and the end of the to be repaired or replaced.

next 3-month period; however, the intent is that the actual time between tests be approxir':4tely equal. For quarterly testing, the staff recommends the pump and valve tests be scheduled such that a particular test is performed 3-7 NUREG-1482

Basisfor Recommendation 3523 of Section XI stipulate that corrective action is to be implemented immediately for This recommendation is based on the standard valves, and if the condition is not corrected technical specifications which have been within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the valve shall be declared developed, reviewed, and approved by the NRC inoperative. The NRC issued guidance in the j

staff. These intervals and extensions apply bases for TS 4.0.5 and in GL 87-09, " Sections directly to IST which is a technical specification 3.0 and 4.0 of the Standard Technical surveillance requirement for certain pumps and Specifications on the Applicability of Limiting valves. In interpretation XI-78-01 for Section Conditions for Operation and Surveillance XI, the ASME Code Committee clarified the Requirements." The NRC stated in the " Bases" intent of the "2-year" frequency specified in for TS 4.0.5:

IWV-3300 for position indication verification and IWV-3420 for leak rate testing stating that Under the terms of this specification, the intent of the Code test and examination the more restrictive requirements of frequency be related to periods of time rather the Technical Specifications take than refueling outages. Refueling outages are precedence over the ASME Boiler referenced to preclude the necessity to shut down and Pressure Vessel Code and the plant for Section XI intent only. The applicable Addenda.... The requirement of the Code for Paragraph IWV-Technical Specification definition of 3300 is that the valve position indicator test may OPERABLE does not allow a grace be done each one to two years without regard to period before a component, that is the frequency of refueling outages. The not capable of performing its requirement for Paragraph IWV-3420 is that the specified function, is declared valve leak rate test may be done each 1 to 2 inoperable and takes precedence over years without regard to the frequency of the ASME Boiler and Pressure refueling outages.

Vessel Code provision which allows a valve to be incapable or The NRC recommendation for extended performing its specified function for shutdown periods is consistent with TS and Code up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> beft te being declared requirements, whichever are more restrictive.

inoperable.

Responding to inquiry IN92-025A, the ASME Code Committee stated that it is the intent of In Position 8 of GL 89-04, the NRC stated that a Paragraphs IWV-3410 and IWV-3520 of Section pump or valve which exhibits performance in a XI to require testing of valves every 3 months, required action range must be declared including during extended shutdown periods, for inoperable and the TS action period started as valves other than those declared inoperable in soon as the data is recognized as being in the accord with Paragraph IWV-3416.

required action range (or a valve exceeds a r

limiting stroke time or fails to exhibit the 3.2 Start of the Time Period in required change of disk position). Pumps and j-Technical Specification valves e vered by Section XI are frequently in -

"Y'**** **ered by TS. Upon dedaring a ACTION Statements component.moperable, the licensee may be required to place the plant in an action Section XI, IWP-3220, " Time Allowed for statement, which generally allows a specific time Analysis of Tests," states that all test data shall period for continued operation. If the equipment be analyzed within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> after the completion remains inoperable after the time period, the of a test. If the deviations fall within the licensee may be required to take action such as required action range, the pump is to be declared to begin a plant shutdown.

inoperative. Paragraphs IWV-3417 and IWV-l NUREG-1482 3-8 i

l 1

l l

NRC Recommendation component would be taken. The licensee's analysis would typically address the condition of The staff recommends that test procedures the pump and not be based solely on a system include test parameter reference values and condition, with a determination of the co se of acceptance criteria to enable the licensee to the degrading condition to ensure that reandant quickly determine the condition of a component.

components would not be degraded by the we i

Using this information would allow those cause. To complete an engineering analysis, ne responsible for conducting the test to_both licensee would not typically exceed the time determine whether the data meet requirements allowed in a limiting condition for operatbn.

and ensure the pump or valve is operable. The staff recommends that the determination, at a Basisfor Recommendation

]

minimum, be made by the same duty shift that performed the test unless the test results are not The limits established for IST are based on Code available before the end of the shift, in which requirements or the limits in either the TS or the case the on-coming duty shift may have to make safety analysis, whichever are more the determination.

conservative. The plant safety analysis lists values considered in analyzing various scenarios After declaring a component inoperable and and includes a minimum requirement of determining that an engineering analysis of the performance for a component to meet the most condition is appropriate to determine if the limiting conditions under which it may be component can be returned to service, the required to operate.

analysis would, typically, be performed within the allowable time of the TS action statement. If For example, a pump may have three times the particular engineering expenise is necessary, a capacity required to meet the maximum analyzed preliminary analysis may be acceptable for capacity for accident conditions. The reference declaring the pump or valve operable and exiting values for the pump and the Code-required the action state,ient, with a more detailed action limits may be much higher than the analysis to follow. The preliminary analysis required capacity of the pump since the Code l

would typically contain sufficient basis on which limits are not based on system requirements (see i

to determine that a component is operable in the Section 5.6.2 below). However, in exceeding degraded condition, with the component placed the Code limits, the pump exhibits degraded on an increased test frequency as specified in the performance and may soon fail. NOTE: If the Code, if applicable. In performing the analysis, testing indicates that instruments are erratic, the the licensee would also typically determine that test may be discontinued and the instruments the redundant train or trains are operable to recalibrated without declaring the pump j

perform the safety function of the affected inoperable (see IWP-3230(d), paragraph 6.1 of equipment in case this equipment is later OM-6, and Question 46 of the minutes to GL determined by more detailed analysis to have not 89-04 meetings).

been capable of performing its safety function.

' The operability of a redundant train may be Upon finding the pump to be inoperable, determined based on its last surveillance and the technical specifications (if applicable) would maintenance condition of the system. Testing require the licensee to declare it inoperable while may be appropriate, but cannot be performed if.

reviewing the test results and making all trains of the system would be inoperable comparisons to previous test results to ensure during testing. The more detailed analysis that a condition has not developed that will -

would follow in a timely manner. Upon further degrade the pump until exceeding the completion of the detailed analysis, appropriate safety analysis limits. If the licensee finds that actions relative to the operability of the the pump is not in danger of further degradation -

3-9 NUREG-1482

i over an acceptable period of time, the licensee's 3.3120-Month Updates Required analysis may be an acceptable alternative to the by 10 CFR 50.55a(f)(4)(ii) repair or replacement of the pump for that period until such time that repairs can be After the initial 120-month interval, the licensee i

effected, as allowed by the Code. However,.f must, in accord with the regulation, conduct i

the licensee determmes that the condit, ion wil!

inservice tests during successive 120-month so(m result m further degradation, the analysis intervals to verify operational readiness of may indicate that immediate action is required t pumps and valves, whose function is required

[

repair or replace the pump, for safety. In conducting these inservice tests, the licensee must comply with the requirements If particular expertise is needed but not readily of the latest edition and addenda of the Code available, this NRC recommendation allows the incorporated by reference in 10 CFR 50.55a(b) licensee to avoid an unnecessary plant shutdown 12 months before the start of the 120-month by scheduling a preliminary engineering analysis interval, subject to the limitations and to be performed by an engineer on shift, such as modifications listed in paragraph (b). Paragraph the shift techmcal advisor or shift engmeer.

(f)(5)(iv) specifies that the licensee list the Code requirements found to be impractical for the new The preh.mmary analys.is performed by the interval such that "the basis for this licensee establishes a basis for justifymg the determination.. be demonstrated to the equipment is capable of meetmg safety analys.is satisfaction of the Commission not later than 12 limits, even though degraded from previous months" from the start of the interval, tests, and would assess the condition of the t

redundant train of the system, if applicable.

3.3.1 Extension of Interval With a more detailed engineering analysis completed in a timely manner, the period the If an extended outage hinders a licensee from component could be considered operable based on the preliminary analysis is limited in the comply.ing wndi k inseme mspect.

ion requirements for items such as piping welds, event the component is later determined to be vessel welds. or pressure testmg, it may request incapable of continued operability. The period to extend the,nterval in accordance with IWA-i for performing a more detailed analysis will 2400(c) (1983 edition; the reference paragraph allow adequate time to review all information for may vary am ng editions), which states:

j a thorough engineering analysis, assuming the licensee will begin the action without delay.

Each. inspect. ion mterval may be Such action is also consistent with the decreased or extended (but not philosophy that even a complete engineering cumulatively) by as much as one analysis, if performed immediately after

year, r p wer un s that are out declaring a pump or valve inoperable, will be f seivice continuously for 6 months further reviewed by plant managers and safety or m re, the inspection mterval review committees to find any results that during which the outage occurred contradict analysis and testing. This may be extended for a period recommendation is more conservative than Code equivalent to k outage.

requirements, in some respects, but is consistent l

with TS requirements.

The licensee will typ.ically also request to extend the interval for IST to maintain the programs on -

L the same interval for inspection and testing.

i NUREG-1482 3-10

NRC Recommendation regulations do not specifically allow conentrent intervals, when the interval start dates are to be l

Wher the date for the new interval is concurrent, the licensee may request a one-time ertabbshed, the next updated yogram is required alternative to or exemption from to be established to the laten edition of the Code 10 CFR 50.55a. If the licensee prefers not to incorporated in the regulation 12 months before equest an alternative or exemption, the j

the new date. For example, if a licensee has an es ablishment of concurrent intervals would l

extension from December 14,1994, to require that program updates be performed more September 16, 1995, in accordance with the often than once every 120 months. Paragraph Code, the licensee's program for the new 50.55a (f)(4)(iv) allows that IST of pumps and interval must meet the edition of the Code valves may meet the requirements in subsequent incorporated in 10 CFR 50.55a(b) as of editions of codes and addenda or portions thereof September 16, 1994. The staff recommends the which are incorporated by reference in licensee inform the NRC before the date that 10 CFR 50.55a(b), subject to the limitations and would have been the end of the current i.,tervai.

modifmations listed, and subject to Commission Any extension beyond 1 year requires approvo' approval. This regulation allows a licensee to of an alternative to or exemption from update programs before the end of a 120-month 10 CFR 50.55a.

interval.

Basisfor Recommendation NRC Recommendation Subsection IWA of Section XI applies to both if a licensee elects to use the same Code edition IST and inservice inspections. While it is not for multiple units, the staff recommends that an mandatory to maintain identical intervals for alternative to or exemption from the regulation inservice inspections and IST, it is often be requested to place the multiple units on a desirable for maintaining the same edition of the concurrent interval for IST. To establish Code for all plant activities related to Section concurrent intervals without an alternative or i

XI. Even though 10 CFR 50.55a des not exemption, the licensee must update the discuss extending the intervals, the Code is referenced edition of the Code more frequently incorporated by reference in the regulation, and to remain in compliance with Section 50.55a, therefore, has the same effect as the regulation.

except in the case where the interval dates are Although the Code does not require NRC within 12 months, whereby the Code allowance i

approval for' l-year extensions of the interval, for an extension would result in concurrent the licensee would avoid any discrepancies in the intervals. If the licensee elects to use paragraph interval dates by informing the NRC of the (f)(4)(iv) to update to later editions of the Code, extension and documenting it in the IST this section gives the requisite approval for the program. Because the Code does not allow IST program, but not for inservice inspection, if extension beyond one year, other than for the following guidelines are used, and further extended outages, such an extension would approval is not required:

require an exemption in order to comply with the regulatory requirements.

Without obtaining an alternative or exemption, the licensee may perform the 3.3.2 Concurrc Intervals IST program for multiple units using the same edition of the Code at concurrent-Several licensees have established concurrent intervals if the initial interval for intervals for all units at sites with multiple units combining the programs is established such so that each unit is updated to a newer edition of that no single unit is tested at an interval the Code at the same starting date. Because the of over 120 months (or no greater than the 1

1 3-11 NUREG-1482

interval extension allowed by Code).

Basisfor Recommendation Thus, the licensee must use the interval for the first unit that was licensed for By obtaining an alternative or an exemption, a commercial operation to establish the licensee may test multiple units at the same interval dates and establish the correct interval, which is less confusing than performing Code edition according to the most recent more frequent program updates. However, the required for either unit.

licensee may choose ta update without requesting an alternative or exemptica, perhaps to e

To exceed 120 months, other than as periodically maintain an IST program with a addressed in the Code for an extension, the more current edition of the Code, licensee must first obtain approval of an alternative to or an exemption from Tae regulations allow for concurrent intervals 10 CFR 50.55a; therefore, establishing among multiple units if the program is updated two units on the same interval requires an each time an interval for either unit is due. The alternative or exemption unless the licensee preferred manner for establishing concurrent intends to repeatedly upda'e both units intervals is to consider each unit on the same more often than the required 120 months.

120-month period with updates occurring at the That is, the licensee will test each unit end of the 120 months through an alternative or according to the most recent edition of the exemption. While the example presented is Code required for either unit, acceptable to 7;T programs in which test frequencies for compenents other than safety and relief valves do not ex eed 18 to 24 months, this Example of current IST intervals which do not arrangement may not be acceptable for inservice require an alternative to or exemption from inspection intervals for schedules of 3-1/3-year 10 CFR 50.55a and 10-year examinations. The staff might change this recommendation if future changes to Unit 1 Commercial Operation Date 12/19/74 the regulation or the Code do not allow for the Unit 2 Commercial Operation Date 03/26/80 extension of IST intervals.

First Interval:

Unit 1 - 12/19/74 to 12/18/84 3.3.3 Implementation of Updated Unit 2 - 03/26/80* to 12/18/84 Programs Second Interval: Unit 1 - 12/19/84* to 03/25/90 Updating the IST program to a revised edition -

Unit 2 - 12/19/84* to 03/25/90 and addenda of the Code is an extensive effort that involves changes to administrative and Third Interval:

Unit 1 - 03/26/90* to 12/18/94 implementing procedures. Often, the revised Unit 2 - 03/26/90* to 12/18/94 requirements will necessitate establishing new

• Program updates required for both units, reference valt,es, such as by implementing a vibration program using velocity measurements The request for the alternative or exemption and rather than displacement measurements, or by the IST program document would typical!y establishing stroke-time reference values for describe the method for selecting the intervai power-operated valves.

dates, specifying the dates at which it will beg.n j

and end, and comparing the effect of these dates NRC Recommendation l

with that of the dates required otherwiss.

The staff recommends that, before beginning the first tests during the new interval, the implementing procedures be revised according to NUREG-1482 3-12

the appropriate requirements. When the testing dates of the intervals or the Code edition in use.

requires baseline values to be reestablished to At more than one plant, the individuals I

meet Code changes, this would typically involve responsible for the IST programs were not aware l

the new baseline (reference) values being that the Code offederal Regulations is updated established during the first quarterly or cold throughout the year. Therefore, when they shutdown outage test performed in the new revised their programs, they used the bound l

interval, if not before. Before performing tests version of 10 CFR Part 50 to determine the during the first refueling outage, the licensee Code edition cited in paragraph 50.55a(b) 12 would typically revise implementing procedures months before the interval start date. However, for the tests to be performed during that outage a more recent edition had been incorporated by to incorporate any new requirements or new reference in paragraph 50.55a(b), which resulted components.

in the program being developed to an incorrect edition of the Code.

All tests required to be performed during the refueling outage must be completed before or NRC Recommendation during startup from the refueling outage, as required by the Code (OM-10, paragraphs ne staff recommends that the interval dates and 4.2.1.2(h) end 4.3.2.2(h)). If the licensee Code edition be included in each IST submittal, det(rmines that a tiQ implementation is not whether it is for an entire program or only a possible, the staff recommends that a schedule partial submittal containing new or revised relief be submitted to NRC before the beginning of the requests. The staff must ensure that the interval interval, or if the interval begins while a plant is dates are correct and that the evaluation is shut down for refueling, before she startup from performed using the edition of the Code from the refueling outage, which reliefis requested. The staff recommends that the individuals responsible for developing Therefore, the staff recommends that the relief and maintaining the IST program be aware of requests be submitted to the NRC before the new the regulatory changes made in 10 CFR 50.55a interval begins, and in any case, by the end of throughout the year and review any new or 12 months following the new interval start date revised requirements for any effect on the IST per 10 CFR 50.55a(f)(5)(iv).

program.

Basisfor Recommendation Basisfor Recommendation In updating the IST program to a revised edition The NRC has noted incorrect interval dates and and addenda of the Code, the staff recognizes Code editions cited in submittals for IST that changes might be completed over a period programs. The Code stipulates that the licensee of time to allow for adequate review and shall calculate the inspection interval according approval and recommends completion of the to the number of calendar years that have passed procedural revisions in a timely manner. The since the power unit was placed into commercial regulations do not allow that a licensee continue service. The NRC lists, for information, the with a previous program until the NRC has licensing and commercial operation dates for

. reviewed the relief requests for the next interval, nuclear power plants in the annual "NRC Information Digest" (NUREG 1350). The 3.3.4 General Comments on Inservice licensees for several plants established the initial Testing Intervals interval as beginning on the date of their operating licenses, or some other unspecified He NRC has received requests for IST milestone. However, if the NRC revised programs and partial submittals that lack the 10 CFR 50.55a after the date cited by the 3-13 NUREG-1482

licensee and before the date of the operating Waste-Containing Components of Nuclear Power license, and if this revision incorporated a later Plants," the NRC gives guidance on classifying edition of the Code, the regulations may have components for quality group A (Code Class 1),

required use of a more recent edition than was B (Code Class 2), C (Code Class 3), and D actually used.

(ASME Code Section VIII; Amer,can National i

Standards Institute (ANSI) B31.1). When many 3.4 Skid-Mounted Components and of the components were procured, the Component Subassemblies requirements for IST did not apply and thus the i

components may not have included features for IST. If the NRC specifies that these individual j

The Code class of piping systems at a plant may c mponents be included in the scope of not include skid-mounted components or 10 CFR 50.55a, it would need to complete a j

component subassemblies such as valves in backfit analysis to justify imposing additional diesel air-start subassemblies, diesel skid-testing requirements beyond the current testmg mounted fuel oil pump (s) and valves, steam requirements. The OM Committee, includmg admission and trip throttle valves for high the OM-16 Working Group for diesels, is pressure coolant injection or auxiliary feedwater considering clarifymg whether skid-mounted pump turbine drivers, steam traps, and air c mp nents are within the defined scope of the supply system check valves and solenoid-OM codes and standards, or if add,tional i

operated valves for main steam isolation valves.

guidance on testing these components is needed.

Licensees may elect to use the IST program for NRC Recommendation testing these components, or may state in the test pmcedures for the major components that the Until the scope of components for 10 CFR, surveillance tests of these components melude a Section 50.55a, is expanded to include all safety-test of the skid-mounted components.

related pumps and valves, and until the OM codes and standards specifically address skid-NOTE: It is not required that die NRC evaluate mounted components, the staff has determined relief requests for components outside the scope that the testing of the major component is an f 10 CFR 50.55a. For further information in acceptable means for verifying the operational this area, refer to staff response to Question 53 readiness of the skid-mounted and component of the public meetings on GL 89-04. He NRC subassemblies. Dese components may be listed discussed its position for testing components separately in the IST program, if desired, noting outside the scope of 10 CFR 50.55a (see that they are not in the required scope of Appendix A).

10 CFR 50.55a. Appendices A and B to 10 CFR Part 50 may require,'for some plants, 3.5 Test.mg m the As-Found testing of certain of these components, and the IST program is an acceptable program for Condition safety-related pumps and valves o'.itside the Code class botmdaries.

The Code does not specifically require testing to be performed for components in the as-found Basisfor Recommendation condition except for safety and relief valves.

Appendix 1 to 10 CFR Part 50 requires.

Various pumps and valves procured as part of containment isolation valve leakage be measured larger component subassemblies are often not with the valve in the as-found condition.

subject to the requirements for components in Measurement of the initial lift of safety relief ASME code classes 1,2, and 3, In Regulatory valves is required, to determine if additional Guide 1.26, " Quality Group Classifications and valves are to be tested, by IWV-3513, Standards for Water, Steam, and Radioactive-NUREG-1482 3-14

I paragraphs 1.3.3.1.4/5 and 1.3.4.1.4/5 of OM-Basisfor Recommendation i

1-1981, or paragraphs 1.3.3.l(d/e) and 1.3.4.l(d/e) of OM-1-1987. OM-1-1981 and When testing is not performed with the OM-1-1987 specify that periodic testing of all component in the as-found condition, pressure relief devices is required and that no information important in identifying degradation maintenance, adjustment, disassembly, or other mechanisms may be missed. Test data obtained activity which could affect the as-found set from as-found testing more accurately indicates -

pressure or seat tightness data is permitted the condition of the component and can be before testing.

evaluated for trends to better predict when a component may not function as required.

i NRC Recommendation The staff recommends that IST be performed with the components in the as-found condition where practical, j

i

?

NUREG-1482 3-15

1 Table 3.1 Required tests and test frequencies for pumps and valves l

Test ~

Frequency :-

l Measure pump parameters Once every 3 months j

'l Except for Pumps in regular use Pumps in systems out of service Pumps lacking required fluid inventory i

Exercise Category A and B valves Once every 3 months I

Except for:

Extension because of impracticality Valves in regular use Valves in systems out of service Measure stroke times of power-operated Once every 3 months Category A and B valves Expect for-Extension because of impracticality Valves in regular use Valves in systems out of service Verify remote position indication Once every 2 years Observe operation of fail-safe actuators for Once every 3 months applicable valves Leak-test Category A and A/C valves Once every 2 years

]

Test safety and relief valves Test interval specified by Table IWV-3510-1 or as specified by OM-1. The schedule is based on either a 5-year or 10-year frequency.

Exeretse check valves Once every 3 months Except for:

Extension because of impracticality Valves in regular use Valves in systems out of service Test explosively-actuated valves 20 percent tested once every 2 years. Charges shall not be older than 10 years.

NUREG-1482 3-16

Example 3.1 Cold shutdown justification CSJ-4 i

Aeolicable Valm CV-00112C l

System:

Chemical Volume and Control System l-Function: Volume Control Tank Outlet Valve Basis for Deferrine Testing; Closing this valve while operating a charging pump would isolate the volume control tank from the charging pump suction header, damaging any operating charging pumps and interrupting the flow of charging water flow to the reactor coolant system. This action could result in a reactor coolant system transient and a plant trip.

Example 3.2 Cold shutdown justification RBC-1 SYSTEM: REACTOR BUILDING CLOSED LOOP COOLING COMPONENTS:

15RBC-24A,B CATEGORY: AC 15RBC-26A,B CATEGORY: A SAFETY FUNCTION: These valves close for containment isolation.

JUSTIFICATION: Exercising these valves will interrupt the flow of cooling water to'one of the two operating cooling water trains for the containment vessel (drywell). Since the 3

drywell cooling system has a limited capacity, this interruption during normal operating conditions could significantly increase the temperature in the drywell which could result in a-plant trip on "high containment pressure."

NUREG-1482 3-17

Example 3.3 Refueling outagejustification SYSTEM:

Safety Injection VALVE: SI-8958 Code Class:

2 CATEGORY: C P&ID: M-65, D-7 FUNCTION: This check valve opens to supply water from the refueling water storage tank (RWST) to the suction for the residual heat removal (RHR) pumps.

BASIS FOR DEFERRAL OF TESTING TO REFUELING OUTAGES: This check valve cannot be full-stroke exercised open during unit operation because the shutoff head of the pumps is lower than the reactor coolant system pressure.

The valve cannot be partially stroked during normal operation when testing the RHR pumps on mini-flow recirculation. Alternative flow paths were investigated and evaluated. The 8-inch [20.32-cm] recirculation line to the RWST with the RHR return valve, SI-8735, is not a prudent method to partially-stroke exercise this valve quarterly or during cold shutdowns.

The following are the reasons for this determination:

1.

This is the only valve in the line that isolates the RHR system from the RWST. Failure of this valve (single failure) to close would render the RHR system inoperable and not able to fulfillits design basis function during an accident.

2.

Operators would not have sufficient time to close this valve would within 25 to 27 seconds because of its large size.

i l

• I NUREG-1482 3-18

Example 3.4 Refueling outage justification ROJ/SI-4 1

l-Yaly_en SI-8815, SI-8900A, B, C, D, SI-8969A

(

High Head Safety Injection Flowpath Check Valves l

SI-8819A, B, C, D, SI-8905A, B, C, D l

SI-8922 A &B, SI-8926, SI-8949A&D and SI-8969B Intermediate Head Safety injection Flowpath Check Valves i

Reason for ROJ:

These valves are full-stroke exercised at refueling outages. These valves cannot be fully or partially opened during plant operation or during cold shutdown outages because the flowpaths discharge into the reactor coolant system (RCS).

Justification:

The valves for the high head subsystem cannot be full-etroke exercised during plant operation because the high RCS pressure will prevent the maximum required injection flow rate. Part-stroke exercising during plant operation is not practicable because any flow through the valves results in unnecessary thermal transients on the RCS cold leg nozzles for which they are not designed and impcces hydraulic transients on the charging system and on the reactor coolant pump seals which can cause them to cock. The check valves in the high head injection path cannot be full-stroke exercised at cold Ouowns because the high flow rates could challenge the RCS cold overpressure mitigation system and wou'd impose hydraulic transients on the charging system and on the reactor coolant pump seals which can cause them to cock. Part-stroke exercising at cold shutdowns is not practicable because the high head injection flowpath is not designed for throttled operation.

The valves in the intermediate head subsystem cannot be fully or partially exercised during plant operation because the high pressure of the RCS will not allow flow forward through these paths. (An exception to this is valve 8926 which is in the mini-flow path of the safety injection (SI) pumps and thus is part-stroke exercised open during quarterly pump tests.) Using the Si test header to part stroke exercise certain check valves during plant operation is not practicable because this path yields flow rates too small (approx. 5 gpm [0.315 IJsec]) for assessing the operational readiness of these valves. The check valves in the intermediate head injection paths cannot be full-stroke exercised at cold shutdown outages because the high flow rates could challenge the RCS cold overpressure mitigation system. Part-stroke exercising these valves during cold shuMown outages is not practicable because the flowpaths are not designed for throttled operation.

Test Frecuenen The subject check valves are full-stroke ext.rcised closed during refueling outages at the same frequency as the full-stroke open exercise for the reasons described above. Close exercising of valve 8926 is not practicable after its quarterly part-stroke exercise open because that would defeat both trains of the intermediate head subsystem. Therefore, valve 8926 is niso full-stroke close exercised at refueling outages coincident with its full-stroke open exercise.

3-19 NUREG-1482

4 SUPPLEMENTAL GUIDANCE ON INSERVICE TESTING OF VALVES The following are recommendations of the U.S.

4.1.1 Closure Verification for Series Nuclear Regulatory Commission (NRC) staff for Check Valves without valves that may be a part of an inservice testing Intermediate Test Connections (IST) program. The types of valves discussed herein are covered by Section XI of the Many plants have piping configurations which American Society of Mechanical Engineers include two check valves in series with no (ASME) Boller and Pressure Yessel Code (the provision (such as intermediate test taps) for Code) and Part 10 of the ASME Operations and verifying that each valve can close. These Maintenance (OM) Standards (OMa-1988 valves may perform a safety function in the edition).

closed position. For example, the valves may be required to prevent the gross diversion of flow 4.1 Check Valves rather than to be leak-tight. The Code requires valves performing safety functions to be stroked The NRC considers check valves, and other to the position (s) required for the valves to automatic valves designed to close without perform those functions.

operator action after an accident and for which flow is not blocked, as " active" valves which Systems containing these valves may have would be classified as such in the IST program, provisions for verifying that at least one of the Those check valves (Category C valves) which two valves in a pair is closed. The provisions must also be leak-tight (Category A valves) would enable the licensee to measure or observe would be Category A/C. The NRC issued the an operational parameter such as leakage, following information notices (ins) on IST for pressure, or flow for the pair of valves. The check valves:

verification may be done each quarter or during each cold shutdown outage as practical.

IN 82-08 " Check Valve Failures on

- However, this in-situ testing demonstrates only Diesel Generator Engine that at least one valve of the pair is capable of Cooling System" reverse flow closure. The only indication of a problem would be the failure of both valves to IN 83-03

" Check Valve Failures in Raw close.

Water Cooling System of Diesel Generators" IST of a pair of valves does not enable the licensee to verify the operational readiness of IN 83-54

" Common Mode Failure of each component as intended in the Code, Main Steam Isolation because this testing method would not detect if Nonreturn Check Valves" one valve of the pair failed open. However, testing the pair of valves'would be acceptable if

)

IN 88-70 " Check Valve Inservice the configuration does not require two valves.-

i Testing Program Deficiencies" The safety analysis for such a configuration would credit either of the two valves.

NRC Recommendation If the licensee has no practical means for verifying the ability of each valve in a series to close, it may review the plant safety analysis to

)

4 4-1 NUREG-1482

- + - -

determine if both valves are required to function.

To perform testing of the pair of valves as If only one of the two valves is credited in the described above, the licensee must obtain relief.

safety analysis (that is, if one valve could be The relief requests typically include information removed without creating an unreviewed safety on the safety analysis, quality assurance question or creating a conflict with regulatory or requirements, the acceptance criteria, and the license requirements), then verification that the corrective actions that would be taken if pair of valves are capable of closing is excessive leakage is identified.

acceptable for IST. If relief is requested on this basis, both series check valves must be included Basisfor Recommendation in the IST program and be subject to equivalent quality assurance criteria. Testing (such as the Many plants contain piping configurations with use of pressure indication to verify the closure of series check valves that have no provision (such one of the check valves) is required during each as test taps) for testing the closure capability of quarter or at an extended intervi.! in accord with each valve. Some of these check valves perform the Code. No additional testing need be -

a safety function in the closed position to prevent performed unless the licensee finds indication the gross diversion of flow. The Code requires that the closure capability of the pair of valves is that each valve performing a safety function be questionable. If so, both valves must be stroked to the position required to perform that declared inoperable and be repaired or replaced function.

before being returned to service.

Systems containing these valves may have When testing of the pair of valves in accordance provisions for verifying that at least one valve is with the Code is not practical, the licensee may capable of closing. These provisions enable the demonstrate the capability of both valves to close licensee to measure or observe operational by disassembly and inspection (GL 89-04, parameters such as leakage, pressure, or flow Position 2) or other positive means during each quarter, during cold shutdown outages, or refueling outages. If the series valves are during refueling outages. However, this testing specifically required by the plant safety analysis provides no assurance that both valves close.

assumptions, the Code requires verification of The only indication of a problem would be the the capability of each of the pair of valves to failure of both valves in the series, function. The licensee may follow the guidance in GL 89-04, Position 2, to disassemble and Keep-fill valves are a special case in that they inspect each as an alternative means of verifying are redundant valves in redundant systems in y

that capability, but not for verifying leak-which only one valve of a series is actually tightness.

necessary to perform a system's intended function. Licensees have proposed to exclude Both valves in a series pair must be verified to the upstream valve from the IST program.

function if the plant safety analysis credits or However, recognizing that neither valve can be otherwise requires both valves. For example, individually demonstrated to shut, the NRC l

the two valves in the reactor coolant pressure previously determined for the alternative test boundary are required by Criterion 14 in method discussed in this section that both valves Appendix A to Part 50 of Title 10 of the Code must be included in the IST program and p

offederal Regulations (10 CFR Part 50).

operationally tested as a pair to prevent reverse Pressure isolation valves are a special case of flow. The NRC specified that, upon observing reactor coolant pressure boundary valves which leakage, the licensee disassemble, inspect,' and -

generally are required to be individually leakage repair or replace both valves as necessary before tested at a frequency specified by technical the return to service.

specifications and the Code.

NUREG-1482 4-2'

.~

l 4.1.2 Exercising Check Valves with During subsequent testing, if the system Flow conditions are repeatable, each valve would typically be fully stroked; however, the The Code requires check valves to be exercised nonintrusive verincation need be performed for to the position (s) required to fulfill their safety only one valve of the group on a rotating function (s). To verify the disk position of check schedule each time testing is performed. Under l

valves that do not have external disk position a sampling program for check valves, one valve l

indication, the Code allows the use of indirect would typically be nonintrusively tested each evidence (such as changes in system pressure, time the testing is performed, on a rotating flow, temperature, or level) or other positive schedule, and the balance of the group would be means. Instruments used to verify flow or flow tested. If problems are found with the pressure measurements for check valve full-sample valve, all valves must be tested using stroke are not subject to the range and accuracy nonintrusive techniques during the same outage.

requirements for such instrumentation used for The following table illustrates this pump IST; however, there may be testing recommendation.

techniques that necessitate a high degree of i

instrument accuracy.

Sample testing using nonintrusive techniques j

(NIT) and the flow testing (FT) procedure Cycle of the Train 1 Train 2 Train 3 Train 4 R efueling Valve valve valve Valve In supplementing the guidance from Position 1 I

Fr/NrT Fr/Nrr FT/Nrr FT/NrT in Generic Letter (GL) 89-04, the NRC 2

U/NR R R

R z

determined that the use of nonintrusive N##" h,wg h g

techniques is acceptable to verify the full stroke 5

Fr Fr Fr Fr/Nrr of a check valve, although the flow rate must be sufficient to stroke the valve to the backstop.

The staff has determined that nonintrusive The licensee may use nonintrusive techniques to techniques meet the Code requirements for verify the capability to open, close, and fully verifying disk movement for the full-stroke i

stroke in accord with quality assurance program exercising - opening and closing - of check requirements. These techniques are considered valves. The nonintrusive reverification allows "other positive means" in accordance with flow testing at repeatable conditions to be Paragraph IWV-3522 of Section XI (Paragraph performed on all valves in a group while 4.3.2.4(a) of OM-10), and relief is _not required requiring nonintrusive tests of only one of the except as would be necessary for the testing group on a rotating schedule. Relief is not frequency.

required because this test method is considered an acceptable "other positive means." However, When using nonintrusive testing techniques in a if the recommended alternative methods of this sampling plan, the licensee may implement a section are implemented, the licensee must program such that similar valves in the same describe the implementation of this section in the service are grouped for testing purposes, not to IST program document.

exceed four valves in a single group. GL 89-04 indicates that the valves in the group selected be Basisfor Recommendation of the same size, model number, and system function. During the initial test of each valve, By performing nonintrusive testing initially on

. the licensee would typically use nonintrusive.

all valves in the group, the licensee demonstrates techniques to verify that the system pressures that the full-stroke capability verification is and flow conditions specified in the test acceptable. By repeating the flow test under the procedures cause the valves to fully stroke.

same conditions, with nonintrusive verification 4-3 NUREG-1482

of only one of the four valves, the licensee NRC Recommendation verifies that the testing is repeatable. If the leecsee finds a problem with one train, it must If no other practical means is available, it is check all four trains with the nonintrusive acceptable to verify that check valves are capable techniques. When the system has not been of closing by performing leak-rate testing, such modined and the flow and pressure conditions as local leak rate testing in accord with are repeated, no phenomena would be expected Appendix J to 10 CFR Part 50, at each reactor to invalidate the testing as verified initially that refueling outage. Recognizing that the setup and would not be indicated in one of the four trains.

performance limitations may render leak testing If the licensee modified the system or performed impractical during power operation and cold the testing with a different valve alignment or shutdown outages, the staff has determined that test condition, it must perform the initial implementation of an extension of the test verifications. A copy of an NRC safety frequency for such valves is acceptable in accord evaluation for a relief request to adopt this with 10 CFR 50.55a(f)(4)(iv).

.i method is included in Appendix D.

Thus the licensee may perform testing in 4.1.3 Extension of Test Interval to accordance with the provisions of Paragraph Refueling Outage for Check 4.3.2.2(e) of OM-10. That is, if valve Valves Verified Closed by Leak exercising is not practicable during plant Testing operation or cold shutdowns, it is acceptable to limit testing to full-stroke exerching durin:;

Section XI requires that check valves performing refueling outages. To use this position, the l

a safety function in the closed position be licensee must include a refueling outage exercised to that position. OM-10 allows for the justification describing the impracticality of licensee to verify the exercise by visually performing testing at the Code frequency and observing the valve, recording an electrical referencing this position in the IST program. If signal initiated by a position-indicating device, these valves also perform a safety function in the observing the appropriate pressure indication in open position, they would typically be exercised the system, performing seat leakage testing, or open at the Code-required frequency, or the using other positive means. IST programs refueling outage justification would typically include check valves that perform a safety include the technical justification for not testing function in the closed position. Certain of these the valves quarterly or during cold shutdown valves cannot be verified in the closed position

outages, quarterly because they do not have remote position indication and are generally located in the justification for the Code cold shutdown inside reactor containment or at other outage or refueling outage frequency, the basis inaccessible locations. These valves may lack f r the impracticality of performing testing design provisions for system testing to verify during power operations and, if applicable, closure capability at any plant condition. The during cold shutdown outages, must be described.

only practical means of verifying valve closure may be by performing a seat leakage test. Many of these valves are Category A/C valves that are Basisfor Recommendation Type C leak-rate tested during each refueling outage as specified in Appendix J to 10 CFR Leak rate testing generally necessitates that Part 50.

certain systems necessary for plant operation be taken out of service for extended periods.

Additionally, containment access may be needed.

Therefore, this testing is not practical to perform -

NUREG-1482 44

quarterly. This testing may not be practical to power ascension and initially found the stroke perform during cold shutdown outages because times acceptable upon comparing them with the installation and removal of test equipment previous values. However, after further review could delay plant startup. OM-10 recognizes the with the plant at 100-percent power, the licensee limitations of performing testing during power found that the stroke time for at least one valve operations and cold shutdown outages and allows had increased such that the corrective action testing to be performed during refueling outages requirements of IWV-3417(a) applied. In for those valves which cannot be practically accordance with the Code, this increase exercised otherwise. Open exercising and necessitated that the test frequency be increased verification is required at the Code-specified to monthly until corrective action was taken. To frequency and is not required to be performed at conduct monthly full-stroke tests of MSIVs, the the same time the leak rate testing is performed.

licensee would have had to reduce plant powec and possibly bring the plant to a shutdown 4.2 Power-Operated Valves mode.

Power-operated valves are equipped with The NRC granted the licensee's request for actuators that use motive force to change the exigent relief from the requirements of IWV-position of the valve obturator. The types of 3417(a) to avoid shutting down the plant based actuators include motor operators, pneumatic on an analysis that the valve stroke time actuators, hydraulic actuators, and solenoid remained well within the plant's safety analysis actuators. Certain valves, such as main steam limits and that an increase was not expected to isolation valves and valves that have a fail-safe exceed the limits prior to the next planned cold function, may pneumatically or hydraulically shutdown. The licensee found that the need for actuate open (or closed) on spring force. The this exemption resulted from a weakness in the NRC discussed the IST of several types of administration and implementation of its IST power-operated valves in NRC IN 86-50, program.

" Inadequate Testing to Detect Failures of Safety-Related Pneumatic Components or Systems -

NRC Recommendation and IN 85-84, " Inadequate Inservice Testing of Main Steam Isolation Valves " The NRC issued The staff recommends that the licensee be aware GL 89-10, " Safety-Related Motor-Operated that it cannot test safety-related power-operated Valve Testing and Surveillance," upon finding a valves during power operation and :nust increase common mode failure with motor-operated the testing frequency as a result of tests valves. Testing programs addressing GL 89-10 Performed during cold shutdown outages in are beyond the stroke-time measurement accordance with IWV-3417(a), corrective action requirements for IST, but may be an alternative as specified in IWV-3417(b) is required before method of monitoring the condition of valves for returning the plant to power operation, or the which conventional stroke timing is not plant must return to a mode that permits testing practical, the valves each month. This also applies to valve stroke times in an " alert" range when 4.2.1 Increased Frequency of Testing compared to reference values for testing, unless for Valves That Can Be Tested an exception is specifically addressed in a relief l

Only During Cold Shuldown request approved by NRC.

This does not apply to testing performed in

+

accordance with OM-10, which does not include ne licensee for one pressurized-water reactor this requirement; rather, OM-10 requires (PWR) plant performed stroke time tests of the corrective action if a limiting stroke time is main steam isolation valves (MSIVs) during i

4-5 NUREG-1482

exceeded and does not allow for an increased acceptable, the licensee must consider the valve test frequency. Therefore, the increased testing degraded and take corrective action. OM-10 is not required if a licensee is testing against does not specify an intermediate condition that portions or all of the stroke time requirements of allows continued operation of the valve without OM-10 in accord with 10 CFR 50.55a (f)(4)(iv).

corrective action, but with increased testing.

liowever, corrective actions are required more expeditiously under OM-10.

4.2.2 Stroke Time Measurements for Rapid-Acting Valves With test results indicating that some degradation has occurred, it would not be conservative to New technologies and new applications of allow an extension of the testing interval from existing technologies enable licensees to time the orue each month to once each cold shutdown strokes of rapid-acting valves with accuracy

.,utage. To avoid a plant shutdown in one measured in milliseconds, though the Code does month, the staff recommends that these valves be not require such accuracy. Using new repaired or otherwise analyzed and the increase technology, the licensee could establish an j

in stroke time determined acceptable before the appropriate limit based on a multiple of a return to power. liowever, the licensee may reference value to ensure corrective actions are elect to periodically place the plant in a mode taken if degrading conditions are evidenced.

that allows for monthly testing of the valve which would meet Code requirements.

NRC Recommendation Basis for Recommendation Although the licensee is not required to do so by the Code, if a licensee uses new technology for Paragraph IWV-3412(a) of Section XI permits stroke-time measurements of rapid-acting valves, the licensee to defer valve testing from a the staff recommends that the licensee determine quarterly interval until cold shutdown outages, if if continued reliance on Position 6 of GL 89-04 it is impractical to perform during power or paragraph 4.2.1.8(e) of OM-10 is appropriate operation. However, the Code requires the when actual stroke times are measured to within licensee to increase the frequency of testing to milliseconds.

Once each month until corrective action is taken if the licensee, while conducting cold shutdown Basisfor Recommendation testing, finds that a power-operated valve fails to exhibit the required change of position within the The NRC and the OM Committee established the stroke time limits of IWV-3417(a). Although 2-second limit for rapid-acting valves for the the affected valves may be degrading, they need conventional method of measuring stroke-times not be considered inoperable if placed on an using a stop watch. Other methods have been increased frequency of testing. Since these developed as technology has improved. The valves are technically crerable, the technical latest technology may improve the monitoring of specifications (TS) ma; yet permit plant startup.

the condition of these valves or serve to verify r

However, the licensee may have previously that a valve actuates within a safety analysis determined to test these valves only during cold limit which is less than 2 seconds.

shutdown outages because they cannot be practically tested during power operation-4.2.3 Measurement of Valve Stroke Time The Code requires that the stroke time of power-In contrast to Section XI, IWV-3417, OM-10 operated valves be measured to at least the includes specific requirements for the limiting nearest second (IWV-3413, for valves that stroke stroke times such that, if the test results are not in less than 10 seconds, and OM-10, paragraph c

l NUREG-1482 4-6

4.2.1.4(b), for all power-operated valves).

method for monitoring these valves for However, many licensees use instruments that degrading conditions, including stroke timing.

can measure stroke times accurately to fractions Because the testing addresses much more than of a second.

only timing the valve strokes, the additional information obtained on the condition of the NRC Recommendation valves could justify the extension of the test interval for performing diagnostic testing.

To comply with Code requirements, the licensee measures stroke times for power-operated valves 4.2.4 Main Steam Isolation Valves to at least the nearest second. Similarly to Section 4.2.2 above, if using a more precise The NRC described an inadequacy in the IST of technique, it may be desirable, though not MSIVs in IN 85-84, " Inadequate Inservice required, to establish stroke-time limits based on Testing of Main Steam Isolation Valves." The a multiple of the reference value.

staff stated that two different licensees were testing their MSIVs using the nonsafety-related When it is impractical to measure stroke times instrument air to achieve closure. Fail-safe IST by any other method, a program of diagnostic of MSIVs as required by IWV-3415 and OM-10, methods for valves may be an acceptable paragraph 4.2.1.6, necessitates the removal of alternative test method. One example is a the instrument air supply and electric power.

program established in accord with GL 89-10,

" Safety-Related Motor-Operated Valve Testing NRC Recommendation and Surveillance," for monitoring motor-operated valves. Relief may be necessary if the The staff recommends that licensee review their test schedule is not consistent with the IST fail-safe testing to ensure compliance with Code requirements. If a licensee requests relief, the requirements.

submittal would typically specify the details of t

the proposed alternative and describe the Basisfor Recommendation impracticality or hardship of performing testing in accordance with the Code.

The practice of performing IST of components which are relied on to mitigate the consequences The staff has determined that this alternative can of accidents and which are relied on to do so ensure an acceptable level of quality and safety with sources of power not considered in the if the licensee has an established program of safety analyses is not in keeping with the 4

periodic testing. In this context, the staff has objective of periodic IST for fail-safe testing. In found acceptable the testing programs established IN 85-84, the NRC informed licensees that, with to GL 89-10 guidance. Because this alternative low or no steam flow, the MSIV might not close is not in accord with the Code requirements for unless instrument air is available to power the I

test frequency, relief is required, actuator.

Basisfor Recommendation In Service Information Letter.477, General Electric (GE) described a related concern for Valve diagnostic programs for monitoring valve boiling-water reactors (BWRs) in which operating parameters such as stroke times yield excessive tightening of gland flanges in the significant information about the valve assembly MSIV can prevent the valve from closing from i

(the valve and actuator). When IST spring force alone. During a postulated design

-l requirements are impractical, the periodic basis accident in which a recirculation line verification performed using valve diagnostic breaks with the MSIVs open, containment techniques may be an adequate alternative pressure may increase significantly, exerting an i

47 NUREG-1482

opening force on the valve actuators inside operational parameters such as leakage, pressure, containment. Under such circumstances, the and flow that give positive indication of the MSIV springs alone will not close the MSIV valve's actual position (s). "Ihis is consistent with unless the spring force can overcome the paragraph 4.1 of OM-10. The staff determined combination of the opening force caused by that the use of this portion of OM-10 is containment pressure and the resistive force acceptable pursuant to 10 CFR 50.55a (f)(4)(iv) caused by stem packing fraction. GE and that relief is not required if all requirements recommended a review of packing chamber of paragraph 4.1 of OM-10 are implemented.

maintenance practices, " springs-only" full-stroke No other related requirements apply.

closing tests, a force balance in which containment pressure is considered, a leak Basisfor Recommendation tightness test of the MSIV actuator and accumulator, and a modification of the Paragraph IWV-3300 of Section XI requires that applicable licensing basis documents. GE noted

" valves with remote position indicators shall be that this would necessitate measurement of the observed at least once every two years to verify actual valve stem travel because the final 10-that valve operation is accurately indicated."

percent of stem travel coincides with the weakest Often, licensees cannot verify the accuracy of spring force. GE stated that, by monitoring remote position indication by local observation position switches alone, the utility could not of many valves such as those with enclosed determine that the valve is fully closed because stems or sealed solenoid valves, and these valves the switches monitor the valve only when it is may not have position indicators, such as 90-percent open and 90-percent closed.

pointers, on the valve actuators.

4.2.5 Verification of Remote Position Accurate position indication for safety-related Indication for Valves by valves is important for reactor operation during Methods Other Than Direct all plant conditions. Therefore, the Code Observation requires verification of the accuracy of the remote position indication for all valves in the The Code (IWV-3300 and OM-10, paragraph IST program with remote position indication.

4.1) requires that valves with remote position Many positive ways are available to verify the indicators be observed at least once every 2 indication that a valve is open or closed. Leak-years to verify that valve position is accurately rate testing may yield positive indication that the indicated. Many valves such as sealed solenoid disk is in the closed position. An in-line flow valves and valves with enclosed stems have no rate instrument can indicate system flow or flow provision for verifying the position by direct stoppage. System pressures or differential observation. To verify the position by Pressure across a valve seat may also give a observation, the licensee can disassemble the positive indication of actual valve position, valve which could introduce additional valve failure mechanisms. Other methods, such as Paragraph 4.1 of OM-10 states that where local causing the flow to begin or cease, leak testing, observation is not possible, other indications and pressure testing can yield a positive shall be used to verify valve operation.

indication of position.

4.2.6 Requirements for Verifying NRC Recommendation Position Indication If remote valve position cannot be verified by The Code requirements for verifying valve local observation at the valve, an acceptable position indication do not restrict the verification approach is for the licensee to observe to only the position for which the valve has a NUREG-1482 4-8

i safety function, though the requirement was remote position indicators at multiple locations established to ensure proper indication when (such as in the control room and also on a used for stroke time measurement.

remote shutdown panel or sampling panel) that only the remote position indicator at the location NRC Recommendation utilized in exercising the valve (IWV-3412) and timing the stroke of the valve (IWV-3413) be Though not specifically required by the Code, verified for accurately indicating valve the staff recommends that the position indication operation.

l for both positions of a valve be verified, even if I

the valve has only one safety position. All 4.2.7 Stroke Time Measurernents valves in the IST program having position Using Reference Values I

indication are subject to the periodic verification j

requirements.

Position 6 of GL 89-04 states that it is acceptable for the licensee to measure changes in Dough not required by the Code, the staff also stroke times from either a reference value or the l

recommends that the remote locations that previous test value as required by IWV-3413. In include position indication for operators to use in Position 5, the NRC gave guidance on an accident condition, or in cycling the valve to establishing limiting values, but did not list a safe position, be verified on a periodic basis, acceptable percentages of the reference values.

This verification may be at a different frequency than the IST frequency of once every 2 years.

NRC Recommendation Basisfor Recommendation OM-10 specifies the allowable changes in stroke times from reference values. Therefore, when a The licensee can use both position lights in licensee elects to compare measured stroke times conducting inservice stroke-time testing of to reference values, the requirements of valves. When valve indication consists of a paragraph 4.2.1.8, " Stroke Time Acceptance single light, it could be possible to verify both Criteria," of OM-10 and all related requirements the "on" and "off" positions of the valve.

such as testing requirements and corrective action apply. The staff has determined that it is The Code does not restrict the verification of acceptable for a licensee to implement this position indication to only active valves. OM-method in accord with 10 CFR 50.55a (f)(4)(iv) 10, Table 1, indicates that the licensee must also for use of portions oflater editions of the Code verify the position indication for Category B approved in 10 CFR 50.55a(b) if all related passive valves. If the position indications for a requirements are met which include paragraphs valve are located in various remote locations, 1.3, 3.1, 3.2, 3.3, 3.4, 3.5, 3.6, 4.2.1.1 -

such as remote shutdown panels, the control 4.2.1.9,.5, and 6.

room, and local panels, and if these remote position indications are relied on when the -

Basisfor Recommendation control room is evacuated for a fire or other emergency as required in Appendix R of 10 The licensee can follo'w the requirements of OM-CFR Part 50, the licensee can periodically verify 10 for establishing reference values of stroke that the remote panels have accurate indication times because the stroke timing acceptance of valve position. However, the Code does not criteria for power-operated valves in IWV were require the licensee to verify the indication at the based on a change from the previous values, remote panels. In Interpretation 'XI-1-89-10, the This removes the inconsistencies of applying ASME Code committee stated that it is the intent acceptance criteria where no previous guidance of Section XI, IWV-3300, that for valves having -

was available. Variance from these requirements 4-9 NUREG-1482 -

'l of OM-10 would necessitate specific relief.

and Valve Testing." Valve diagnostic systems Figure 4.2 is a sample relief request for the use can be used to trace the stroke of an SOV and of stroke time reference.

thus indicate the stroke time in milliseconds.

4.2.8 Solenoid-Operated Valves 4.2.9 Control Valves with a Fail-Safe Safety Function The NRC has received many relief requests to not measure the stroke times of enclosed Often a safety function is performed by control solenoid-operated valves (SOVs) that do not have valves that fail in the safe position, whether that position indication. Most of the requests is open or closed. As valves that respond to proposed no alternative to monitor the valves for system conditions, these valves would be exempt degradation, from IST as required in IWV-1200 or Paragraph 2.1 of OM-10; however, the valves are required NRC Recommendation to be tested in accordance with the requirements for IST because they perform a fail-safe i

If the licensee cannot time the stroke of an SOV function. The staff has received many requests l

by the conventional method using position for relief from stroke-time measurement l

indication, the Code would require that it requirements based on the impracticality of propose a method to time the stroke of the valve performing the measurement by the conventional or otherwise monitor for degrading conditions to method using position indication lights.

give adequate assurance of operational readiness.

Typically, the control valves do not have He staff has determined that, while an exercise position indication, and testing can only be of the valves on a quarterly schedule ensures that performed by bypassing control signals. To the valves actuate properly, this is not adequate allow stroke timing by bypassing the control for IST. If the frequency requirements of the signals of those control valves with position l

Code are met, no relief is required to use indication, the licensee may also have to drain methods such as acoustics or diagnostic systems entire systems which makes testing at the Code l

for stroke timing. If a method to monitor for frequency impractical.

l~

degradation other than by measuring stroke time is proposed as an alternative, NRC approval is NRC Recommendation required. An enhanced maintenance program or periodic replacement may be acceptable when Control valves that perform a fail-safe function testing methods cannot be used effectively.

are required to be tested in accordance with the -

l Code requirements for IST to monitor the valves l

Basisfor Recommendation for degrading conditions. - Simply verifying that the valves function is not an acceptable j

In NUREG-1275, Vol 6, " Operating Experience alternative when the stroke time measurement by l

Feedback Report - Solenoid-Operated Valve the conventional method is impractical.

Problems," the NRC described common-mode Acceptable alternatives exists for monitoring the SOV problems that could significantly reduce valves for degrading conditions.

l plant safety. Several methods have been developed recently to measure stroke time or The staff recommends that the licensee monitor the condition of SOVs using parameters investigate alternatives that include stroke-timing such as the acoustics effects of disk movement, with acoustic or other nonintrusive methods.

electric resistance, and the temperature of the stroke-timing with local observation or -

coil. One such method and continuing research observation of system conditions, enhanced are described in NUREG/CP-0123, " Proceedings

- maintenance with a periodic stroke which may of the Second NRC/ASME Symposium on Pump _

not be timed, stroke-timing and fail-safe testing NUREG-1482 4-10

l during cold shutdowns or refueling outages that overpressure may not typically perform a involve bypassing control signals, and a control

" safety-related" function. However, these valves system signal calibration to verify the stroke are now required to be included in the IST times of the valves. The motor-operated valve program and tested according to the schedules testing program established in accordance with stipulatalin OM-1-1981 or OM-1-1987 GL 89-10 and performed on a periodic schedule "Requi,ements for Inservice Performance is an acceptable alternative, along with a Testing of Nuclear Power Plant Pressure Relief periodic valve stroke, because it would yield Devices.' The regulation requires this testing to more information on issues including stroke be included in 120-month updated IST programs.

time, although the information would be t

obtained less frequently. The alternative method NRC Recommendation proposed by the licensee would typically be described in detail in the relief request, if None. This discussion is for clarification of required, in order for the staff to determine the existing requirements.

acceptability of the alternative method.

4.3.2 OM-10 Reference to OM-1 Basisfor Recommendation OM-1-1981 was the edition of OM-1 referenced These control valves are not exempt from IST in the 1986 edition of Section XI. IST programs because they perform a safety function other developed and implemented in accordance with than " control." The Code requires stroke timing OM-10 are to use OM-1-1987, which was in of power-operated valves, but the features that effect when OMa-1988, Part 10, was issued.

enable testing have often not been provided for control valves with a fail-safe function.

NRC Recommendation Therefore, an alternative method is acceptable if the method, possibly in combination with a None. This discussion is for clarification of periodic valve stroke, provides an indication of existing requirements.

degrading conditions. Although stroke timing by an alternative method is preferred based on the 4.3.3 Test Supervisor Qualifications Code requirements, the licensee can use other methods if stroke timing is impractical.

Performance Test Code (PTC) 25.3-1976 is the However, the licensee must obtain relief because PTC referenced in Section XI, IWV-3512, for the alternative does not comply with the Code.

setpoint testing of safety valves and relief valves.

Paragraph 3.02, " Qualification of Person 4.3 Safety and Relief Valves Supervising the Test," of the PTC is a requirement for IST. The OM committee The NRC has received many relief requests for recognized that PTC 25.3-1976 was written for the IST of safety and relief valves.

testing at the manufacturer's facility and includes requirements that are difficult to apply to an j

4.3.1 Scope operating power plant, does not include all testing that should be performed for inservice in Paragraph IWV-1100 of the 1986 edition of valves. Therefore, the OM Committee issued l

'I Section XI, the Code committee increased the OM-1, " Requirements for Inservice Performance scope of the valves subject to IST to include Testing of Nuclear Power Plant Pressure Relief those valves which protect certain Code class Devices," for application to both preservice and IST. When OM-1 was issued for testing safety safety-related systems from overpressure.

Pressure relief valves which are installed in the valves and relief valves in nuclear power plants, applicable systems to protect against it did not include specific requirements for the NUREG-1482 4-11

qualifications of test supervisors. Paragraph (1)

Following the requirements of OM-1, 1.3.2.l(d) of OM-1, lists "the qualification of Paragraph 1.3.2.1, the licensee may personnel who perform testing and maintenance" establish the criteria for qualifying the test as an item for which the owner has supervisor and document the qualifications responsibility, in the test implementation procedure or work package for the setpoint testing.

The MC specifies that a test supervisor who has Documentation that the test supervisor obtained an academic degree in a branch of meets the qualifications must be available engineering from a recognized school of in the test records. The staff has engineering, and who has at least two years of determined the implementation of the practical experience in fluid-flow measurement, requirement of OM-1, paragraph 1.3.2.1, may be considered qualified to supervise the test.

for test supervisor qualifications is Code Case N-442, "1977 Addendum to ASME acceptable pursuant to 10 CFR 50.55a PTC 25.3-19'76, ' Safety and Relief Valves,'

(f)(4)(iv).

Class 1,2, 3, and MC [ metal containment]

Section III, Division 1," stated that the 1977 (2) The licensee may follow the guidance in Addendum to PTC 25.3-1976 could be used as Code Case N-442 which relaxes the alternative rules for ASME Section III safety and educational requirements specified in PTC relief valve testing. The 1977 Addendum 25.3-1976. This alternative necessitates a specifies that a person who supervises the test relief request.

shall have a formal education in thermodynamics and fluid mechanics, experience in superving Basisfor Reconunendation tests, and at least 2 years practical experience in measuring fluid flow.

The 1986 and later editions of ASME Section XI reference OM-1 for setpoint testing of relief A licensee often issues a purchase order c(mtract devices. The staff may approve the use oflater for a testing contractor to conduct the setpoint editions, or portions thereof, pursuant to testing of safety valves and relief valves, either 10 CFR 50.55a (f)(4)(iv). Therefore, it is at a test facility or on site. In following OM-1 acceptable to follow the requirements of OM-1 requirements such that the owner specifies the which state that the owner is responsible for qualifications, licensees typically have specified establishing the qualification of personnel who the applicable requirements in the purchase order perform testing and maintenance of safety relief and have documents from the testing contractor

devices, to verify that the individuals performing the tests meet the specified qualifications. These criteria Responding to inquiry number IN-92-027, the also apply for testing supervised by the owner ASME Code Committee,Section XI, stated that, such that test procedures specify the although the test supervisor's qualifications of qualifications of the individuals performing the ASME NC 25.3-1976, paragraph 3.02, apply tests and documents are available showing these when performing set point testing in accordance qualifications are met. A general statement is with Section XI, IWV-3512, the provisions not sufficient, stated in PTC 25.3-1976, paragraph 3.02, are-permissive (allow discretion). Therefore, the NRC Recommendation guidance for test supervisor qualifications in Code Case N-442 would be acceptable for

' The staff has found acceptable either of two Section XI IST and Section III design capacity alternatives to the quaiFication requirements in verification.

the NC:

NUREG-1482 4-12

l I

Appendix B to 10 CFR Part 50 specifies the determine the proper category (ies) for these requirements for quality assurance of activities valves (R. Favreau, OM Meeting, September 21, conducted for nuclear power plants. Included 1993). The Category B power-operated function are requirements for documenting tests of the valves would be tested in accordance with conducted by a test contractor or facility or by requirements of Section XI, Paragraph IWV-plant personnel. These documents would 3400, at least during each refueling outage. The confirm that the test supervisor meets the Category C function of the valves would be requirements necessary for ensuring the quality tested in accordance with requirements of of the tests.

Section XI, paragraphs IWV-3510 and IWV-3514 (or OM-10) and PTC 25.3-1976 or OM-1.

4.3.4 Frequency and Method of Testing Automatic NRC Recommendation Depressurization Valves in Boiling-Water Reactors The Code requirements for measuring stroke time govern the monitoring of power-operated Most boiling-water reactors (BWRs) are valves for degrading conditions. In many plants, equipped with dual-function main steam safety position indication is not provided for the ADS relief valves to protect the reactor vessel from valves, making direct stroke time measurement overpressure and to enable the licensee a means impractical. Many licensees meet the Code to quicidy depressurize the primary system. If a requirements for stroke time by using the acoustic momtors downstream of these valves to small-break loss-of-coolant accident (LOCA) measure the stroke time. This alternative is coincides with a failure of the high pressure injection system, the opening of these valves acceptable per GL 89-04, Position 6, if a 2-would depressurize the vessel to enable the low second limiting value of is assigned using the pressure injection system to inject coolant for guidance for rapidly acting valves. Other core cooling. Licensees have typically identified acceptable methods include (1) measuring the these valves as Category B/C for both the stroke time at the set pressure test facility, with an exercise in-situ after reinsta!!ation to ensure power-operated function and the self-actuating function.

controls have been properly connected, and (2) performing enhanced maintenance of the ADS Automatic depressurization system (ADS) valves and pilot valves, with stroke time measurements are capable of (1) acting as simple mechanical of the pilot valves. The staff determined that the relief valves, (2) being manually operated from a test frequencies in OM-10 are acceptable remote location, or (3) responding to an Pursuant to 10 CFR 50.55a(f)(4)(iv). Therefore, automatic safety system signal independently of the licensee may perform testing using the reactor pressure. Because of the categorization acoustic monitors and the guidance of GL 89-04, of these valves as B/C, licensees typically Position 6, during refueling outages by preparing request relief for an alternative to measuring a refueling outage justification for_ extending the stroke time for these valves. The alternatives test interval. Other proposed alternatives the staff has accepted include the use of acoustic necessitate NRC approval.

monitors, the indirect measurement of stroke time, and the performance of enhanced Basisfor Recommendation maintenance on the valves.

Testing these power-operated valves as Category The ADS valves perform dual functions which B valves may be difficult because they can be may require them to be Category B/C in the IST exercised only when sufficient reactor steam program, although the ASME OM Committee pressure is available. The NRC discussed concerns for these valves in NUREG-0123, has indicated that it is reviewing this issue to I

l 4-13

.NUREG-1482 l

I l

" Standard Technical Specifications for General replacement, repair, and maintenance. Section Electric Boiling Water Reactors (BWR/5)," and XI and OM-1 require that refurbished equipment NUREG-0626, " Generic Evaluation of be tested in accordance with the periodic testing Feedwater Transients and Small Break Loss-of-requirements as applicable. OM-1 also requires Coolant Accidents in GE-Designed Operating that, before resuming electric power generation, Plants and Near-Term Operating License the licensee shall verify the ability to open and Applications." In these documents, the staff close for each pressure relief valve in the BWR recommends reducing the number of challenges main steam system if this valve has auxiliary to the dual function ADS valves in order to actuating devices and has been maintained or-reduce their failure rate, because failure in the refurbished in place, removed for maintenance open position is equivalent to a small break and testing, or both, and reinstalled. The LOCA. Therefore, the period between refueling licensee shall verify this capability by remotely outages is a reasonable alternate frequency for actuating the valve at reduced system pressure.

verifying the Category B function of these Further set pressure verification is not required valves.

(reference Paragraph 3.4.1.l(d) of OM-10).

The testing that verifies the Category C function NRC Recommendation of these valves can typically be performed as specified in the Code, as this testing is The staff recommends that, if a licensee chooses performed infrequently and presents no special to use the jack-and-lap process and not reverify problems. If the ASME OM Committee the set pressure of the valves, it determine if the determines that these valves should be only maintenance activity is of an extent that a Category C (as opposed to Category B/C or setpoint test is required after the valve is A/C), meeting the Code requirements for reassembled and reinstalled. If thejack-and-lap Category A or B will be unnecessary.

process is controlled such that the setpoint will not be affected, the licensee may not need to 4.3.5 Jack-and-Lap Process perform a test once again, other than the remote actuation required for BWR main steam safety In Information Notice 91-74, " Changes in valves. Because the NRC staff cannot make this Pressurizer Safety Valve Setpoints Before determination by evaluating a relief request, Installation," the NRC stated that the setpoint relief is neither appropriate nor available for this changes in Dresser pressurizer safety valves activity.

could result in part from changes made during a

" jack-and-lap" procedure which is performed Basisfor Recommendation after setpoint testing and before installation to reduce seat leakage. This procedure may have Action in accord with this recommendation lacked adequate controls, necessitates determination of the effect of this activity and evaluation within the quality controls Many licensees avoid performing setpoint testing and quality assurance for the process. Controls afterJack-and-lap maintenance because this include limits on the amount of material which is testing could lead to leakage. The Code requires removed, the controls to ensure the settings and that when the licensee has repaired a valve or adjustments of the valve parts which affect the performed maintenance that could affect its setpoint are not changed, and the requirements in performance, the licensee must demonstrate that the maintenance procedure to address any the performance parameters are acceptable by unusual conditions that occur during the testing the valve before returning it to service, maintenance activity. The licensee can also The licensee must test pressure relief devices as consider industry experience to determine if required by Section XI and OM-1 for changes in the methods of performing this NUREG-1482 4-14

activity are necessary as plants accumulate more OM committee also stated in Intrepretation 92-2, data.

that in accordance with OM-1, adjustment of the valve setpoint without valve disassembly can 4.3.6 Safety / Relief Valve Setpoint satisfy the requirement for corrective action Adjustments specified in paragraphs 1.3.3.1.5(b) and 1.3.4.1.5(b) if the cause of failure is determined Ync common corrective action for valves is to and corrected as required.

perform analysis, retest, or a repair or replacement. However, the most appropriate 4.3.7 Setpoint As-Found Value action to take may be to adjust the setpoint for a safety relief valve when the setpoint for a safety The requirements of OM-1 differ significantly relief valve is not within the required range of from the requirements of IrrC-25.3-1976. OM-values. The terminology for a repair or 1 specifies that the valve must be opened at least replacement activity does not include setpoint twice consecutively and be found within Code adjustment; however, Paragraph 1.3.4.1.5(b),

tolerance each time. In determining the as-found

" Valves Not Meeting Acceptance Criteria," of setpoint, the licensee performs the first lift, OM-1 requires that any valve exceeding its compares the result with the acceptance criteria, stamped set pressure by 3 percent or greater and determines the need for additional tests, shall be repaired or replaced, the cause of failure Before completing valve setpoint testing for the determined and corrected, and the valve verified as-left conditions, the licensee must complete at to have successfully passed a retest before that least two consecutive openings within the Code valve is returned to service.

tolerance and must not use the average of the values. In Interpretation 92-4, the OM NRC Recommendation committee stated that paragraph 8.1.1.9,

" Number of Tests" (steam service), of OM The staff has determined that setpoint adjustment 1981 refers to as-left conditions, and that is an acceptable means of implementing the paragraph 8.1.3.8, " Number of Tests" (liquid corrective action reqeirements of IWV-3514 and service), of OM-1-1981 does not refer to as-OM-1. If the out-of-specification condition can found conditions. In other words, paragraphs be corrected by adjusting the setpoint, a Section 8.1.1.9 and 8.1.3.8 refer to the as-left set XI repair or replacement activity is unwarranted.

pressure number of tests.

Basisfor Recommendation NRC Recommendation A Section XI repair or replacement activity is None. This discussion is for clarification of defined as a weld repair of the pressure-retaining existing requirements.

parts of a component or the replacement of pressure-retaining parts. Although setpoint 4.3.8 Vacuurn Relief Valves adjustment does not constitute a Section XI repair or replacement activity, it may be the in OM Interpretation 92-5, as to whether the most appropriate action to correct a setpoint requirements of OM Put 1, paragraphs 7.1.2.3, drift. In Interpretation XI-1-8945 for Section 7.2.2.3,7.3.2.4, and 7.4.2.4 apply to all Class XI, the Code committee stated that Section XI, 2 and 3 vacuum relief valves which are requirnd IWV-3414, does not imply that valve set point to perform a specific function in shutting down'a adjustments are a Section XI repair (IWA-4000).

reactor or in mitigating the consequences of an However, the Code committee stated that set accident, the Code committee stated that the point adjustments satisfy the requirements for requirements of Part 1 apply only to pressure corrective action specified in IWV-3514. The NUREG-1482 4-15

relici devices required for overpressure frequency to verify the capability to open and protection.

close, the set pressure, and the performance of any accessories for sensing pressure and Paragraph 1.1.2(b) of OM-1 states that the position.

requirements apply only to pressure relief devices required for overpressure protection.

NRC Recommendation The definition of overpressure protection in OM-1 states that "[t]his term is defined in Article Paragraph 1.3.4 of OM-1 is not clear as to the 7000 of the applicable Subsection of Section III frequency for testing vacuum breakers, other of the ASME Boiler and Pressure Vessel Code."

than those that function as " primary containment The definition of overpressure in ASME vacuum relief valves." The staff recommends B&PVC Section III NC-7111 (Class 2) and ND-that licensees test Class 2 and 3 vacuum 7111 (Class 3) includes pressure changes that breakers, which are within the scope of OM-1, require relief devices that function to relieve at the frequency specified in Paragraph 1.3.4.1, vacuum. The definition is as follows:

" Pressure Relief Valves," of OM-1. The frequency would, therefore, be once in each ten-NC/ND-7111:... (2) Changes in year interval, except for any additional testing of differential pressure resulting from check valves as noted above.

thermal imbalances, vapor condensation, and other similar Basisfor Recommendation phenomena, capable of causing an internal or external pressure increase The test frequency is not clearly stated in OM-1; of sufficient duration to be however, the vacuum breakers which provide an compatible with the dynamic overpressure protection function are considered response characteristics of the within the scope of OM-1 by the definition in pressure relief devices listed in this NC/ND-7111.

Article.

4.4 Miscellaneous Valves Footnote 2 to NC/ND-7150n " Acceptable Pressure Relief Devices," states the following:

The following issues and NRC recommendations A pressure relief devi:e is designed to open to prevent a rise of internal 4.4.1 Pressurizer Power-Operated fluid pressure in excess of a Relief Valve Inservice Testing specified value due to exposure to emergency or upset conditions. It Power-operated relief valves (PORVs) were may also be designed to prevent often not purchased as safety-related valves and excessive internal vacuum. It may the function of these valves to provide pressure be a pressure relief valve, a non-control for plant transients was not considered reclosing pressure relief device, or a safety-related. The valves were not considered vacuum relief valve.

overprotection devices as required by ASME Section III, but many have since been used as To meet Code requirements, vacuum breakers low-temperature overpressure protection valves.

that are simple check valves are required to be full-stroke exercised in accordance with IWV-3520 and Paragraph 4.3.2 of OM-10 at the specified frequency, and are required to be tested in accordance with OM-1 at the specified NUREG-1482 4-16

I i

I I

NRC Recommendation Basisfor Recommendation

?

The staff recommends that licensees be aware of The NRC guidance on the IST requirements for previous NRC guidance, that the PORVs should PORVs is included in GL 90-06, " Resolution of be included in the IST program as Category B Generic Issue 70, ' Power-Operated Relief Valve i

valves and tested to the requirements of Section and Block Valve Reliability,' and Generic Issue L

XI. Recognizing that the PORVs have shown a 94, ' Additional Low-Temperature Overpressure i

high probability of sticking open and are not Protection for Light-Water Reactors,' Pursuant needed for overpressure protection during power to 10 CFR 50.54(f)." In IN 89-32, operation, the IWV-3410 provisions for

" Surveillance Testing of Low-Temperature i

exercising quarterly during power operation is Overpressure-Protection Systems," the NRC "not practical" and, therefore, exercising would discussed the stroke times of PORV assumptions be performed during cold shutdown conditions.

made in plant safety analyses for these PORVs, and IST performed for these valves. Stroke Previously approved NRC guidance (see below) times of the valves were unacceptable or were indicates that because the PORVs function not measured in the direction required for low-during reactor startup and shutdown to protect temperature oserpressure systems to prevent the reactor vessel and coolant system from low-exceeding the limits in Appendix G to 10 CFR temperature overpressurization conditions, they Part 50. Compliance with the guidance of GL should be exercised before system conditions 9046 has been coordinated between plants and warrant vessel protection, and exercised after the NRC Project Managers for each plant on a case-operational readiness of the block valves is by-case basis.

ensured, by exercising and stroke timing

[

according to the following test schedule:

4.4.2 Post-Accident Sarnpling System Valves l

(a)

Perform full-stroke exercising at each cold shutdown or, as a minimum, once each NUREG-0737, " Clarification of TMI Action i

refueling cycle.

Plan Requirements,"Section II.B.3, details the requirements and capabilities of post-accident (b)

Perform stroke timing at each cold sampling systems (PASSs) for sampling both the '

shutdown, or as a minimum, once each reactor coolant and the containment atmosphere.

refueling cycle.

The PASS consists of pumps and valves that perform these and possibly other functions. The (c)

Perform fail-safe testing at each cold PASS also includes valves that perform 'a shutdown, or as a minimum, once each containment isolation function.

refueling cycle.

NRC Recommendation (d)

Include the PORV block valves in the IST program and test them quarterly to ensure The IST nrogram applies to any PASS valves protection against a small break LOCA within the scope of 10 CFR 50.55a and Section should a PORV fail open.

XI of the ASME Code. Such valves in the PASS that perform a containment isolation (e)

If the plant frequently enters cold function are required to be included in the IST shutdown mode, testing of the PORVs is program as Category A or A/C and be tested to not required more often that once every 3 Code requirements except where relief has been months.

granted.

t 4-17 NUREG-1482 1

i l

The remaining valves in the PASS would obtain information on the condition of an typically be tested as required by the te:hnical individual valve.

specifications or other documents and need not be included in the IST program. However, the Paragraph IWV-3426 of Section XI requires the staff recommends that if the licensee elects to licensee to assign permissible leakage rates for include these valves in the IST program, a note each valve. The Code includes a formula for be included that the testing is beyond the scope calculating s limit that was not otherwise of 10 CFR 50.55a.

assigned and requires the measured leakage rate be compared to both the permissible value and to Basisfor Recommendation the previous measurements to determine if the valve requires corrective action. However, OM-NUREG-0737, " Clarification of TMI Action 10 requirements for leak testing allow for testing Plan Requirements,"Section II.B.3, " Post-valves in groups, trending leakage rates of the -

Accident Sampling Capability," details the group, and taking corrective actions if the group requirements and capabilities for the licensee's leakage limit is exceeded.

PASS, which provides for sampling both the reactor coolant and the containment atmosphere NRC Recommendation and consists of pumps and valves to perform these functions. The PASS also contains valves Valves may be leak tested in groups as allowed that can isolate containment where the system by OM-10. If two or more valves on a penetrates containment.

containment penetration are tested as a group, limiting leakage-rate values must be assigned to 4.4.3 Multiple Containment Isolation the group for the purpose of monitoring the Valve Leak-Rate Testing condition of the valve and taking corrective action. If the limiting values are exceeded, the Some piants have containment penetrations with licensee must take actions to determine the multiple isolation branches from a common leakage path. The licensee for a plant that has header which include several containment not updated to OM-10 need not obtain relief as isolation valves (CIVs). In many cases it is not the staff has determined it is acceptable to leak practical to perform a seat leakage test on each test valves in groups per Paragraph 4.2.2.3 of valve. Licensees typically request relief and OM-10 in accord with 10 CFR 50.55a (f)(4)(iv).

propose to test the valves as a group to verify the leak rate is with a limiting value of leakage To implement this guidance, the IST program assigned to the group, must include a discussion of the methodology for establishing leakage limits for valves tested as a By assigning a limiting value of leakage rate to group. The licensee would typically establish an individual valve, the licensee can ascertain limits at values sufficient for finding leakage trends and determine the best time for repair or from any valve in the group, based on the replacement, as necessary. ' Many valves seat diameter of the smallest valve in the group or i

differently each time they are operated and can based on a conservative limit established to exhibit a differing seat leakage rate after each another criterion not related to the diameter of closure, which would challenge the the valve. If the licensee chooses to implement determination of degradation based on the this guidance, the licensee must continue to analysis of leakage rate. This problem will be comply with the analysis ofleakage rates and further compounded when valves are tested in corrective action requirements of Paragraphs groups. In measuring the trends in the leakage IWV-3426 and IWV-3427(a) of Section XI or rate of the valve group, the licensee would not Paragraph 4.2.2.3 of OM-10 to the extent -

practical for group leakage testing.

i NUREG-1482 41g

Basisfor Recommendation impractical to stroke valves that must remain in position for operations to continue. Recent The NRC approved the use of OM-10 with examples include main steam isolation valves exceptions for CIVs to require the leakage test and main feedwater isolation valves. If the requirements of paragraph 4.2.2.3 of OM-10 be leakage does not pose a personnel safety hazard, applied to CIVs (see 57 Federal Register 34666, licensees often may adjust the packing without August 6,1992),

removing the valves from service. Improper adjustment of valve stem packing could In accordance with the Code, the licensee can adversely affect the valve's functional capability.

establish acceptance criteria with limits for a group of valves. Once a leakage rate exceeds NRC Recommendation the acceptance criterion, the leakage pathway would be determined using methods structured The staff has determined that whenever valve for individual valves, perform repairs upon stem packing is adjusted without a stroke test, determining the leakage pathway, and retest the the licensee must assess the effect of this valves to ensure all pathways were repaired to adjustment on the valve's functional capability to ensure that leakage is within acceptable limits open and close and to meet stroke-time after maintenance. This procedure eliminates requirements and verify the stroke time by test unnecessary individual valve leakage testing when it is practical to perform.

conducted solely to meet 10 CFR 50.55a and Appendix J of 10 CFR Part 50. The licensee The staff has determined that it is acceptable for would obtah no additional information by testing a licensee to perform an engineering evaluation individual valves for leakage upon finding little of the impact of adjusting valve stem packing to or no leakage during the initial testing of a valve meet Code requirements. If it is necessary to grenp. If the licensee finds increased group adjust the stem packing to stop leakage and if a leakage, it could assess the leakage pathway by required stroke test or leak rate test is not evaluating individual valves. However, this practical in the current plant mode, the licensee procedure must comply with the requirements of must justify that the packing adjustment is within Appendix J to 10 CFR Part 50 and OM-10 for torque limits specified by the manufacturer for the direction of the test pressure against the seat the existing configuration of packing such that of the valve.

the performance parameters of the valve are not adversely affected.. Examples of such valves are 4.4.4 Post-Maintenance Testing the main feedwater isolation valve and main Following Stem Packing steam isolation valve, which remain open to l

Adjustments continue power operations. The licensee must evaluate any data available from previous testing Paragraph IWV-3200 of Section XI requires with the packing torqued to the limit specified that, up(m performing maintenance to a valve in and verify that the valve was previously stroked a manner that could affect its performance, such within acceptable limits with the packing as by adjusting the stem packing, the licensee adjusted to the higher value.

shall, before returning the valve to service, test it to demonstrate that the performance Relief is not required because this action is in parameters are within acceptable limits.

accordance with the Code requirements if the Paragraph 3.4 of OM-10 contains similar licensee can demonstrate that the performance requirements, parameters will not be adversely affected; -

however, packing adjustments beyond the The licensee may need to adjust the stem manufacturer's limits'may not be performed

- packing during power operations when it is without an engineering analysis and approval cf 4-19 NUREG-1482 I

the manufacturer unless tests can be performed time (or leakage rate) such that it would not after adjustments. In implementing this exceed its limiting value, can make the guidance, the licensee must perform a partial-adjustment without a post-maintenance stroke stroke test if practical to obtain further assurance time measurement (or leakage test). This that the valve stem is free to move. At the first guidance applies only to valves that need opportunity when the plant enters an operating adjustment during power operation and cannot be mode in which testing is allowed, the licensee fully stroked in the plant operating mode. The must test all valves that have packing guidance does not apply merely as a convenience adjustments that were made without post-to the licensee and does not supersede any maintenance testing to the extent practical. The related guidance associated with GL 89-10.

maintenance procedure used to adjust the packing must include the limits, and any changes Responding to Inquiry IN-91-045, the ASME to the limits must be subject to a 10 CFR 50.59 Section XI Boiler and Pressure Vessel review. The licensee would typically avoid Committee stated that Subsection IWV-3200 of adjusting redundant valves without performing Section XI does not require a stroke-time test if I

post-maintenance testing. When plant conditions it is established that adjustment of packing will l

allow, however, the licensee must partially not affect the stroke time of a specine valve.

i stroke the valve to ensure that the stem is not l

binding.

Responding to Inquiry IN-92-031, the Code committee also stated that Subsection IWV-3200 To implement this guidance, the licensee must does not require a test to verify seat leakage if perform individual vaive evaluation unless it has the owner establishes that an adjustment of i

l established a valve packing program in which packing will not in any way affect the required designated limits, justified by test data, allow seat leakage performance of a specine valve.

i adjustments that do not affect performance l

parameters. Specine or general relief is not 4.4.5 Leak-Rate Testing Using OM-10 appropriate for this activity. If the licensee Requirements l

j cannot justify that the packing adjustment does not adversely affect performance parameters, Though the leak-rab 'esting requirements of there would be no basis for relief and the Code Paragraphs 4.2.? ! of UM-10 and IWV-3420 of requirements must be met. Therefore, the Section XI differ only slightly, a licensee may licensee must consider this issue for each valve use the requirements of OM-10 for monitoring individually, the leak-rates of valves.

Basisfor Recommendation NRC Recommendation The NRC would not require a licensee to shut Paragraph 4.2.2.3 of OM-10 speciDes acceptable down a plant to perform IST unless the licensee requirements for implementing a leakage-L has no alternative to ensure that the operational monitoring program for valves. The staff has readiness of components is maintained or unless determined that licensees may update their l

a safety issue exists. The IST requirements do programs to the requirements of Paragraph not prohibit or discourage the licensee from 4.2.2.3 of OM-10 pursuant to 10 CFR 50.55a l

making limited adjustments to packing to stop a (f)(4)(iv) and meeting all the requirements of leak that may be adversely affecting the valve or Paragraphs 4.2.2.1 and 4.2.2.3.

(

surrounding components. Therefore, the l

licensee can perform an analysis of the packing adjustment and, upon demonstrating that the adjustment does not adversely affect the stroke NUREG-1482 4-20 I

Basisfor Recommendation 4.4.6 Manual Valves The leakage-monitoring requirements of OM-10 The staff has received questions about the differ from previous requirements in the requirements for including manual valves in the following areas:

IST programs. The Code includes manual valves that meet the scope requirements of 10 (1)

OM-10 allows leak-rate testing for groups CFR 50.55a. To comply with the Code, of valves.

exercising requirements for a manual valve must be in accord with applicable IST requirements of (2)

OM-10 allows a pressure decay test for IWV or OM-10 if the manual valve is credited determining leakage.

in the safety analysis for being capable of being repositioned to shut down the plant, to maintain O)

OM-10 changes the permissible Code the plant in a safe shutdown condition, or to leakage rate of water from 30D ml/hr to mitigate the consequences of an accident.

0.5D gpm or 5 gpm (whichever is less),

where D is the nominal valve size NRC Recommendation (diameter) expressed in inches.

None. This discussion is for clarification of (4)

OM-10 eli.ninated the allowance for leak existing requirements.

testing valves (except check valves) in eder direction if the function differential pressure is 15 psi or less.

These differences are not considered to be relaxations of the intent of the Code to monitor for degrading conditions.

ih, i

4-21 NUREG-1482

- =.

5 SUPPLEMENTAL GUIDANCE ON INSERVICE TESTING OF PUMPS 5.1 General Pump Inservice Testing startup.

Issues In Generic Letter (GL) 87-09, the U.S. Nuclear Regulatory Commission (NRC) clarified its.

5.1.1 Frequency of Inservice Tests -

position about the 1-week allowanee of the Code Comparison of the American in the Bases section of Technical Specification Society of Mechanical Engineers 4.0.5 as follows:

Code to Technical Specifications Specification 4.0.5. establishes the Paragraph (a) of IWP-3400, " Frequency of requirement that inservice inspection Inservice Tests," in Section XI of the American of ASME Code Class 1,2, and 3 Society of Mechanical Engineers (ASME) Boiler components, and inservice testing of and Pressure Vessel Code (the Code) specifies ASME Code Class 1,2, and 3 the following:

pumps and valves shall be performed in accordance with a periodically An inservice test shall be run on updated version of Section XI of the each pump nominally every 3 ASME Boiler and Pressure Vessel.

months during normal plant..

Code and Addenda as required by operation. It is recommended that 10 CFR 50.55a... Under the this test frequency be maintained terms of this specification, the more during shutdown periods if this can restrictive requirements of th'e reasonably be accomplished.

Technical Specifications take although this is not mandatory. If it precedence'over the ASME Boiler is not tested during plant shutdown, and Pressure Vessel Code and j

the pump shall be tested within 1 applicable Addenda. The i

week after the plant is returned to requirements of Specification 4.0.4 -

normal operations.

to perform' surveillance activities before entry into an Paragraph 5.4, " Pumps in Systems Out of OPERATIONAL MODE or other Service," in Part 6 of the ASME/ ANSI specified condition takes precedence l

[American National Standards Institutel over the ASME Boiler and Pressure -

Operations and Maintenance Standards (OM-6)

Vessel Code provision which allows includes similar requiremants:

pumps... to be tested up to one week after return to normal For a pump in a system declared operation.

inoperable or not required to be '

i operable, the test schedule need not Therefore, to comply with GL 87-09 guidance, be followed. Within 3 months prior if the testing schedule is not maintained during to placing the system in an operable plant shutdowns, the affected pump (s) must be j

status, the pump shall be tested and tested before entering an operational mode which 1

the test schedule followed in requires the pump (s) to be operable. The only accordance with the requirements of exceptions to this guidance are for those plants this' Part. Pumps which can only be with specific technical specification allowances tested during plant operation shall be that state otherwise.

tested within I week following plant 3

5-1 NUREG-1482 9

i NRC Recommendation but that it has little value for quarterly pump testing.

No new guidance or recommendations are contained in this section. This section discusses (4) Bearing temperature previously issued guidance and experience.

OM4 does not specify that bearing temperature 5.1.2 Continued Measurement of he measured. Bearing temperature increases Parameters Deleted from OM-6 rapidly until the bearing fails. The main reason for deleting this requirement is that it is unlikely The following parameters required to be that bearing failure would be detected by a -

measured by Subsection IWP of Section XI were yearly test. The parameter indicates pending not included in the requirements of OM4 for the pump bearing failure only when it is reasens stated (see NUREG/CP-Olli, continuously monitored, which does not apply

" Proceedings of the Symposium on Inservice for standby pumps.

Testing of Pumps and Valves, paper entitled

" Introduction to ASME/ ANSI OMa-1989a Part 6 NRC Recommendation

- Inservice Testing of Pumps in Light-Water Reactor Power Plants - and Technical The staff has determined that licensees may (1)

Differences Between Part 6 and ASME Section eliminate the parameters deleted from the XI, Subsection IWP," John J. Zudans, pg. 25 inservice testing (IST) requirements by OM4 -

58):

with consideration of the discussion above of the reasons why these parameters were deleted and -

(1) Inlet pressure (2) include them in a maintenance program, as applicable pursuant to Section 50.55a (f)(4)(iv)

This parameter was not included in OM4 of Title 10 of the Code ofFederal Regulations becat.se IWP did not include acceptance criteria.

(10 CFR 50.55a (f)(4)(iv)). Relief requests need It is included in IWP to help the owner prepare not be submitted to delete the requirement to the test and recognize that adequate suction measure these parameters which are no longer pressure needs to be specified in the test required to be monitored. There are no specific -

procedure. OM4 recognized that the owner is related requirements for using this responsible to address testing limitations in the recommendation; however, discharge pressure procedures, for positive displacement pumps must be monitored with the specified limits'of OM4. If '

i (2) Diferentialpressureforpositive this recommendation is used, the documents for displacement pumps the IST program must discuss the implementation.

Subsection IWP requires differential pressure for both centrifugal and positive displacement (PD)

Basisfor Recommendation pumps. Since discharge pressure is independent of inlet pressure for PD pumps, the requirement The staff reviewed the OM Committee's basis has been changed to require discharge pressure for deleting these parameters and agrees with its -

as the sole indicator of pump degradation.

determination as stated above. Eliminating the requirements for monitoring certain parameters (3)

Proper lubricant level orpressure which have not proven to yield useful data is consistent with the intent of the IST requirements OM4 does not require this parameter because and is, therefore, not detrimental to the the OM committee found that it should be continued safe operation of the plants.

j.

observed as part of regular maintenance practice, NUREG-1482 5-2 l

5.2 Use of Variable Reference 0.90 - 0.93 or 1.02 - 1.03 times the Values for Flow Rate and Value fr m the pump curve. The pump is operatmg m the requiren action range if Differential Pressure Dur,ng i

the measured differenti.d pressure is less Pump Testing than 0.90 or greater than 1.03 times the value from the pump curve at the tested Some designs do not allow for testing at a single flow rate.

reference point or a set of reference points. In these cases it may be necessary to plot pump Since pump vibration readings may vary widely curves to use as the basis for variable reference with changes in pump flow rate and differential points.

pressure, the licensee must propose a method of evaluating pump vibration measurements taken NRC Recommendation with the pump operating in possible as-found conditions to ensure that a degraded pump would The NRC considers acceptable the use c? pump be declared inoperable and repaired.

curves for reference values of flow rate atA differential pressure if the licensee clearly The licensee must perform the following demonstrates in a relief request the impract cality elements in preparing pump curves for the relief of establishing a fixed set of reference vahtes.

request for IST of pumps:

To obtain approval for a proposed method of evaluating these pump parameters to detect (1)

Prepare pump curves, or validate the hydraulic degradation and determine pump manufacturer's pump curves, when the operability, the licensee must demonstrate that pumps are known to be operating the method is equivalent to the Code acceptably.

requirements in Table IWP-3100-2 (or Table 3b of OM-6) for allowable ranges.

(2)

When measuring the reference points for plotting or validating the curve, use To use this test method, the licensee must plot a instruments at least as accurate as required valid pump chs.racteristic curve from empirical by the Code.

data or obtaia one from the pump manufacturer and verify it with measurements taken when the (3)

Construct each curve with a minimum of pump was known to be in good operating five points.

condition. The following is an example of an acceptable test plan.

(4)

Construct the curve with only those points beyond the " flat" portion (low flow rates)

Measure pump flow rate with the pump of the curves in a range which includes or operating as found. Plot a point for this is as close as practicable to design basis flow rate en the pump characteristic curve.

flow rates.

Measure the pump differential pressure with the pump operating as found and (5)

Establish acceptance criteria for the pumps -

compare this differential pressure to the that do not conflict with the operability differential pressure obtained from the criteria for flow rate and differential pump curve for the measured flow rate.

pressure in the technical specifications or The pump is operating in the acceptable the facility safety analysis report.

range if the measured differential pressure is from 0.93 - 1.02 times the value from (6)

If vibration levels vary significantly over the pump curve, and is in the alert range if the range of pump conditions, prepare a the measured differential pressure is from method for assigning appropriate vibration 5-3 NUREG-1482

i I

acceptance criteria for regions of the pump which is severly degraded, either hydraulically curve.

or mechanically, is declared inoperable and' repaired. Appendix C includes an example of an (7)

When the reference curve may have been acceptable relief request demonstrating the use of affected by repair, replacement, or routine a pump curve.

service, plot a new reference curve or revalidate the previous curve by in Interpretation 92-6, the OM committee stated conducting an inservice test.

that reference values and acceptance band curves over a small range of expected flow, for IST of This guidance requires relief because the Code a pump where system resistance cannot be does not allow for testing using pump curves. If varied, do not meet the requirements of OM Part the licensee impleraents this guidance, it mast

6. The committee also stated that OM Part 6 demonstrate the impracticality of achieving specifies a maximum value for the alert and reference conditions for IST. A relief request required action ranges in Table 3a.

must include a description of the methodology to be used in evaluating these pumps.

5.3 Allowable Variance from Basisfor Recommendation Severallicensees recently requested relief from Where.t.i is not practical to return to the same the Code requirements for fixed reference flow configuration for each subsequent mservice points. Certain designs do not allow for the pump test, it is necessary for the licensee to licensee to set the flow at an exact value because establish a method for evaluatmg the operat,onal i

of limitations in the instruments and controls for readiness of pumps m variable flow systems.

maintaining steady flow. The characteristics of This may be the case for service water or piping systems in other designs do not allow for component cool, g water systems and other m

flow to be adjusted to exact values. The Code systems where temperature or flow is controlled does not allow for variance from a fixed at a variety oflocations. During quarterly pump reference value, stating only that "[t]he testmg, the licensee may not be able to manually resistance of the system shall be varied until control each of these local stations and duplicate either the measured differential pressure or the the overall system reference conditions, as measured flow rate equals the corresponding required by the Code.

reference value." Licensees have requested 1

relief to establish a range of values similar to I

Us.ing the manufacturer's pump-specific curves using a pump curve, but with a very narrow for flow and differential pressure, the licensee band. For example, one licensee proposed to may be able to evaluate the pump m as found use a reference curve with the tolerance around system conditions. In implementing th,s i

the selected value to be i 2 percent. Plant guidance, the licensee would confirm these implementing procedures may instruct operators values by performmg in-situ testmg. Another to set the flow to 1500 gpm [94.6 L/s]. When method would be to plot pump curves over the this step is performed, the operator would range of conditions expected during the system's i

attempt to set the flow as close as possible to normal operat,on. It is also important to develop 1500 gpm [94.6 L/s] and maintain it steadily at a method of evaluating pump vibration approximately 1500 gpm [94.6 L/s].

measurements taken with the pump operat, g m

over the tange of possible as-found conditions, NRC Recommendation smce th,s is a variable pump parameter. By i

evaluatirg these measurements of pump The staff has determined that, if the design does vibratv;n, the licensee will ensure that a pump not allow for establishing and maintaining flow NUREG-1482 -

5-4

1 at an exact value, achieving a steady flow rate or tolerance. Licensees may set the repeatable differential pressure at approximately the set parameter as close as possible to the reference value does not require relief for establishing value during each test rather than treating any pump curves. The allowed tolerance for setting variance in the value with a pump curve. If, the fixed parameter must be established for each upon establishing trends in data, the licensee case individually including the accuracy of the determines that the parameter varies such that instrument and the precision of its display. This the readings are outside the accuracy of the will necessitate verification of the effect of instrument, it may need to establish pump curves precision on accuracy as considered in the design and request relief for the applicable pumps (see of the instrument gauge. In no case is a total Section 5.2),

tolerance of greater than i 2 percent of the reference value allowed without relief. If a total The basis for allowing a variance of i 2 percent tolerance ofless than i 2 percent of the from the reference value is paragraph IWP-4150 reference value is achievable, relief is not of Section XI which specifies the requirements required; however, in using this guidance, the for instrument fluctuations. IWP-4150 allows variance and the method for establishing the symmetrical damping devices or averaging variance must be documented in the IST techniques to reduce instrument fluctuations to program.

within 2 percent of the observed reading for values specified in the implementing procedures.

In 10 CFR 50.55a(f)(4)(iv), the NRC allows for the licensee to use later editions of the Code If an analog gauge is used, the precision is which have been incorporated into determined by the increments in the scale and i

10 CFR 50.55a(b). The staff determined that thus could be the limiting factor. Readings the use of Paragraph 5.2(c) of OM-6 for systems would be acceptable to a degree of precision no in which resistance cannot be varied is greater than one-half the smallest increment.

acceptable pursuant to 10 CFR 50.55a(f)(4)(iv).

For example, a gauge that has a full-scale range No related requirements apply other than the of 0 - 12,000 gpm [0 - 757.1 L/s] has requirement to compare the flow and pressure to increments of 200 gpm [0 - 12.6 L/s]. The limits of Table IWP-3100-2, or OM4 Table 3b standard reading between increments would be if using OM-6 limits, no more than 100 gpm [6.3 L/s]. If the indication is between 6000 gpm and 6200 gpm Basisfor Recommendation

[378.5 and 391.2 L/s], the operator could " read" the gauge at only three values: 6000 gpm,6100 The Code does not address the possibility that a gpm, or 6200 gpm, [378.5,385.0, or 391.2 L/s]

flow rate or differential pressure may not be depending on whether the indication is in the controllable to an exact value. However, the middle or closer to the line for either 6000 gpm limits for flow rate and differential pressure do or 6200 gpm [378.5 or 391.2 L/s]. A reading not both apply (i.e., are not both allowed to of 6050 gpm [381.7 L/s] would not be vary across the acceptable range for the acceptable for an increment of 200 gpm [12.6 -

parameter) for monitoring the condition of L/s].

l pumps. When the Code specifies that the system resistance be varied until either the flow or '

Note that Paragraph 5.2(c) of OM4 specifies

]

differential pressure equals the corresponding that, if the pump is in a system for which the reference value, it does not intend that the " set resistance cannot be varied, the " flow rate and value" have an acceptable range as stated in pressure shall be determined and compared to Table IWP-3100-2 (OM-6, Table 3b). Licensees their respective reference values." This provides.

recognize that the reference value for certain further justification for the position that the pumps can only be achieved within a specified limits for pressure and flow do not both apply to

{

5-5 NUREG-1482

each test parameter, but only to the parameter Basisfor Recommendation being measured for the pumps for which the resistance of the system can be varied when the By using units of velocity rather than pumps are tested.

displacement in measuring vibration in pumps that operate above 600 revolutions per minute 5.4 Monitoring Pump Vibration in (rpm), the licensee could more rapidly detect Accord with OM-6 wear in the anti-friction bearing and other types of pump degradation and thus could effect mpairs in a mom dmely mannu.

ne NRC has received relief requests from licensees requesting approval to use th Pump bearing degradation results in increased requirements of OM-6 for monitoring pump vibration at frequencies 5 to 100 times the vibration. He OMa-1988 edition of OM4 did not include the figure that accompanies Table 3 r tational speed of the pump. These high-in the OMb-1989 addenda. Table 3 in the 1989 hequency bearmg vibrations may not sigm6cantiy increase the measured displacement edition is referenced as " Fig.1" in footnote 2 of f pump v,ibration and could go undetected.

Table 3a' However, the high frequency vibration would signWicantly increase the measured velocity of NRC Recommendation pump vibration which could indicate the need for corsch acdon Nfom the Wng faus.

OM4 allows for monitoring pump vibration in Because pump bear,ngs vibrate at high i

units of either pump displacement or pump velocity and includes acceptance criteria for both frequencies, the measured vibration velocity indicates the mechamcal condition of the pumps units of measurement. The staff has determined that if the licensee uses OM4 for monitoring and reveals pump bearmg degradation much vibration in the IST program, the program must m re accurately than does measured vibration include all of the requirements for such displacement.

monitoring. Licensees may update their Advantages of measuring vibration velocity in programs in accordance w,th this position i

lieu of displacement for monitoring mechanical without further relief if they meet all related requirements for monitoring vibration in condition of pumps, with the exception of low-paragraphs 4.6.1, 4.6.4, and 6.1 of OM4, speed pumps, are widely acknowledged in the pursuant to 10 CFR 50.55a (f)(4)(iv).

mdustry. Many nuclear licensees measure pump vibration velocity to detect pump degradation in following this guidance, the frequency and obtain advanced warning of incipient pump bearing failure. Upon obtaimng this advanced response range of the instrumentation must be as speciDed in paragraph 4.6.1.6 of OM4 for both warmng, the licensee can plan and prepare for mamtenance durmg scheduled outages mstead of low-speed and high-speed pumps unless the licensee demonstrates that the information gained suKerma losses msuhing kom unplanned outages to repair failed critical equipment.

at the low frequency response does not apply for the bearing design of the pumps. Although the OM4 includes a set of allowable ranges for instruments in the low frequency response range inservice pump vibration velocity and for were only recently made commercially available measured pump vibration displacement. These and may not be w,idely used, the unavailability ofinstruments is not sufficient as the sole ranges am based on an evaluation of empirical justification for either obtaining relief from the data and various acceptance criteria for pump frequency response range requirements of OM4, vibration velocity established by U.S. mdustries, or obtaining approval of an alternative from the academ,ia, mternational industry, and foreign requirements.

agencies. The OM4 workmg group considered NUREG-1482 54

the data and proposed the ranges of OM-6. The the staff will grant relief when the combination ASME Code, Winter 1988 Addenda to the 1986 of the range and accuracy yields a reading at edition, and the 1989 edition, reference OM-6 in least equivalent to the reading achieved from its entirety. Effective September 9,1992, the instruments that meet the Code requirements.

NRC approved OM-6 in 10 CFR 50.55a(b).

The use of a test gauge in lieu of a permanent instrument is acceptable if the reading is at least The OM committee changed the frequency equivalent to the Code. When using temporary response range requirements from one-half to instruments, the staff recommends that the one-third of the minimum pump shaft rotational licensee include in the IST records an instrument speed in order to encompass all noise number for tracing each instrument and a contributors that could indicate degradation.

calibration data sheet for verifying that the Although instruments with a frequency response instruments are accurately calibrated. The range which meets these requirements for slow-licensee need not obtain relief if the temporary speed pumps are now commercially available but instruments meet the range and accuracy not widely used, the unavailability of instruments re.quirements of the Code. If relief is requested, is not adequate justification for obtaining relief the licensee would typically describe the effect or approval of an alternative. However, on each group of applicable pumps and would frequencies less than running speed may not typically discuss adjustment of acceptance limits apply for pumps with certain types of bearings.

to account for the inaccuracies.

5.5 Pump Flow Rate and Basisfor Recommendation DifTerential Pressure Because the IST requirements originally Instruments specified an instrument range of 4 times the reference values or less, the permanent ne NRC received relief requests to cor,tinue nstruments in many early licensed plants do not using instruments that do not meet either the meet the current requirements of the Code for an range or accuracy requirements of th: Code.

instrument range of 3 times the reference values The Code requires each analog instrument to or less. The NRC does not consider installation have a full-scale range 3 times the reference or replacement of instruments an undue burden,

_value or less, and each digital instrument to be and compliance with the instrument requirements such that the reference values do not exceed 70 in later editions of the Code is not a backfit.

percent of the calibrated range of the instrument.

However, the use of any available instruments The Code requires an accuracy for analog that meet the intent of the Code requirements for instruments of i 2 percent of full-scale, the actual reading would yield an acceptable i 2 percent of total loop accuracy for a level of quality and safety for testing.

combination of instruments, or i 2 percent of reading over the calibrated range for digital This position applies to the early licensed plants instruments.

but not for the purchase of replacement instruments that can be procured to meet the 5.5.1 Range and Accuracy of Analog current requirements of the Code. In Instruments Interpretation XI-1-89-55, for Section XI, the ASME Code committee stated that Section XI, NRC Recommendation IWP-4110, does not allow the acceptable instrument accuracy (Table IWP-4110-1) to be When the range of a permanently installed based on the maximum full-scale range allowed.

analog instrument is greater than 3 times the reference value but the accuracy of the

. instrument is more conservative than the Code, NUREG-1482 5-7 i

l When the licensee submits a relief request, each requirements for digital instrumentation. The group of affected pumps could be addressed licensees have posed questions about the separately if the instruments are permanently definition of a digital instrument. For instance, installed. A general relief request may be if an analog instrument supplies data to a digital acceptable for temporary instrumentation.

display, the instrument should be considered However, the NRC may not approve relief if the digital, though the Code committee could readings will not be equivalent to the Code provide a more detailed definition.

i requirements unless the licensee can demonstrate that the variance is not sufficient for the 5.5.3 Use of Tank or Bay Level to degradation to be overlooked. If the instruments Calculate Differential Pressure do not meet the intent of the Code requirements, the NRC may require the licensee to adjust The NRC received relief requests to use a tank acceptance limits to account for the inaccuracies.

or bay level to calculate differential pressure when inlet pressure and or differential pressure 5.5.2 Range and Accuracy of Digital direct measurement are not available.

Instruments NRC Recommendation NRC Recommendation When inlet pressure gauges are not installed in Subsection IWP of Section XI does not include the inlet of a vertical line shaft pump, it is requirements for digital instruments used to impractical to directly measure inlet pressure for monitor the flow rate and differential pressure of use in determining differential pressure for the pumps. Thus, the requirements in OM4 for pump. The staff has determined that, if the digital instruments apply when using such licensee uses a bay level to calculate the suction instruments for IST. If the requirements cannot (inlet) pressure as described in IWP-4240 or be met, relief could be requested. OM4 paragraph 4.6.2.2 of OM4, the calculation must requires digital instruments to be accurate within be included in the implementing procedure. The i 2 percent over the calibrated range, which licensee must verify that the reading scale for could also be stated as i 2 percent of reading.

measuring the level and the calculational method The Code requires that licensee shall select yield an accuracy within i 2 percent. If direct digital instruments such that the reference value measurements are impractical for other types of does not exceed 70 percent of the calibrated pumps with suction from a tank, the licensee range of the instrument. However, if the must apply similar controls. The Code allows requirements in OM4 are met, the licensee need the licensee to determine differential pressure by not request relief from IWP because the obtaining the information from a differential requirements of OM4 for digital instruments pressure gauge or differential pressure result in greater accuracy than the requirements transmitter, or by determining the difference in IWP.

between the pressure at a point in the inlet pipe and the pressure at a point in the discharge pipe Basisfor Recommendation (IWP-4240 and paragraph 4.6.2.2 of OM4).

Therefore, the licensee may implement a The accuracy of digital instruments is generally calculational method without obtaining relief based on a percentage of the reading displayed.

because the ASME Code allows for the The ranges of most digital instruments can be calculation of the pressure in the pump inlet. To varied, and thus differ from the ranges for implement this guidance, the method must meet analog instruments. The OM committee quality assurance requirements and be included recognized these differences, as indicated in the in a procedure.

requirements of OM4. OM4 states the NUREG-1482 5-8

Basisfor Recommendation Basisfor Recommendation The method is in accordance with a In Inquiries IN 91-3 (paragraph 4.6.1.1 of OM-determination of differential pressure allowed by

6) and IN 91-037 (Table IWP-4110-1 of Section the Code, By including the calculation in XI), the Code committees stated that the implementing procedures, the licensee can requirements for the final indication of flow rate determine the differential pressure in a manner on an analog instrument to be within 2 percent that is consistent and repeatable from test to test.

of full scale of actual process flow rate applies This method will yield the information needed only to the calibration of the instrument and does for monitoring the hydraulic condition of the not take into account attributes such as orifice applicable pumps without the need to install plate tolerances, tap locations, and process suction (inlet) pressure gauges which may not be temperature.

practical, depending on the design limitations in the inlet of the pump.

5.6 Operability Limits of Pumps 5.5.4 Accuracy of the Flow Rate Although IWP-3210 discusses the expansion of Instrument Loop the ranges for pump acceptance criteria, OM4 does not include such a provision. The OM4 As clarified in interpretations to OM4 and Working Group stated that it could not endorse Subsection IWP of Section XI, the accuracy the IWP philosophy in letting the owner specify requirements of analog instruments measuring any acceptance criteria deemed appropriate when process flow apply only to the calibration of the the limits of the applicable table could be met.

instruments. In determining accuracy, the OM4 requires the acceptance criteria to be met.

j licensee is not specifically required to consider There are provisions for the Owner to review the attributes such as orifice plate tolerances, tap test results and, if justified, establish new l

locations, and process temperatures. However, reference values (see paragraph 4.5 of OM4).

factors associated with these attributes which could affect the measurements include the effects NRC Recommendation of wear, the effects of accumulation of dirt or grease on an annubar flow coefficient, and the The staff has determined that licensees with reversed installation of a one-direction orifice programs established to comply with Subsection plate.

IWP may continue to follow IWP-3210 as allowed until the program is updated with the NRC Recommendation values and acceptance criteria from the later edition, or portions thereof. When Subsection The Code requirements for accuracy ensure that IWP-3210 is used, the Code requires that the the instrument loop accuracy is adequate for expanded ranges be documented in the record of monitoring pumps for degrading conditions, tests, also stating the basis for finding that the The accuracy for analog instruments specified in pump performance does not demonstrate Section XI IWP and OM4 applies only to the degrading conditions. Licensees must obtain calibration of the instruments. The staff relief if expanded ranges are needed for plants recommends that, when test results indicate that using OM4. The request for relief must include conditions in the pump or the test circuit have the licensee's basis for the expanded ranges and changed, licensees consider corrective action for the basis for finding that the pump performance other attributes that could affect the overall loop does not demonstrate degrading conditions. ' The accuracy of the measurements, basis for acceptable pump performance, in either case, would pertain to the pump and not the system, though pump performance must meet 59 NUREG-1482

system requirements to remain in an analyzed Basisfor Recommendation condition.

The OM committee eliminated the high " alert" Basisfor Recommendation limits and increased the high " required action" limits because hydraulic performance or pumps in Section XI Interpretation XI-1-79-19, the does not improve. The required actio1 upper i

Code committee clarified the intent of the limits ensure that problems with instrurcents will allowance in IWP-3210 by stating that IWP-3210 not be overlooked.

refers to Table IWP-3100-2 which specifies three ranges: Acceptable Range, Allowable Range, 5.8 Duration of Tests and Required Action Range. He limits within each of these ranges refer to the pump and not to twp.3500, " Duration of Tests," requires that, the system, that is, the ranges are for the pump before measuring specified parameters, the test data. If these ranges cannot be met, the licensee run each pump for at least 5 minutes Owner can specify new range limits for under conditions as stable as the system permits, differential pressure from a range of 0.93 -

Paragraph 5.6, " Duration of Tests," of OM-6 1.02 to a range of 0.89 - 1.03. Using the less requires only 2 minutes of run time with stable conservative ranges, the Code requires the pump conditions before obtaining test data.

owner to show that the overall pump performance has not degraded from its intended NRC Recommendation function.

The staff has determined that the licensee may 5.7 Use of OM-6 Table 3b Ranges follow the requirements of Paragraph 5.6 OM4 for IIydraulic Parameters for the duration of tests if it determines the shorter duration represents stable operation OM-6 contains new limits for test parameters pursuant to 10 CFR 50.55a (f)(4)(iv). If a and no longer includes the upper limits for the licensee elects to use this guidance, the use must

" alert range." The OM committee also increased be documented in the IST program. No related the " required action range" 1.10 times the requirements apply. The NRC recommends not reference value.

operating a pump on minimum recirculation (see NRC Bulletin 88-04, " Potential Safety-Related NRC Recommendation Pump Loss," and Position 9, " Pump Testing Using Minimum-Flow Return Line With or The staff has assessed the use of the new limits Without Flow Measuring Devices," of GL 89-and determined that an acceptable level of 04).

quality and safety is maintained with these new limits, and the new limits are acceptable Basisfor Recommendation pursuant to 10 CFR 50.55a (f)(4)(iv) using the ranges of Table 3b in OM-6 for the IST of The OM committee stated that a 2-minute run pumps, or groups of pumps, in an IST program.

time is adequate after the pump operation The requirements of Paragraph 6.0, " Analyses becomes stable. The staff agrees, particularly and Evaluation," of OM-6 apply. He use of for pumps tested using a minimum flow this guidance must be documented in the IST recirculation line.

program.

NUREG-1482 5-10

6 REVISED STANDARD TECIINICAL SPECIFICATIONS 6.1 Introduction The Bases section of Technical Specification 4.0.5 states, in part, the following:

Section 4 of the technical specifications (TS) for licensed operating power reactors include a This specification ensures that general surveillance requirement for the inservice inspection of ASME Code inservice testing of pumps and valves. Several Class 1,2, and 3 components and licensees have requested revisions to technical inservice testing of ASME Code specifications to remove unique surveillance Class 1,2, and 3 pumps and valves requirements for pumps and valves and to add will be performed in accordance with the general surveillance requirement for IST.

a periodically updated version of Section XI of the ASME Boiler and TS 4.0.5 states, in part, the following:

Pressure Vessel Code and Addenda 4.0.5 Surveillance Requirements for as required by 10 CFR 50.55a.

inservice inspection and testing of Relief from any of the above ASME [American Society of requirements has been provided in Mechanical Engineers] Code Class 1, writing by the Commission and is 2, and 3 components shall be not a part of these Technical applicable as follows:

Specifications.

a. Inservice inspection of ASME 6.2 IIistory Code Class 1,2, and 3 components and inservice testing of ASME Code The regulations for the industry's codes and Class 1,2, and 3 pumps and valves standards are stated in 10 CFR 50.55a. Before shall be performed in accordance March 15,1976, the regulations contained no with Section XI of the ASME Boiler requirements for IST of pumps and valves. The and Pressure Vessel Code and ASME Boiler and Pressure Vessel Code (the applicable Addenda as required by Code) Grst included Subsections IWP and IWV 10 CFR 50, Section 50.55a(g),

to Section XI in the Summer 1973 Addenda.

except where specific written relief The rules effective March 15, 1976 (41 Federal has been granted by the Commission Register 6256, published February 12, 1976),

pursuant to 10 CFR 50, Section required that an operating license for a l

50.55a(g)(6)(i).

utilization facility be subject to the conditions l

speciGed in 10 CFR 50.55a(g), which included NOTE: Effective September 8 new requirements for the IST of pumps and 1992, the requirements for inservice valves. The regulations provided for alternatives testing were moved from paragraph to the requirements if compliance would result in (g) to paragraph (f) in Section hardship without a compensating increase in the 50.55a of Title 10 of the Code of level of quality and safety, or if the proposed Federal Regulations (10 CFR alternatives would give an acceptable level of 50.55a).

quality and safety. The regulations also provided for relief from Code requirements if a The requirements of TS 4.0.5 prchibit licensces licensee determined that conformance was from implementing alternative testing methods impractical for its facility. The regulations described in IST program relief requests before continue to include these provisions.

receiving U.S. Nuclear Regulatory Commission (NRC) approval.

6-1 NUREG-1482

After publishing the rules that took effect March in advance of, but not less than 90 15,1976, the NRC issued letters to licensees days before, the start of the informing them of the rule change and inspection period. Early submittals recommending that they propose technical are particularly important for the specification changes with the following standard first 40-month inservice and 20-statement:

month pump and valve testing period

[ NOTE: This [ testing period] was Inservice testing of ASME Code later changed to 120-month intervals Class 1, Class 2, and Class 3 pumps for both inservice inspection and and valves shall be performed in IST.] because they will enable the accordance with Section XI of the NRC staff to evaluate the ASME Boiler and Pressure Vessel information received from all Code and applicable Addenda as licensees and determine which required by 10 CFR 50.55a(g),

ASME Code requirements may be except where specific written relief generally impractical for various has been granted by the NRC classes of plants. Early submittals pursuant to 10 CFR 50, Section will thereby facilitate earlier 50.55a(g)(6)(i).

feedback to licensees regarding the e

acceptability of their requests.

In letters of November 1976, the NRC further discussed the regulation, which required updates The NRC Staff recognizes that it will of the inservice inspection programs at 40-month not be possible in all cases for a intervals and the IST programs at 20-month licensee to determine in advance that intervals. The NRC suggested that licensees any particular ASME Code submit requests for relief from ASME Code requirement will be impractical for requirements as far in advance as possible of the his facility. In cases where, during start of any 20-month period for testing pumps the process of inservice testing, and valves but at least 90 days before that certain requirements are found to be period. The NRC stressed the need to impractical due to unforeseen incorporate 10 CFR 50.55a(g) by reference in circumstances, the licensee may technical specifications (1) to avoid duplication request relief at that time. Thes.

of requirements, (2) to alleviate the need for occurrences are not expected to be technical specification changes whenever a many and are expected to result in testing program is updated, and (3) to simplify only minor changes to an inservice j

the process for obtaining relief from impractical testing program.

J ASME Code requirements.

All relief from ASME Code The NRC discussed relief requests as follows in requirements that are determined to the letters to licensees:

be impractical for a facility will be -

granted in the form of a letter within Generally, the licensee will know the provisions of $50.55a(g)(6)(i).

well in advance of the beginning of This written relief should be any inspection period, whether or incorporated into the document not a particular ASME Code' describing the inservice inspection requirement will be impractical for and testing program retained by the his facility. Thus, the licensee licensee... the written relief itself -

should request relief from ASME will not become an explicit part of Code requirements as far as possible the facility license...

NUREG-1482 6-2

The NRC approved a change to the TS because

d. The provisions of SR 3.0.3 are TS 4.0.5, as originally proposed, was more applicable to inservice testing restrictive in prohibiting the licensee from activities; and implementing relief for impractical Code requirements before obtaining approval from the

e. Nothing in the ASME Boiler and NRC. The administrative section of the revised Pressure Vessel Code shall be standard technical specifications includes the construed to supersede the following requirements for IST program:

requirements of any TS.

5.7.2.12 Inservice Testing Program 6.3 Discussion This program provides controls for In the 1976 letters to licensees, the NRC staff inservice testing of ASME Code recognized that situations would arise which Class 1,2, and 3 components would put the licensee in a condition that is not including applicable supports. The in strict compliance with the TS 4.0.5 program shall include the following:

requirement to comply with ASME Section XI "except where specific written relief has been

a. Provisions that inservice testing granted." Therefore, if TS 4.0.5 was interpreted of ASME Code Class 1,2, and 3 literally, it would require the licensee to address pumps, valves, and snubbers shall be these situations by shutting down the plant to performed in accordance with perform testing. For example, the TS would Section XI of the ASME Boiler and require a shutdown because a pump or valve that Pressure Vessel Code and applicable would otherwise require IST and that was the Addenda as required by 10 CFR subject of a relief request must.be considered 50.55a; inoperable until the NRC issues a safety evaluation granting relief from the.equirements

b. Testing frequencies specified in of ASME Section XI. This conflict could result Section XI of the ASME Boiler and in the licensee exceed ng a limiting condition for I

Pressure Vessel Code and applicable operation when the component can meet its Addenda as follows:

functional requirements, and is the basis for the change in the revised standard technical AWE Code and spCCifications, applicable Addenda Requ. ired Frequenc.ies terminology for for perforrning in-inservice tening service testing The revised standard technical specifications

• diviti"

'"idi" reflect the position that the licensee must bnIIy establish and implement the program in accord

^

A1 st 3 deys quarteriy or every with 10 CFR 50.55a, which does not require 3 inonths At least once per 92 days that relief requests must be granted before they eN'ry 6 nds are pe ented. Raeer,6e reguladons &w At least once per 184 days Every 9 months At least once per 276 days a licensee up to a fuit year arter the begmning of Yearly or annually At least once per 366 days the updated interval to inform the NRC of those Biennially or every new Code requirements which cannot be met and 2 years At least once per 731 da)s

c. The provisions of SR licensee to submit relief requests within 12

[ surveillance requirement] 3 0.2 are months of the interval start date, or during the applicable to the above reqmred interval as it finds specific needs for relief.

Frequencies for performing i.tservice testing activities; 6-3 NUREG-1482

NRC Recommendation technical specifications cannot be achieved for the period between the time of preparation and The staff recommends that licensees revise their submittal of a relief request up until the NRC TS to incorporate the revised standard technical has issued a safety evaluation and granted the specifications for IST programs. With the relief. This situation could occur at the revised standard technical specifications beginning of a new interval, or throughout an incorporated into its TS, upon finding a Code interval. The risk of a situation developing requirement impractical because of prohibitive where a licensee has implemented testing with a dose rates or limitations in the aesign, relief request based on its assessment of an construction, or system configuration, the impracticality that is later denied by the NRC licensee can implement the relief request at the because of inadequate justification still exists; time it has been (1) approved by the plant staff however, attention to the guidance herein and in according to the administrative process described previous documents can minimize these in the IST program administrative procedure (s),

situations.

(2) reviewed by the plant safety committee, and (3) processed by the plant staff under Basisfor Recommendation 10 CFR 50.59. The licensee should submit the relief request to the NRC within a reasonable When a Code requirement is practical but an time (approximately 2 weeks) after finding the alternate method is requested, approval from the need for relief and completing this approval NRC is required before implementing the alternative method of testing (1) proposed to process.

achieve levels of quality and safety equivalent to Upon determining an impractical requirement, those of the Code method or (2) proposed to the licensee may follow the requirements of avoid an undue hardship without yielding a 10 CFR 50.55a(f)(5)(iii). The specification does compensating increase in the level of quality and not allow the licensee to implement alternative safety. The licensee can use the guidance in testing under paragraphs 50.55a (a)(3)(i) and (ii)

Generic Letter (GL) 89-04 and in Sections 3,4, until the NRC has determined that such and 5 herein when implementing alternatives alterratives are authorized. However, this approved by GL 89-04 or meeting the tecl'nical specification will enable licensees to requirements oflater editions of the Code.

avcid situations where compliance with the NUREG-1482 64

7 IDENTIFICATION OF CODE NONCOMPLIANCE An example of a noncompliance situation is The guidance in GL 91-18 applies to those when a licensee finds, through a design basis situations in which a licensee would be required review, components within the scope of Section to shut down a plant or maintain the plant in that 50.55a of Title 10 of the Code ofFederal mode for an extended period, solely to complete Regulations (10 CFR 50.55a) that must be in the IST in accordance with the requirements of IST program. If these components were not in Section XI of the American Society of the IST program, the technical specifications Mechanical Engineers (ASME) Boller and could be interpretated to require that the licensee Pressure Vessel Code, or of Operations and immediately begin testing to comply with Maintenance Standards Parts 6 and 10 (OM-6 Technical Specification (TS) 4.0.5. The and OM-10). A forced shutdown solely to guidance in Generic Letter (GL) 91-18, perform IST may not be in the best interest of "Information to Licensees Regarding Two NRC safety because it could unnecessarily challenge

[U.S. Nuclear Regulatory Commission) plant systems.

Inspection Manual Sections on Resolution of Degraded and Nonconforming Conditions and on In determining noncompliance with the Code Operability," discusses situations of requirements, details of each specific case are noncompliance with the Code requirements. If considered. If a component has not been testext the plant is operating when a noncompliance is in accordance with the Code requirements, the identified, and if testing at power or during cold licensee may be able to reference other tests in shutdown is impractical, relief or a refueling justifying continued operation if the IST cannot outage justification may be required to perform be performed within the TS limiting conditions the IST during refueling outage conditions. In for operation. The operability of the component the situations which require relief, the licensee could be assessed using the guidance provided in may not be able to obtain NRC approval within GL 91-18 which discusses the need for obtaining the allowable TS action statement time period for a Temporary Waiver of Compliance or exigent components which are subject to limiting relief from the ASME Code requirements.

conditions for operation.

i 7-1 NUREG-1482 i

8 REFERENCES American Society of Mechanical Engineers,Section III, Division 1, Code Case N-442, Boller and Pressure Vessel Code,Section III, "1977 Addendum to ANSI /ASME PTC Division 1, Subsection NC, " Class 2 25.3-1976, Safety and Relief Valves, Class Components," New York,1986, 1,2,3, and MC," February 23, 1987.

t

-- Boller and Pressure Vessel Code, Section Section XI, " Rules for Inservice Inspection III, Division 1, Subsection ND, " Class 3 of Nuclear Power Plant Components,"

Components," New York,1986.

Summer 1973 Addenda through 1989 Edition.

-- Boiler and Pressure Vessel Code, New York Section XI, Subsection IWA, " General Requirements," 1986.

Inquiry IN91-045, "Section XI, IWV-3200; Valve Stroke-Time Test," March Section XI, Subsection IWP, " Inservice 10, 1992.

Testing cf Pumps in Nuclear Power Plants," Summer 1973 Addenda through Inquiry IN92-025A, "Section XI, IWV-1989 Edition.

3410 and IWV-3520; Valve Testing -

Extended Shutdown," February 9,1993.

Section XI, Subsection IWV, " Inservice Testing of Valves in Nuclear Power Inquiry IN92-031, "Section XI, IWA-Plants," Summer 1973 Addenda through 3200; Valve Testing - Adjustment of 1989 Edition.

Packing," August 27,1992.

Section XI, Code Case N-415, Interpretation XI-1-79-19, "Section XI,

" Alternative Rules for Testing Pressure Division 1, Operability Limits of Pumps, Relief Devices," September 5,1985.

IWP-3210," File Number BC-79-150, December 12, 1979.

Section XI, Code Case N-427, " Code Cases in Inspection Plans," December 5, Interpretation XI-1-89-10, "Section XI, 1985.

i Division 1, IWV-3300, IWV-3412, and IWV-3413; Valve Exercising Test," File Section XI, Code Case N-465, Number IN88-015, November 14, 1988.

" Alternative Rules for Pump Testing, 1

November 30,1988.

Interpretation XI-1-89-55, "Section XI, IWP-4110, Table IWP-4110-1, and IWP-Section XI, Code Case N-472, "Use of 4120; Pump Instrument Accuracy," File Digital Readout and Digital Measurement Number IN90-021, January 9,1991.

Devices for Performing Pump Vibration Testing," March 8,1989.

Interpretation XI-1-89-65, "Section XI, IWV-3512 and IWV-3514; Valve Set Point

-- Performance Test Codes, IrrC 25.3-1976, Adjustments," File Number IN90-002,

" Safety and Relief Valves," New York,1976.

January 15, 1991.

8-1 NUREG-1482

American Society of Mechanical Testing," File Number OMI-91-5, March Engineers /American National Standards Institute 24,1992.

(ASMElANSI), Operations and Maintenance Standards, New York,1987.

General Electric, Service Information Ixtter 477,

" Main Steam Isolatio'n Valve Closure,"

-- Operations and MairJenance Standards, December 13, 1988.

New York U. S. Code ofFederal Regulations, Title 10, Pan 1 (OM-1), " Requirements for

" Energy," Chapter 1, Part 50, " Domestic l

Inservice Performance Testing of Nuclear Licensing of Production and Utilization Power Plant Pressure Relief Devices,"

Facilities."

1981 and 1987.

U. S. Nuclear Regulatory Commission, Federal Part 6 (OM-6), " Inservice Testing of Register, Vol. 41, No. 30, " Codes and Pumps in Light-Water Reactor Power Standards for Nuclear Power Plants" (10 CFR Plants," 1988 Addenda and 1989 Addenda.

Part 50), February 12,1976, p. 6256.

Part 10 (OM-10), " Inservice Testing of Federal Register, Vol. 57, No. 3152, Valves in Light-Water Reactor Power

" Codes and Standards for Nuclear Power Plants" Plants," 1988 Addenda.

(10 CFR Pan 50), August 6,1992, p. 34666.

American Society of Mechanical _

--- Generic Evaluation of Feedwater Engineers /American National Standards Institute Transients and Small Break Loss-of-Coolant (ASME/ ANSI), Codefor Operation and Accidents in GE-Designed Operating Plants and Maintenance of Nuclear Pour Plants, New Near-Term Operating Licensee Applications,"

York,1990.

January 1980.

I Interpretation 92-2, "OM-1-1981, Generic Letter 87-09, " Sections 3.0 and Paragraphs 1.3.3.1.5,1.3.4.1.5, and 4.0 of the Standard Technical Specifications l

1.3.1.3; Adjustment of Valve Setpoint --

(STS) on the Applicability of Limiting l

Corrective Action," File Number OMI Conditions for Operation and Surveillance 2, March 24,-1992.

Requirements," May 4,1987.

l Interpretation 92-4, "OM-1-1981,

--- Generic Letter 89-04, " Guidance on L

Paragraphs 8.1.1.9 and 8.1.3.8; Set Developing Acceptable Inservice Testing l

Pressure Testing," File Number OMI Programs," April 3,1989.

3d, March 24,1992.

-- Generic Letter 89-10, " Safety-Related Interpretation 92-5, "OM-1987 With Motor-Operated Valve Testing and Addenda Through OMc-1990, Part 1, Surveillance," June 28,1989.

Paragraphs 1.1.2, 7.1.2.3, 7.2.2.3, 7.3.2.4, and 7.4.2.4; Applicability -

-- Generic Letter 90-06, " Resolution of '

Class 2 and 3 Vacuum Relief Valves," File Generic issue 70, ' Power-Operated Relief Valve Number OMI-91-4, March 24,1992.

and Block Valve Reliability,' and Generic Issue 94, ' Additional Low-Temperature Overpressure Interpretation 92-6, "OM-1987 With Protection for Light-Water Reactors,' Pursuant-Addenda Through OMc-1990, Part 6, to 10 CFR 50.54(f)," June 20,1990.

Paragraph 5.2 and Table 3a,; Pump l

NUF.EG-1482 8-2 1

I Generic Letter 91-18, "Information to

-- Information Notice 91-56, " Potential Licensees Regarding Two NRC Inspection Radioacti_ve Leakage to Tank Vented to Manual Sections on Resolution of Degraded and Atmosphere," September 19, 1991.

Nonconforming Conditions and on Oeprability,"

November 7,1991.

Information Notice 91-74, " Changes in Pressurizer Safety Valve Setpoints Before

-- Information Notice 82-08, " Check Valve Installation," November 25,1991.

Failures on Diesel Generator Engine Cooling Systems," March 26,1982,

" Minutes of the Public Meetings on Generic Letter 89-04," October 25, 1989.

-- Information Notice 83-03, " Check Valve Failures in Raw Water Cooling System of Diesel NRC Inspection Manual (sections published Generators," March 10, 1983.

periodically).

Information Notice 83-54, " Common Mode Inspection Procedure 73756, " Inservice Failure of Main Steam Isolation Nonreturn Testing of Pumps and Valves," March 16, Check Valves," August 11,1983.

1987, i

-- Information Notice 85-84, Inadequate Part 9900, " Technical Guidance -

Inservice Testing of Main Steam Isolation Maintenance - Voluntary Entry into Valves," October 30, 1985.

Limiting Conditions for Operation Action Statements to Perform Preventive Information Notice 86-50, " Inadequate Maintenance," April 18, 1991.

Testing to Detect Failures of Safety-Related Pneumatic Components or Systems," June 18, Temporary Instruction 2515/110, 1992.

" Performance of Safety-Related Check 4

Valves," November 19, 1992.

-- Information Notice 87-01, "RHR [ Residual Heat Removalj Valve Misalignment Causes Temporary Instruction 2515/114, Degradation of ECCS [ Emergency Core Cooling

" Inspection Requirements for Generic System l in PWRs [ Pressurized-Water Reactors),"

Letter 89-04, Acceptable Inservice Testing January 6,1987.

Programs," January 15, 1992.

l

-- Information Notice 88-70, " Check Valve NUREG-0737, " Clarification of TMI Inservice Testing Program Deficiencies," August Action Plan Requirements," November 1980.-

29,1988.

~

-- NUREG-1275, " Operating Experience

-- Information Notice 89-32, " Surveillance Feedback Report - Solenoid-Operated Valve l

Testing of Low-Temperature Overpressure-Problems," Vol. 6, February 1991.

Protection Systems," March 23,1989, NUREG-1350, "NRC Information Digest,"

Information Notice 89-62, " Malfunction of issued annually.

Borg-Warner Pressure Seal Bonnel Check Valves Caused by Vertical Misaligmnent of Disk,"

-- NUREG/CP-Olli, " Proceedings of the l

August 31,1989.

Symposium on Inservice Testing of Pumps and Valves,' October 1990.

1 i

i' 8-3 NUREG-1482

NUREG/CP-0123, " Proceedings of the Regulatory Guide 1.147, " Inservice Second NRC/ASME Symposium on Pump and Inspection Code Case Acceptability - ASME Valve Testing, July 1992.

Section XI Division 1," Revision 10, July 1993.

-- NUREG/CP-0123, " Proceedings of the

" Standard Technical Specifications for Second NRC/ASME Symposium on Pump and General Electric Boiling Water Reactors Valve Testing," Supplement 1, November 1992.

(BWR/5)," Revision 3, Fall 1980.

-- Regulatory Guide 1.26, " Quality Group

-- Supplement to Minutes of the Public Classifications and Standards for Water,

Meetings on Generic Letter 894)4, September Steam, and Radioactive-Waste-Containing 26,1991.

Components of Nuclear Power Plants," Revision 3, February 1976.

I NUREG-148'2 8-4

i I

i APPENDIX A GENERIC LETTER 89-04 POSITIONS AND QUESTIONS AND RESPONSES WITH GUIDANCE ON CURRENT CONSIDERATIONS 1

)

A-1 NUREG-1482

NRC STAFF POSITION 1 FULL FLOW TESTING OF CIIECK VALVES Section XI of the ASME Code requires check (5)

A description of the basis used to verify valves to be exercised to the positions in which that the baseline data has been generated they perform their safety functions. A check when the valve is known to be in good valve's full-stroke to the open position may be working order, such as recent inspection verified by passing the maximum required and maintenance of the valve internal accident condition flow through the valve. This

[ components], and is considered by the staff as an acceptable full-stroke. Any flow rate less than this will be (6)

A description of the basis for the r

considered a partial-stroke exercise. A valid acceptance criteria for the alternative full-stroke exercise by flow requires that the testing and a description of corrective flow through the valve be known. Knowledge actions to be taken if the acceptance of only the total flow through multiple parallel criteria are not met.

lines does not provide verification of flow rates through the individual valves and is not a valid An acceptable alternative to this full-stroke full-stroke exercise.

exercising requirement is stated in position 2 below.

Full flow testing of a check valve as described above may be impractical to perform for certain Questions nnd Answers for Position I valves. It may be possible to qualify other tech-niques to confirm that the valve is exercised to Question Group i the position required to perform its safety function. To substantiate the acceptability of any Questions alternative technique for meeting the ASME Code requirements, licensees must as a Item 1 of Attachment 1 to the generic letter minimum address and document the following requests that flow through a check valve be items in the IST program:

known for a valid full-stroke exercise test. Does this mean a direct flow indication and a recorded (1) The impracticality of performing a full flow rate is [ sic] the only acceptable method for flow test, the test? For example, BWR minimum flow lines are not instrumented with flow indicators.

(2)

A description of the alternative technique used and a summary of the procedures is direct flow rate instrumentation required for being followed, verification of full-stroke capability for all check valves? For example, the diesel cooling water (3)

A description of the method and results of check valves?

the program to qualify the alternative technique for meeting the ASME Code.

Verifying full flow through small check valves in auxiliary systems or gas systems is typically (4)

A description of the instrumentation used impractical. As an alternate, will the NRC and the maintenance and calibration of the accept a qualitative evaluation of system instrumentation, resp (mse or performance in the place of flow measurements?

NUREG-1482 A-2 l

For check valves where design accident flow is throttled to minimize significant diversion of not specified, what guidance can you give for flow. The Technical Specification requirement full-flow testing?

was not intended to verify individual check valve operability. The licensee is expected to justify

Response

the use of a test method that does not verify full f

stroke of individual check valves.

l Any quantitative measure that has acceptance criteria that demonstrate the required flow Current Considerations through the check valve may be used to satisfy the full-stroke requirement. An indirect measure In a safety evaluation of January 24,1992 of flow may be acceptable. For example, a (Docket 50-334), the NRC informed the change in tank level over a specified period Duquesne Light Company of the results of an could be used. In another case, the acceptance evaluation of flow through parallel lines and criterion could be based on a change in flow rate stated a flow test through parallel lines without of an instrumented line when flow is admitted individual flow measurement may not be from a non-instrumented line containing the sufficient to indicate that the check valves in the check valve being tested. In any event, some lines are full-stroke cxercised. (See Section form of quantitative criteria should be 4.1.2).

established to demonstrate full-stroke capability.

Question Group 3 Question Group 2 Questions

\\

Questions Can check valves with exteinal operators and Why isn't knowledge of total flow through position indicators be testea only with these multiple parallel lines acceptable, when the total devices and never exercisa! with flow or flow through each path was known when it was disassembled?

established?

Is it the intent of the NRC to require full-stroke Regarding full flow testing of checs valves, why flow testing of all check valves or is it is knowledge of total flow through parallel flow acceptable to perform manual exercising and lines unacceptable? This seems to challenge panial stroke testing of check valves as conservative Technical Specification permitted by IWV-3522(b)7 requirements for flow balancing.

Position 1 implies that the only method

Response

acceptable to the NRC for full stroke exercising is a full flow test. No mention is made of check The objective of inser see testing is to evaluate valves with external features which can be used; and investigate the possibility of degradation of for full stroke exercising. Do the 6 criteria components and to take corrective act on e ore presented have to be addressed in the IST i

bf the components fail. Verification of total header program to justify using an external operator?

flow rate might not identify a problem, developing or occurring, with an individual

Response

check valve in one of the parallel flow paths.

With respect to the balancing of flow, the Tech-The ASME Code in IWV-3522(b) allows full nical Specification requirement is based on the stroke testing of check valves either with flow or flow from 'one loop being lost through a break.

with a mechanical exerciser. Full flow testing is Consequently, that flow path is restricted or preferable where practical, but Position 1 of A-3 NUREG-1482

I Generic Letter 89-04 was not intended to imply associated acceptance criteria) as per IWV-that the ASME Code provisions for mechanical 3522(b)?

exercising were not acceptable. Such mechanical exercising is clearly acceptable and is

Response

certainly preferable to valve disassembly as a means of ensuring valve operability. If an The ASME Code does not require the external operator is used to exercise a check measurement of valve differential pressure when valve, the provisions of IWV-3522(b) must be exercising check valves with flow. It should be met, but the six criteria in Position 1 of the recognized, however, that such a measurement generic letter need not be addressed.

might provide useful information for evaluating the condition of the valve.

Current Considerations Current Considerations Paragraph 4.3.2.4(b) of OM-10 addresses the use of mechanical exercisers for check valves.

Certain test methods for verifying the full-stroke (See Section 4.1).

of check valves necessarily involve measurement of both the flow and differential pressure across Question Group 4 a valve. (See Section 4.1).

Questions Question Groep o What is considered the maximum required Question accident condition flow?

For check valves which are never required to

)

in reference to items I and 2 of Attachment 1, open fully (i.e., thermal expansion or siphon please clarify the term " maximum required breakers), verification of design (safety) function accident condition flow."

is the testing required for forward flow. Is this correct?

i

Response

Response The phrase " maximum required accident condition flow" is intended to mean at least the In addition to verifying its safety function largest flow rate for which credit is taken in a performance, quantifiable acceptance criteria safety analysis for this component in any flow should be developed for the testing of thue configuration. The safety analyses are those components. For example, a pressure decay test contained in the plant's final safety analysis with specified acceptance criteria would be report (FS AR), or equivalent, but are not limited considered a reasonable test.

to the accident and transient analyses.

Current Considerations Question Group 5 Verifying that the system is full is also an Question acceptable means for verifying that the keep-fill Is it the intent of the stated position of_

check valves are capable of opening to provide flow when necessary. (See Section 4.1.1).

Attachment I that a satisfactory test of a valve in the open direction requires only measurement of full accident flow through the valve and not the measurement of differential pressure (with NUREG-1482 A-4 l

I i

Question Group 7 that the check valve is exercised to the position required to perform its safety function. One of Questions the stated conditions for this approach is that the licensee should describe the test method and In reference to Item I of Attachment 1, for non-results of the program to qualify the alternate parallel full flow test, does the flow obtained technique for meeting the ASME Code. The need to be documented quantitatively, or can it language of Position 1 in this regard was chosen be qualitative (i.e., greater than gallons to allow the licensees flexibility in qualifying per minute)?

alternatives to full flow teting. In general, the licensee should demonstrate that the alternate test t

What is an acceptable flow condition when, for is quantifiable and repeatab'e. The alternate test example, the safety analysis requires 250 gallons should also meet the intent of the ASME Code.

per minute (gpm) flow but 600 gpm can be This qualification of the alternate test should be delivered? Would passing greater than, or equal documented by the licensee and available for to,250 gpm be a valid full flow test, or would review by NRC inspectors. The Nuclear 600 gpm need to be delivered?

Industry Check Valve Group (NIC) is said to be investigating the qualification of various testing

Response

techniques, such as ultrasonics and radiography for check valves. The results of those and other The full flow test is intended to demonstrate that industry efforts might be of value to the the necessary flow rate can be achieved and to individual licensee in providing for the use of detect any degradation of the check valve.

alternatives to full flow testing.

Therefore, acceptance criteria for the test should involve more than the achievement of flow Current Considerations for Position 1 above a minimum rate. The acceptance criteria should also include the allowable variation of The guidance established for Position I remains test results. To enable that test results to be valid for inservice testing. However, with the 7

compared, the initial parameters for the test progress made in developing and using l

should be standardized to the maximum extent nonintrusive testing techniques, the staff feasible. The acceptance criteria for the full recommends that licensees investigate and flow test and the bases for those criteria should employ these techniques where practical. The be documented and available for review by NRC criteria listed in Position I could be applied to inspectors.

the nonintrusive techniques. Further guidance and requirements for the use of nonintrusive Question Group 8 techniques are being incorporated into the OM codes and standards by the OM-22 Working Question Group on check valves. (See Section 4.1).

-l l-l In reference to item 1.3 of Attachment 1, please clarify what the NRC would expect a

" qualification program" to include (i.e., how extensive).

Response

Position 1 of Generic Letter 89-04 indicates that,-

where full flow testing is impractical, it might be possible to qualify other techniques to confirm

. A-5 NUREG-1482

i NRC STAFF POSITION 2 ALTERNATIVE TO FULL-FLOW TESTING OF CIIECK VALVES The most common method to full-stroke evercise (c)

Where the licensee determines that it it a check valve open (where disk position is not burdensome to disassemble and inspect all observabic) is to pass the maximum required applicable valves each refueling outage, a accident flow through the valve. However, for sample disassembly and inspection plan for some check valves, liceasees crenot practically groups of identical vakes in similar establish or verify sufficMnt flow to full-stroke applications may be employed. The NRC exercise the valves open. Some examples of guidelines for this plan are explained such valves are, in PWRs, the containment spray below:

header check valves and combined LPSI [ low pressure safety injectionj and safety injection The sample disassembly and e

accumulator header check valves and, in BWRs, inspection program involves the HPCI or RCIC check valves in the pump grouping similar valves and testing suction from the suppression pool. In most one valve in each group during each commercial facilities, establishing design refueling outage. The sampling accident flow through these valves for testing technique requires that each vehe in could result in damage to major plant equipment.

the group be the same design (manufacturer, size, model number, The NRC staff position is that valve disassembly and materials of construction) and and inspection can be used as a positive means have the same service conditions of determining that a valve's disk will full-stroke including valve orientation.

exercise open or of verifying closure capability, Additionally, at each disassembly the as permitted by IWV-3522. If possible, partial licensee must verify that the dis-valve stroking quarterly or during cold assembled valve is capable of full-shutdowns, or after reassembly must be stroking and that the internals of the performed.

valve are structurally sound (no loose or corroded parts). Also, if The staff has established the following positions the disassembly is to verify the full-regarding testing check valves by disassembly:

stroke capability of the valve, the disk should be manually exercised.

(a)

During valve testing by disassembly, the valve internals should be visually inspected A different valve of each group is for worn or corroded parts, and the valve required to be disassembled, disk should be manually exercised.

inspected, and manually full-stroke exercised at each successive refueling (b)

Due to the scope of this testing, the outage, until the entire group has personnel hazards involved and system been tested. If the disassembled operating restrictions, valve disassembly valve is not capable of being full-and inspection may be performed during stroke exercised er there is binding reactor refueling outages. Since this fre-or failure of valve internals, the quency differs from the Code required remaining valves in that group must frequency, this deviation must be also be disassembled, inspected, and specifically noted in the IST program.-

manually full-stroke exercised during the same ou; age. Once this is NUREG-1482 A-6

1 completed, the sequence of (b)

A review of industry experience, for disassembly must be repeated unless example, as documented in NPRDS, extension of the interval can be regarding the same type of valve used in justified.

similar service.

Extending the valve sample disassembly and (c)

A review of the installation of each valve inspection interval from disassembly of one addressing the "EPRI Applications valve in the group every refueling outage or Guidelines for Check Valves in Nuclear expanding the group size would increase the Power Plants" for problematic locations.

time between testing of any particular valve in the group. With four valves in a group and an Questions and Answers for Position 2 18-month reactor cycle, each valve would be disassembled and inspected every six years. If Question Group 9 the fuel cycle is increased to 24 months, each valve in a four-valve sample group would be Question disassembled and inspected only once every 8 years.

Does the Generic Letter Attachment 1, item 2c use of " orientation" refer to physical orientation Extension of the valve disassembly / inspection (e.g., horizontal or vertical) or plant orientation?

interval from that allowed by the Code (quarterly or cold shutdown frequency) to longer than once

Response

every 6 years is a substantial change which may not be justified by the valve failure rate data for Orientation, as used in Generic Letter 89-04, all valve groupings. When disassembly /

refers to the physical orientation (horizontal or inspection data for a valve group show a greater vertical) as well as the physical relationship to than 25% failure rate, the licensee should major components. For example, a check valve determine whether the group size should be at the discharge of a pump has a different decreased or whether more valves from the orientation than one at the pump suction, 4

group should be disassembled during every refueling outage.

Question Group 10 Extension of the valve disassembly / inspection

' Guestions interval to one valve every other refueling outage or expansion of the group size above four When manually exercising per position 2c, is valves should only be considered in cases of this done per Code or just a physical stroke extreme hardship where the extension is checking for binding?

supported by actual in-plant data from previous testing. In order to support extension of the When valves are disassembled and manually valve aisassembly/ inspection intervals to longer exercised in lieu of full-flow testing, is than once every 6 ye licensees should adherence to the quantitative aspects and -

i l

develop tha foibwing ictormation:

acceptance criteria ofiWV-3522(b) required?

(a)' Duary% tad inspect each valve in the

Response

valve gwuping and document in deuil the condition of each valve and the valve's The staff believes the requirement in IWV-3522 i

capability to be full-stroked.-

(b) of the ASME Code to measure the force or torque while manually exercising check valves only applies to manual exercising from outside A-7 NUREG-1482

1 the valve where the observation of the valve stroke testing with flow, the licensee should internals cannot be made. This measurement periodically evaluate whether plant conditions permits a quantitative evaluation of the have been altered in such a way that full stroke performance of the valve in that changes in the testing using flow is possible. If so, the licensee measured force or torque may be indicative of should revise the test procedures to provide for degradation of the valve internals. While the such testing.

valve is in a partially disassembled condition the valve internals should be inspected and the Current Considerations condition of the moving parts evaluated This 3

inspection and evaluation should include This response remains valid, even though OM-verification by hand that the valve disk is free to 10 allows for disassembly and inspection as an move, but measurement of force or torque is not alternative to tests. Disassembly and inspection required. Following reassembly, a partial flow is a maintenance activity that could be part of an test is expected to be performed.

overall program for check valves, but testing is preferred for meeting IST requirements. (See Current Considerations Paragraph 4.3.2.4(c) of OM-10).

Paragraphs 4.3.2.4(b) and (c) of OM-10 clearly Question Group 12 divide the disassembly and inspection from manual exerciser use. (See OM-10).

Question Question Group 11 In light of the stated position of requiring check valve internal inspection at least once every six Questions years, is it permissible to schedule the inspections for the total group of valves on a six Does the utility have the option of either year frequency vs. each refuel outage? This is inspection through disassembly or performing especially important where plant preparations for functional testing to satisfy IST requirements?

inspection of multiple valves are essentially Can either be used regardless of the previous equal to those for a single valve and they repre-testing mode?

sent a considerable cost in terms of monetary outlay as well as schedule and availability-

Response

impacts.

Disassembly, together with inspection, to verify

Response

full stroke capability of check valves is an option only where full stroke exercising cannot Position 2 of Generic Letter 89-04 takes practically be performed by flow or by the other advantage of the benefits that can be obtained positive means allowed by IWV-3522. Addi-through dampling techniques. The NRC staff, tionally, partial stroke exercise testing with flow however, recognizes that the position may have a is expected to be performed after the significant impact on outage time. For example,

' disassembly and inspection is completed but some plants have combined injection header before returning the valve to service. If the check valves that are physically located in a -

previous test was performed using flow, the position relative to the reactor coolant system licensee is expected to document the justification (RCS) loops such that their disassembly would for any change from that test method. ~ Also, for require draining the RCS to a level that would.

the case where plant conditions prevent full necessitate core offload. - In order to alter the NUREG-1482 A-8

inspection frequency as suggested by this that have not formally committed to following question, lice tsees should use the criteria in Regulatory Guide 1.58 to review the ANSI Posit!an 2 tc justify and to document the standard and regulatory guide for guidance in proposed disassembly schedule. The justification developing a program foi the qualification of should address the significance of the loss of inservice testing personnel benefits of sampling in light of the condition, service history, and application of the valves.

Current Considerations For additional discussion of this issue, see the response to Question 19.

The staff recommends that the data sheet for recording the results of the inspection include a Question Group 13 determination if the valve internal conditions are acceptable. (See ParOraph 6 of OM-10).

Questions Question Group 14 Does disassembly / inspection require certified visual testing personnel, or can detailed Question inspection procedures be performed by maintenance personnel without certified If a check valve within a sample group is inspectors?

disassembled / inspected in a non-refueling outage, does the next valve need to be inspected i

Do personnel performing the visual inspections at the next refueling outage, or can it still be addressed on Position 2 have to be VT-3 scheduled for its original refueling outage?

certified, ANSI 45.2.6 (i.e., Mechanical Inspector) certified, or may engineering

Response

personnel competent in check valve technique requirements perform this visual inspection?

This question is difficult to answer without more j

detailed information. In general, in order to

Response

alter the disassembly / inspection schedule as suggested by the question, the licensee should The personnel performing the justify and document the proposed change. The disassembly / inspection must be qualified to justification should address the effect of the evaluate the condition of the valve and to assess proposed disassembly! inspection schedule on the

)

its continued operability. The licensee is sampling program. Thejustification should rely responsible for the developmut and on the maintenance history and known valve implementation of a program to escare that IST condition from previous inspections rather than personnel are appropriately trained and qualified subjective qualitative judgement. Position 2 in for performing the valve Generic Letter 89-04 indicates the criteria that disassembly / inspections. Generic Letter 89 need to be addressed.

alone does not impose any requirementr, for visual testing certifications (such as VT-3)

Current Considerations beyond those currently in the ASME Code.

Nevertheless, licensees must implement the If it is practical to disassemble and inspect the provisions of ANSI /ASME N45.2.6, selected valves at a frequen;y not determined by

" Qualifications of Inspection, Examination, and refueling outages, the licensee may establish a Testing Personnel for Nuclear Power Plants,"

schedule for these valves that does not conform according to their commitments based on the to a refueling outage schedule. ' However, implementation section of Regulatory Guide because disassembly and inspection is a 1.58. The NRC staff encourages those licensees maintenance activity and not a " surveillance,"

A9 NUREG-1482

1 t

entry into an LCO to perform the activity may and hispection involved the identification of not be acceptable (See Section 3.1.2).

broke bolting material in Anchor Darling check valves at two nuclear power plants. This Question Group 15 occurrence is discussed in NRC Information Notice 88-85, dated October 14, 1988.

Question The NRC staff is encouraging the development is it the intent of Position 2 of the Generic Letter and use of alternate techniques to evaluate the 89-04 that during valve testing by disassembly, position of check valve disks. The Electric that the valve be completely disassembled and Power Research Institute (EPRI) and the Institute each internal valve part removed, if possible, of Nuclear Power Operations (INPO) are and 100% of the part visually inspected, or may recommending an inspection periodically for only the valve bonnet be removed and the valve check valves that are subjected to potentially internals inspected in place without the removal harsh service conditions. The NRC staff of the internal valve parts unless evidence of encourages these activities as well. The industry discrepant conditions are found which then group NIC is also investigating methods to would require further inspection and probable demonstrate the operability of check valves.

removal of the part? Note: Inspection of the valve internal parts without removal of the part Current Consideratior.s would be by direct visual inspection, use of mirrors, or by remote inspection equipment such Refer to NRC information Notice 89-62, as boroscope fiberoptics.

" Malfunction of Borg-Warnter Pressure Seal Bonnet Check Valves Caused by Vertical

Response

Misalignment of Disk," for an example of a valve disk installation problem.

When performing check valve disassembly and inspection to satisfy the requirements of the Question Group 16 ASME Code for inservice testing, disassembly is required only as far as necessary to assess the Questions

~;

condition of the valve and to allow manual exercising of the disk. (It must be recognized, Even though the check valve flow testing can be however, that the Code requirements for performed as required by ASME Section XI,-

inservice inspection are different from those may the valve test be performed by disassembly associated with inservice testing.) If a partial as permitted by Position 2 in Generic Letter 89-stroke exercise with flow can be performed, this 04 when it is considered by the utility that testing is expected to be performed after the testing by disassembly will provide the same or disassembly and inspection are completed but greater assurance that the valve will function before returning the valve to service.

properly? (Note: If possible, partial valve :

stroking quarterly, or at cold shutdown, or after Disassembly and inspection of a check valve is re-assembly would be performed.) If the answer not considered a " test" as implied by the is yes, (a) can the test frequency, sample, etc.,

question. Disassembly is not a true substitute as described in Generic Letter 89-04 Position 2 for an operability test using flow, but is allowed be used in lieu of ASME Section XI as an alternative to a flow test where that test is requirement-even if the Section XI test could be not practical. Disassembly and inspection does, performed, i.e., at cold shutdown; (b) must a however, provide a valuable means of relief request be processed or may this " test by determining the internal condition of the valve, disassembly" be noted in the valve IST program A recent example of the value of disassembly submittal to the NRC; and (c) must a relief NUREG-1482 -

A-10

)

1 request be processed or may the frequency Letter 89-04 he applied to reverse flow testing of sample, etc., be noted in the valve IST program check valves 7 submittal to the NRC7

Response

Response Position 2 of Generic Letter 89-04 addresses the The various methods aimed at evaluating the use of disassembly and inspection as an operability of check valves are not equally alternative to forward flow testing of check acceptable to the NRC staff. At the outset, the valves. The use of disassembly and inspection ASME Code requires a full stroke exercise using to verify closure capability (i.e., back flow) may flow (or a mechanical exerciser) to be performed be found to be acceptable depending on whether quarterly. Where full stroke exercising cannot verification by flow or pressure measurements is be performed quarterly, the Code allows the practical. As the generic letter d3es not address performance of this test during cold shutdowns.

this use, however, the submission and approval Full stroke exercising during refueling outages of a relief request before implementation is i

may be an acceptable alternative if the test required. Disassembly and inspection is not cannot be performed at cold shutdown, but this acceptable for demonstration of leak-tight approach would require submission of a relief integrity.

request. For those cases where full stroke exercising cannot be performed quarterly, during Current Considerations cold shutdown, or during refueling outages, disassembly and inspection in conformance with In Position 2, the NRC stated that disassembly Position 2 of Generic ictter 8944 is allowed as and inspection could be acceptable for closure an alternative. If the provisions of Position 2 verification. The response to Question 17 are followed, a relief request need not be caused confusion as to whether relief is required, submitted for NRC review but this deviation or the approval granted in GL 8944 is from the ASME Code should be documented, acceptable for using Position 2 in verifying (See also the response to Question 15).

closure. The staff determined that Position 2 is acceptable for closure verification when no other -

Current Considerations means is practical. If the check valve includes a bonnet-hung disk, the staff recommends that the A relief request is no longer required for -

procedures include enhanced requirements for deferral of testing to refueling outages.

maintenance and quality control to ensure that However, if testing can be practically the disk is properly oriented when it is performed, but specific situations occur that.

reinstalled. Nonintrusive methods such as could cause delays or other problems during radiography or acoustics may be used as an refueling outages making a test burdensome, the.

alternate method to verify closure. (See Section L

licensee may request relief from performing 4.1).

I disassembly and inspection during that one j

refueling outage. (See Section 3.1.1).

Question Group 18 Question Group 17 Guestion Question We are only able to perform a partial flow ~ test of the accumulator discharge check valves due to May the valve testing by disassembly / visual limitations based on system configuration. Do inspection identified in Position 2 of Generic we have to supplement this test with disassembly of the check valves?

i A-11 NUREG-1482

valves at some plants, or to operate at mid-level

Response

of the reactor coolant loops may be considered.

The safety injection accumulator discharge check The radiation exposure that would result from valve:i are typically very difficult to exercise the disassembly and inspection is a factor to be with f ow to the position required to perform considered under the ALARA (As Low As their safety function. If a partial flow exercise is Reasonably Achievable) princip?e, but it should all that can be performed, then some other be judged in combination with all of the other technique, as discussed in Position 1 of Generic factors.

Letter 8944, might be developed to periodically verify the capability of these valves to move to Current Considerations their safety function position. If this is not feasible, the licensee is expected to follow the A one-time extension may also be acceptable if provisions for the disassembly alternative unique or unanticipated activities during an contained in Position 2 of the generic letter.

outage prevent the plant staff from disassembling and inspecting the valves. For example, if Currer> Considerations outage activities preclude draining the refueling water storage tank (RWST), which is necessary Tests performed involving nonintrusive to disassemble a check valve, a one-time techniques and tests that measure flow and extension may be warranted. Such extensions differential pressure may be acceptable at less may be documented under the provisions of GL than full-flow. (See Section 4.1.2).

8944 and further NRC approval is not required.

(See Position 2 above regarding extension of the Qutstion Group 19 interval).

Question Question Group 20 h

Regarding disassembly of check valves, please Questions define " extreme hardship" when speaking with regard to extension of disassembly interval.

Position 2 goes into the scheduling of disassembly / inspection in a very detailed

Response

manner. Arc other scheduling schemes acceptable as long as they have each valve The existence of " extreme hardship" that would disassembled / inspected within 6 years? Would allow extension of the disassembly schedule in approval of an alternate schedule have to be in Position 2 of Generic Letter 89-04 is dependent the form of an SER [ safety evaluation report] or on the particular circumstances at the plant. To acceptance of details provided in a confirmation determine whether extreme hardship exists, the letter (existing schedule for disassembly /

licensee should conduct a detailed evaluation of inspection agreed upon in IST program review the various competing factors. First, the with NRC, but SER never issued)?

licensee should determine the effect on plant safety that would result from the proposed

Response

schedule extension. The maintenance history of the component and other information relevant to As stated in Position 2 of Generic Letter 89-04, its reliability should be reviewed to determine the burden is on the licensee to demonstrate the whether the decrease in assurance of plant safety extreme hardship necessary to comply with the resulting from the schedule extension is justified.

identified sample disassembly / inspection A need to offload the reactor core, such as when _

schedule. The staff considers the sampling testing the combined injection header check aspect of the position to provide assurance of the NUREG-1482 A-12 a

=

l continued operability of the valves that are not Current Considerations for Position 2 inspected during any given outage. Therefore, the licensee should justify through the provisions The staff has determined that the use of Position listed in Position 2, any deviation from the stated 2 is acceptable for verifying the capability of scheduled, That justification should be provided valves both to open and to close. The response in the IST program submitted to the NRC staff, to Question 17 contradicted the statements in but need not be included in the confirmation Position 2. Paragraph 4.3.2.4(c) of OM-10 letter. Where the provisions of Position 2 for an allows that "[als an alternative to the testing I

alternate disassembly schedule are followed, it is

[ exercising in accordance with paragraph 4.3.2.4 acceptable to implement the alternative and an (a) and (b)], disassembly every refueling outage SER will not be issued. The NRC staff, to verify operability of check valves may be however, may review the alternative and its used." (See Section 4.1 for discussion on check justification during plant inspections, valves).

i i

i P

V f

4 4

A-13 NUREG-1482 -

NRC STAFF POSITION 3 BACK FLOW TESTING OF CIIECK VALVES Position 3 Questions and Answers for Position 3 Section XI requires that Category C check valves Question Group 21 (valves that are self actuated in response to a system characteristic) performing a safety func-Question 1

tion in the closed position to prevent reversed flow be tested in a manner that proves that the With reference to generic letter item 3, if a leak disk travels to the seat promptly on cessation or test is performed to verify Category C check reversal of flow. In addition, for category A/C valve seat position, would any leak rate be check valves (valves that have a specified leak acceptable so long as the system meets its rate limit and are self actuated in response to a minimum requirements to perform its safety system characteristic), seat leakage must be function?

limited to a specific maximum amount in the closed position for fulfillment of their function.

Response

Verification that a Category C valve is in the closed position can be done by visual When performing a teot to verify closure observation, by an electrical signal initiated by a capability of a check valve that does not have a position-indicating device, by observation of defined seat leakage limit, the achievement of appropriate pressure indication in the system, by the necessary system flow rate through the leak testing, or by other positive means.

intended flow path might be an adequate demonstration of the closure capability of a Examples of ASME Code Class check valves check valve. For example, when verifying the that perform a safety function in the closed closure capability of the check valves on the position that are frequently not back flow tested discharge of parallel pumps, achievement of the are:

required safcty flow rate from one running pump with the idle pump's discharge check valve (a) main feedwater header check valves providing the barrier for recirculation flow would be considered an acceptable test (b) pump discharge check valves on parallel configuration. In addition, the licensee should pumps evaluate the consequences of the back flow through the check valve. This evaluation should (c) keep full check valves consider the loss of water from that system and connecting systems, the effect that the leakage (d) check valves in steam supply lines to might have on components and piping turbine driven AFW pumps downstream of the valve, and any increase in radiological exposure resulting from the leakage.

(e) main steam non-return valves Current Considerations (O

CVCS volume control tank outlet check valves A plant's safety analysis may include a leakage limit for a particular valve, or only require that the valve closes to inhibit gross leakage. When a valve has a safety-related function to close to NUREG-1482 A-14

=

prevent diversion of flow between trains of a 10 CFR 50, Appendix J, Type C, tested valves?

system, there may be a leakage limit based on Tech Specs specify only penetration totals, the total system requirements. The Code does not specifically require that these valves be

Response

Category A. The basis for assigning valves to categories should be available for inspection.

IWV-3426 of Section XI of the ASME Code requires that a permissible leak ate be specified Question Group 22 by the plant owner (licensee) for a specific valve. If leak rates are not specified by the Questions licensee, permissible leak rates are provided in IWV-3426. It should be noted that Section XI Are the items listed in Attachment 1. number 3a, provides no criteria or guidance for licensees on d, e, f, specific to PWR's? The nomenclature is the method to establish or to specify the permis-i not familiar to BWRs.

sible leak rate of a particular valve. Apparently, the Code recognizes that leak behavior of a Section 3 of Generic Letter 89-04 deals with valve varies according to the type of valve, the back flow testing of check valves. It has a list vendor, the valve size, the service conditions, of several valves that NRC states provide a the safety-related functions, and other factors, safety function. Some of these valves do not and that there is no simple leak rate rule that appear to provide a safety function and we may be applicable to all valves, would like to hear the NRC's reason for classifying these valves as safety related.

In general, the leak rate limits should be set within certain bounds. If the leak limits are too

Response

low, unnecessary repairs or adjustments to the valve can result. If too high, failure of the tests All of the listed systems do not necessarily apply required by Appendix J to-10 CFR Part 50 could to each plant. A licensee should evaluate at least occur, leadin; to concerns for leak-tight integrity the listed systems to determine if they apply to of the containment. Appropriate permissible its facility and should make any necessary leak rates can only be developed and refined by modifications to its IST program, in regard to a analyzing and trending the leak rate data of particular question, items 3d, e, and f are specific valves or leak m.te data from similar specific to pressurized water reactors (PWRs) valves at other plants, fherefore, the NRC staff while 3a (feedwater header check valves) may is not in a position to specify leak rates. The be applicable to both boiling water reactors licensee should document its methods for (BWRs) and PWRs. One example provided in establishing the initial permissible leak rates and Position 3 to the generic letter is the volume procedures for improving the leak rate limits, control tank outlet check valve in the chemical and volume control system. This check valve Current Considerations may serve an important safety function at some PWR plants to separate the non-safety grade Refer to Section 4.4.3, " Multiple Containment water source from the safety grade source.

Isolation Valve Leak-Rate Testing" herein.

Question Group 23 Question Group 24 Question Questions In regard to Attachment [1], Position 3, how is In regard to Attachment 1, Position 3, does this individual seat leakage determined for backseat check require a full-stroke exercise and A-15 NUREG-1482

~

is it performed at the Code specified frequency Question Group 25

[

regardless of normal plant positions?

Question in reference to item 3 of Attachment 1, does a valid back-flow test on a check valve first Previous to this, it was permissible to verify require the valve to be exercised to the open closure of stop-check valves simply by operation position then back tested, or is it valid to merely of the stem (shaft), is this acceptable instead of perform the back flow test?

reverse flow testing?

Response

Response if a particular valve performs a safety function Verification of closure capability of stop check only in the closed position, demonstration of a valves by using the handwheel meets the ASME full-stroke open before verification of closure Code requirements. This, however, is not the capability is not required by the ASME Code.

preferred method of test. The NRC staff This closure verification is required to be considers reverse flow testing to be a more performed at the frequency.specified by the reliable indication of valve operability.

Code. If (1) the valve performs a safety function in the closed position, (2) the normal Modified Response position for the valve is closed, and (3) this position can be verified during normal plant This response was modified in Revision 1 to the operation, then quarterly documentation of this minutes, September 26,1991, as follows:

verification satisfies the Code requirements. If a valve performs a safety function in both the open (a)

If the stop-check valves do not and closed positions, however, the Code requires perform _a safety-related function in that the valve be exercised to the open position the closed position, valve closure is and then be verified to close.

only necessary to ensure repeatable opening stroke time testing. Valves Current Considemtions may be closed by using a handwheel or a hand switch.

If the verification of closure is practical more frequently, such as quarterly, the verification can (b)

If the use of a handwheel or a hand be performed without opening the valve, and the switch to close a valve achieves the valves can then be exercised open on an safety-related function of the system, extended frequency such as at each cold then exercising the valve' by this shutdown or refueling outage. Plant conditions method meets the ASME Code during post-maintenance testing may prevent the requirements of IWV-3522.

licensee from partially or fully stroking a valve open after reassembling it. If the disk was (c)

If a prompt closure of these valves stroked or removed, a leak test may verify that on cessation or reversal of flow is the valve can close properly. A post-required to accomplish a safety-maintenance open stroke exercise may be related function closure must be performed to restore a valve to service with the verified by reverse flow testing or verification of closure performed when plant such other positive means as acoustic conditions allow. (See Section 4.1.3; also see monitoring or radiography.

Paragraph 4.3.2.2(a) of OM-10).'

(d)

These valves should be disassembled for verifying valve closure when no NUREG-1482 A-16

.... ~.

other means of verification is

Response

possible. However, disassembly provides limited information on The majority of the wording in the sentence in valve capability to seat promptly on which this particular phrase appears was taken cessation or reversal of flow.

directly from IWV-3522 of Section XI of the Furthermore, if the method involves ASME Code. The NRC staff included the extensive disassembly, a post-phrase "by other positive means" to be consistent reassembly test would be necessary with the wording of the Code. When Generic per IWV-3200 because disassembly Letter 89-04 was written, the staff did not have and inspection can increase the in mind any particular techniques that it would probability of human error when the consider acceptable, valve is reassembled. The licensee should investigate the use of Current Considemtions nonintrusive testing techniques and should implement them if they are Paragraph 4.3.2.4 of OM-10 allows for other demonstrated to be effective to assess positive methods of verification. Recent closure capability, degradation, and examples from inservice testing programs incipient failure. The infrequent include verifying that a parallel centrifugal pump disassembly and inspection of the does not spin in reverse to verify closure of a valves are appropriate to assess pump discharge check valve, monitoring an overall check valve condition, while upstream pressure indicator, monitoring a tank reverse flow testing and nonintrusive level, measuring the flow rate of a redundant testing provide an assessment of train, and opening an upstream vent and drain continued operational readiness.

valve.

This guidance expands on the response provided Current Considerations for Posillon 3 in the meeting minutes. The staff's response contained in the meeting minutes did not address Licensees may refer to NRC Information Notice instances in which verification of prompt closure 91-56, " Potential Radioactive Leakage to Tank was required to ensule that a safety-related Vented to Atmosphere," for information on the function would be accomplished.

categories assigned to of valves which function to close. These valves may also function to if the valve can be stroked open and then prevent leakage above an assumed limit to verified to seat promptly on cessation or reversal prevent the plant from exceeding the limits in 10 of flow only at an extended interval, the use of a CFR Part 100. Position 4.1.1 herein discusses hand wheel or hand switch on a quarterly backflow testing of check valves in series.

frequency may be part of the program in concert with the other testing, if practical.

The staff has received relief requests for backflow testing in which licensees interpret the Question Group 26 requirements such that a forward flow test is required before the verification of closure (i.e.,

Guestion '

perform the forward flow test before the backflow test). _ However, if plant conditions Regarding back flow testing of check valves, make a forward flow test impractical quarterly, what is the position of the generic letter in the or during cold shutdown outages, the licensee phrase " verify by other means"?

may practically verify closure without testing the forward flow. When leak-tightness is not required, backflow testing can be performed by 1

NUREG-1482 A-17.

several methods including verifying of system check valve is closed, monitoring pressure parameters. Paragraph 4.3.2.4 of OM-10 allows upstream, performing system hydrostatic or that other positive means may be used for pressure tests, performing radiography, using verification. Recent examples of acceptable nonintrusive methods, and performing leak tests backflow tests include verifying that a parallel (even if a leakage limit does not apply). These pump does not rotate backwards when the other various methods meet the "other positive means" pump is tested to verify that the pump discharge of the Code.

i ll' l

NUREG-1482 A-18

NRC STAFF POSITION 4 PRESSURE ISOLATION VALVES Position 4 V refers to the scenario described for this j

event in the WASH-1400 study.

a.

General On April 20,1981, the NRC issued an i

Order to 32 PWRs and 2 BWRs which Pressure isolation valves (PIVs) are defined as two normally closed valves in required that these licensees conduct leak series that isolate the reactor coolant rate testing of their PIVs, based on plant-system (RCS) from an attached low specific NRC supplied lists of PIVs, and pressure system. PIVs are located at all required licensees to modify their TS RCS low pressure system interfaces. The accordingly. These orders are known as the " Event V Orders" and the valves listed 10 CFR 50.2 contains the definition of the therein are the " Event V" PIVs. The RCPB. PIVs are within the reactor Event V PIVs are a subset of PIVs.

coolant pressure boundary (RCPB).

The following summary is based upon the Based upon the results of recent staff's review of responses to Generic inspections, it has been determined that the following implementation problem still Letter 87-06, Periodic Verification of Leak exists with respect to testing of PIVs. He Tight Integrity of Pressure Isolation staff has determined that in some cases the Valves. All plants licensed since 1979 have a full list of PIVs in the plant procedures are inadequate to assure that these valves are individually leak tested Technical Specifications (TS) along with and evaluated against the leakage limits leak test requirements and limiting conditions for operation (LCOs). The specified in the TS; in other cases, the plants licensed prior to 1979 fall into procedures were adequate but were not several categories. Some pre-1979 plants being followed. Specifically, some check valves were tested in series as opposed to have a full list of PlVs along with leak test requirements and LCOs in the plant TS.

individually and some check valves were not tested when required.

Some pre-1979 plants have only Event V P!Vs (see below) in the plant TS. Some Licensees should review their testing -

pre-1979 plants have no TS requirements procedures to ensure the Event V PIVs are regarding PIVs.

individually leak rate tested.

. All PIVs listed in plant TS should be listed in the IST program as Category A or A/C Questions and Answers for Position 4 valves. The TS requirements should be referenced in the IST program.

Question Group 27 b.

Event V PIVs Questions Is it the intent of Generic Letter 8944 that the Event V PIVs are defined as two check

.only Reactor Coolant System Presuure Isolation valves in series at a low pressure /RCS Valves (PIVs) to be included in the IST program interface whose failure may result in a

- LOCA that by-passes containment. Event A-19 NUREG-1482 i

are those listed in the Technical Specifications required due to Generic Letter 87-06. Is this and those which are Event V PIVs?

true?

For plants licensed prior to 1979 which do not

Response

list all RCS Pressure Isolation Valves in their Technical Specifications, is it the intent of The responses to Generic Letter 87-06 are being Position 4 of Generic Letter 89-04 that only used as input for the resolution of Generic Issue PIVs listed in the Technical Specifications and 105, " Interfacing Systems LOCAs at L.ight PIVs which are " Event V" be included in the Water Reactors," under investigation by the IST Program 7 NRC Office of Nuclear Regulatory Research.

No further licensee action is required at this time Does the NRC anticipate requiring (in the future) with respect to Generic Letter 87-%.

that all RCS PIVs be included in the IST program 7 Current Considera ions

Response

The results of studies of interfacing system loss of coolant accidents (LOCA) are provided in The position in Generic Letter 89-04 represents NUREG/CR-5124, " Interfacing Systems LOCA:

only a limited area of the staff's concerns Boiling Water Reactors," and NUREG/CR-5102, regarding PIVs. The generic letter position only

" Interfacing Systems LOCA: Pressurized Water applies to those PIVs listed in individual plant Reactors."

Technical Specifications. However, the staff recognizes that the PIVs in the Technical Current Considerations for Position 4 Specifications for many plants, particularly older plants, are a subset of the PIVs in the plant. In Those plants licensed with all PIVs listed in the view of this fact and other concerns regarding TS have a specified leakage Smit for each PIV.

PIVs, the staff has recently undertaken a In responding to GL 87-06, many of the program to reevaluate various aspects of PIVs, licensees for plants having TS for only Event V including testing. Sample inspections are PIVs described the PIVs and testing applied to underway as part of this NRC program.

each set of valves, indicating that the Event V valves were the only PIVs which were leak Current Coneiderntions tested. In recent program submittals, licensees stated that the designations for certain PlVs.have The staff recommends that valves defined as been changed from those listed in GL 87-06 to pressure isolation valves other than those in TS designate other valves in the same lines as PIVs.

are at least verified closed in accordance with The designations are established by the licensee; the inservice testing program, and ensure that however, since two valves are required for the testing described in response to GL 87-06 is reactor coolant pressure boundary applications, maintained or justified. (See Section 4.1.1).

the requirements of 10 CFR 50, Appendix A, General Design Criterion 15 and Criterion 32 Question Group 28 apply for whichever valves are designated reactor coolant pressure boundary valves. (See Guestions Section 4.1.1).

What, if anything, is being done with the licensee responses to Generic Letter 87-06? The generic letter references PIVs in Section 4; however, it appears that there are no changes I

NUREG-1482 A-20

NRC STAFF POSITION 5 LIMITING VALUES OF FULL-STROKE TIMES FOR POWER-OPERATED VALVES Position 5 in the form of a generic letter is being considered by the NRC.

The Code intent with respect to measuring the full-stroke times of power operated valves is to In spite of the limitations of stroke time testing verify operability and to detect valve of MOVs, IWV-3413(a) of the ASME Code degradation. Measurement of full stroke times requires that the licensee specify the limiting for air operating valves fulfills this intent.

value of full-stroke time of each power operated -

However, reviews of operating experience have valve. The corrective actions ofIWV-3417(b) identified several problems with motor operated must be followed when these limiting values are valves (MOVs) including limitations with stroke exceeded. The Code does not provide any time as a measure of operational readiness of the requirements or guidelines for establishing these MOV. As a result, the industry has made limits nor does it identify the relationship that extensive efforts to improve the knowledge and should exist between these limits and any limits understanding of operational characteristics of identified for the relevant valves in the plant TS motor operated valves. This effort has been or safety analysis, i

conducted by industry groups (NUMARC, INPO, NM AC, EPRI), individual licensees, The purpose of the limiting value of full-stroke j

equipment vendors, and national standards time is to establish a value for taking corrective action on a degraded valve before the valve groups.

reaches the point where there is a high We believe the information and knowledge probability of failure to perform its safety developed by these groups should be reviewed function if called upon. The NRC has, and utilized. Some of the information publicly therefore, established the guidelines described available includes an INPO white paper titled, below regarding limiting values of full-stroke

" Motor-Operated Valve Performance Update,"

time for power operated valves.

issued October 4,1988.. This document identifies MOV problem areas and provides the The limiting value of full-stroke time should based on the valve reference key elements for a comprehensive MOV program. Another document is the " Technical or average stroke time of a valve Repair Guidelines for the Limitorque Model when it is known to be in good

. SMB-000 Valve Actuator," issued by the condition and operating properly.

Nuclear Maintenance Application Center The limiting value should be a reasonable deviation from this-(NMAC) in January 1989. This guide addresses reference stroke time based on the several areas such as setting torque and limit switches, preventive maintenance, actuator valve size, valve type, and actuator failure modes, failure analysis to determine root type. The deviation should not be so restrictive that it results in a valve -

cause and corrective action, and preoperational.

and post-maintenance testing.

being declared inoperable due to reasonable stroke time variations.

NRC staff concerns regarding MOV operability _

However, the deviation used to.

led to the issuance of Bulletin 85-03 and Bulletin establish the limit should be such that corrective action would be taken 85-03, Supplement 1. Expansion of this bulletin NUREG-1482 A-21_

for a valve that may not perform its operability of these valves, then the licensee intended function.

should propose an alternative to the Code requirements that does provide such information.

When the TS or safety analysis limit for a valve The Code requires the licensee to establish is less than the value established using the above limiting values of full stroke time for all power-guidelines, the TS or safety analysis limit should operated valves and also requires measurement be used as the limiting value of full-stroke time.

of stroke time to an accuracy of within 10 percent for this particular case. The Code When the TS or safety malysis limit for a valve does not prohibit the measurement of stroke time is greater than the value established using the more accurately or the setting of the limiting above guidelines, the limiting value of full-stroke value at less than 25 percent above the normal time should be based on the above guidelines stroke time. The NRC and industry recognize instead of the TS or safety analysis limit, that the Code-specific criteria are not sufficient for assuring operability of AC motor-operated-Questions and Answers for Position 5 valves. In light of this recognition, the staff issued Bulletin 85-03 to require that licensees Question Group 29 establish programs to ensure that operator switches for MOVs in certain important plant Question systems are selected, set, and maintained properly. As a result, in part, of the responses, Position 5 in part states: "The to that bulletin, the scope of the effort has been deviation should not be so restrictive that it expanded in Generic Letter 89-10 to include results in a valve being declared inoperable due many other MOVs important to plant safety.

to reasonable stroke time variations. However, NRC staff actions such as these will be need to the deviation used to establish the limit should be compensate for weaknesses in the IST provisions such that corrective action would be taken for a of the ASME Code until an adequate IST valve that may not perform its intended standard is available, function." Given that MOVs operated by AC induction motors fail if slowed by more than Question Group 30 l

approximately 10%, a valve normally stroking in 15 seconds will fail to operate by a change of Guestions -

{

l.5 seconds. By comparison, a reasonable I

deviation from normal stroke time of 15 seconds In regard to Attachment 1, Position 5, what is caused by error in measurement might be 2 considered a reasonable deviation from the seconds. The fact that the reasonable deviation reference stroke time?

for this 15 second valve is larger than the possible actual deviation before failure makes the In regard to Attachment 1, Position 5, can the two quoted goals of Attachment 1, Position 5, deviation be different for valves with different mutually exclusive. Request resolution.

functions and/or actuators?

Response

What is meant by " reasonably limiting value of full-stroke time?"

The staff agrees that stroke times for AC motor-operated valves probably will not change What methods are considered acceptable for appreciably before failure, especially for MOVs establishing the limiting value for full stroke that have relatively short stroke times. If the times for power operated valves as given in ASME Code-identified testing does not provide Position 5 of Generic Letter 89-047 useful information for evaluating the continued l

NUREG-1482 A-22

t In reference to Item 5 of Attachment 1, is there Question Group 31 any generic guidance on what is acceptable to the NRC on this item?

Questions What is " reasonable" value for deviating from in regard to Attachment 1, Position 5 the reference stroke time established for valve (paragraphs 2,3 and 5), why are Tech Specs or j

testing?

Safety Analysis limiting criteria not acceptable for valve operability if maintenance is triggered

Response

by component evaluation?

The NRC staff has attempted to provide the With respect to the application of stricter general philosophy for establishing the limiting acceptance criteria for valve stroke times, stroke time. The establishment of specific apparently the NRC has some idea as to the values for the limiting stroke time is dependent philosophy and limits that would be acceptable.

on a variety of parameters relevant to the This information should be shared with I

particular valve and the conditions at the plant.

licensees.

The parameters include operating characteristics, operating environments, actuaur types, and Define the " limiting value of full-stroke time."

valve stroke times. In that t'.ne test should Is this number the operability number for the confirm the operability of de component and not valve even if the Tech Spec stroke is much the system, the limiting value is not to be higher?

considered a function of the valve's safety significance. As the limiting value is specific to

Response

the valve, the staff is not in a position to provide values for limiting stroke times. The licensee The Technical Specifications provide assurance needs to use its best judgement in assigning these that important plant systems are capable of values. The justification for the assigned values performing their safety functions in a timely is expected to be documented and available to manner during selected plant accidents. The the plant site for review by NRC personnel, provisions of Section XI of the ASME Code are One aspect of the staff review will be a intended to ensure the continued operability of comparison of the limiting stroke time to the particular plant components. The distinct bases technical specification value.

for these two documents lead to criteria that may differ significantly. Nevertheless, the Technical Current Considemtions Specifications and ASME Code are both needed to provide confidence that the nuclear power I

Paragraph 4.2.1.8 of OM-10 includes the plant can be operated safely. Therefore, the requirements for using reference values for more restrictive criteria of the two documents stroke time acceptance criteria. Paragraph must be followed even though this might result 4.2.1.4 of OM-10 includes the requirements for in a component or system being declared establishing a limiting value for valve stroke inoperable. The response to questions on time. Any limits other than these would require position 8 of Generic Letter 89-04 also ' address relief for each valve. Refer to Section 4.2.7 the relationship of the ASME Code to the herein.

Technical Specifications.

Current Considemtions The TS and SAR limits are useful for performing analysis of data when a valve has A-23 NUREG-14d2 l

indicated degraded performance and been may vary for each valve type, stroke time, size, declared inoperable. In accordance with Code etc. The use of a quantitative multiplier on a requirements (paragraph 4.2.1.9 of OM-10), the reference time may be an acceptable method for data may be analyzed to verify that the new setting these values. However, as discussed in stroke time represents acceptable valve some of the responses above, the licensee should operation. (See Section 4.2.7).

document the justification for its quantitative methods of establishing maximum allowable Question Group 32 stroke times. This justification should be available at the plant site for review by NRC Question personnel.

Is it required to measure stroke times of valves Current Considerations that are not provided with remote position indication?

This approach may be in accordance with-paragraph 4.2.1.8 of OM-10. If it is not in

Response

accordance with the multipliers in paragraph 4.2.1.8, such an approach would necessitate The ASME Code requires the measurement of separate relief on each valve.

stroke time for all power-operated valves regardless of whether they have remote position Question Group 34 indication. The staff has endorsed this requirement. Without specifics, the staff is not Question in a position to comment on alternate techniques that may be found acceptable.

When the stroke time of a power operated valve exceeds its [ limiting value for] stroke time, as

)

Current Considerations established in accordance with Position 5 of the Generic Letter 89-04, but is still within its plant Section 4.2.9 includes a discussion of Technical Specification or FSAR [ final safety alternatives that might be acceptable.

analysis report] stroke time limit, can performing an evaluation which determines if the Question Group 33 valve may remain operable be used to satisfy Position 5 in lieu of making it mandatory that Qacstion the valve be declared ineperable?

When considering comparison of power-operated

Response

(stroke time) valves according to valve type, valve actuators, valve size, etc., we find there is The limiting value of full stroke time is required no consistency when using this comparison.

to be established for all power-operated valves.

- However each valve consistently tests well. We The limiting value should be that point at which are currently looking at a quantitative method of the licensee seriously questions the continued -

establishing maximum allowable stroke times. Is operability of the valve. 'It is expected to be a

'i this an acceptable method?

value determined to be reasonable for the individual valve based on that valve's

Response

characteristics and past performance, but not to '

exceed any safety analysis requirements. The -

If we understand the intent of the opening value should not be based solely on the system sentence of the question, we agree that criteria

- requirements or values specified in safety -

for setting the limiting value of full-stroke time.

analyses for system performance. When the NUREG-1482 A-24

l identified limiting value is exceeded, the licensee Question Group 36 shall declare the component inoperable and shall enter any applicable Technical Specification Question limiting condition for operation (LCO).

Following the declaration that the valve is In reference to Item 5 of Attachment I, is Item 5 inoperable, the licensee may perform an analysis in fact a rewrite of the stroke time criteria that to identify the root cause of the problem with the are to be applied in accordance with OM-107 valve. If this analysis clearly demonstrates that the valve remains capable of performing its

Response

safety function, the analysis might constitute the corrective action required by the Code. The

%e information in Position 5 of Generic Letter analysis should be documented.

89-04 was not intended simply to be a rewrite of the information in ASME Standard OM-10.

Current Considerations This position has evolved over the years and is considered reasonable by the staff for establish-Paragraph 4.2.1.9, " Corrective Action," of OM.

ing limiting values of full stroke time for power-10 provides the requirements related to this operated valves. As such, the position

response, represents a clarification of existing ASME Code requirements. For its part, ASME Standard Question Group 35 OM-10 does not provide guidance for the establishment of the limiting value of full stroke Question time. This standard, however, does require that a valve be declared inoperable immediately upon If the limiting value of full stroke time is less discovering that it fails to exhibit the required than the " alert limit" identified in the Code, does change of obturator position or exceeds the the trending still have to be done?

limiting value of full stroke time.

Response

Question Group 37 If the limiting value of full stroke time is Question exceeded, then the licensee shall declare the valve inoperable and shall perform corrective Since establishing maximum stroke time limits action. Where the limiting value is less than the may in some cases at first prove too restrictive, 25 percent or 50 percent " alert limits" for is it acceptable for corrective action to be an trending as specified in the ASME Code, engineering evaluation which increases the time trending as envisioned by the Code becomes a limit (based on more detailed analysis)?

j.

moot point. The licensee could identify a I

reduced percentage alert limit for this valve to

Response

provide early warning of problems with this valve, but this is not required either by the The Commission regulations in 10 CFR 50.59 4

Code or by Generic Letter 89-04.

allow licensees to perform engineering.

evaluations of plant structures, systems, and Current Considerutions components. If the stmke time limit is exceeded, the valve must be declared inoperable OM-10 includes reference values for stroke-time and any applicable Technical Specification measurement requirements (refer to Section limiting condition for operation entered. At that 4.2.7 of the guidelines). Rese requirements do point, an engineering analysis may be performed not include alert values.-

to verify that the valve is capable of performing A-25 NUREG-1482

its safety function. This analysis should include what parameters are being measured, how tests more than a determination that the new value is are being performed, and the bases for the 3

less than the FSAR or Technical Specification acceptability of any departures from the ASME limit. For example, a root cause investigation Code. For example, the program should should be performed to determine the reasons indicate forward flow testing or back flow I

for the stroke time increase.

testing, or both, for check valves.

Current Considemtions Current Considemtions

}

Paragraph 4.1.2.9, " Corrective Action," of in Section 2, the staff describes the content of OM-10 includes the requirements for analyzing the IST program. Recognizing that reference test data.

values of stroke-times may be changed, the licensee may consider including these values in 6

Question Group 38 test implementing procedures, but need not include them in the IST program document. The Questions IST program document may specify the type of valve and valve actuator for the licensee to j

We have been informed that we could omit the consider in determining which criteria apply.

[

valve stroke time limits from our IST Submittal.

(See Section 2).

~

Where can we find guidance on what is really required in a submittal (minimum scope)?

Current Considerations for Position 5 Do specific valve stroke time requirements (or For using reference values in performing stroke limits) need to be specified in the IST plan, or is time tests, refer to Section 4.2.7.

specification in implementing procedures sufficient? If procedures are sufficient, can existing limits referenced in the plan be removed in a future revision? If plan specification is required, is this limited to Technical i

Specification and safety analysis stroke time limits, or must owner specified stroke time limits that are required also be in the plan? -

Response

The specific limiting values of full stroke time for each power operated valve as determined according to Position 5 of Generic Letter 89-04 are not required'to be identified in the IST program. These limiting values, however, should be provided in a document such as the individual test procedure or a general procedure that identifies the criteria for establishing these values. The c(mcern for the specification of limiting values is the result of weaknesses that the NRC staff has found while reviewing IST procedures. As a general rule, IST programs -

should contain sufficient information to indicate NUREG 1482 A-26

NRC STAFF POSITION 6 STROKE TIME MEASUREMENTS FOR RAPID-ACTING VALVES Position 6 requirements for many of these rapid-acting valves.

The Code requires the following for power operated valves with stroke times 10 seconds or A valve may have a stroke time of 1.49 seconds less: (a) Limiting values of full-stroke times during one test and a stroke time during the shall be specified [IWV-3413(a)], (b) Valve following test of 1.51 seconds. If stroke times stroke times shall be measured to (at least) the are rounded to the nearest second as allowed by nearest second [IWV-3413(b)] and (c) If the the Code, the difference between these tests stroke time increased by 50% or more from the would exceed the 50% criteria and would previous test, then the test frequency shall be require an increased frequency of testing until increased to once each month until corrective corrective action is taken. This can result from -

action is taken [IWV-3417(a)]. Paragraph IWV-a stroke time difference of 0.02 seconds, which 3417(b) specifies corrective actions that must be is usually not indicative of significant valve

taken, degradation.

With reference to (c) above, measuring changes Power operated valves with normal stroke times in stroke times from a reference value as of 2 seconds or less are referred to by the staff.

opposed to measuring changes from the previous as " rapid-acting valves." Relief may be granted test is an acceptable (and possibly better) from the requirements of Section XI, Paragraph alternative to the staff. However, since this is IWV-3417(a) for these valves provided the different from the Code requirement, this licensee assigns a maximum limiting value of deviation should be documented in the IST full-stroke time of 2 seconds to these valves and, program.

upon exceeding this limit, declares the valve inoperable and takes corrective action in Most plants have many power operated valves accordance with IWV-3417(b).

that are capable of stroking in 2 seconds or less such as small solenoid operated valves.

An acceptable alternative to the Code stroke Licensees encounter difficulty in applying the timing requirements is the above stated rapid-Code 50% increase of stroke time corrective acting valve position. Since this represents a action requirements for these valves. The deviation from the Code requirements, it should purpose of this requirement is to detect and be specifically documented in the IST program.

evaluate degradation of a valve. For valves with stroke times in this range, much of the Questions and Answers for Position 6 difference in stroke times from test to test comes from inconsistencies in the operator or timing Question Group 39 device used to gather the data. These differences are compounded by rounding the Question -

results as allowed by the Code. Thus, the results may not be representative of actual valve With reference to the Generic Letter item 6, degradation, paragraph 4,' where does the two-seconds come :

from and what is the bases for the two-second '

')

The following discussion illustrates the problem only criteria, could this be a minimum of 3 or 4

)

that may exist when complying with the Code -

seconds?

' A-27 NUREG-1482

~. -

l

Response

for power-operated valves. Nevertheless, the staff believes that the use of a reference value The two-second criterion is based on the staft's stroke time as a base line for comparison of rou-consideration of the response time of personnel tine test values is a better method of evaluating and equipment and the difficulties involved in change in valve performance than that specified i

applying the ASME Code requirements in this ASME Code IWV-3400. Therefore, if a situation. Any alternative to Position 6 of licensee wishes to use reference values rather j

Gcneric Letter 89-04 or the ASME Code than previous test values for comparing stroke requirements may be submitted, along with a times for valves with normal stroke times equal sound basis, for staff review through a relief to or less than ten seconds, the generic letter j

request. As relief requests containing provides the vehicle for this deviation from the alternatives to the Code requirements are Code and a relief request need not be submitted.

expected to address the fundamental purpose of As the generic letter does not address valves inservice testing, see the summaries of the with normal stroke times greater than ten opening presentations for a discussion of this seconds, a licensee must submit a relief request subject.

for staff review and approval before using reference values as a base line for stroke times Current Considerations for these values.

Paragraph 4.2.1.8(e) of OM-10 includes the 2-Question Group 41 second limiting value as described in Section 4.2.2 of the guidelines.

Questions Question Group 40 Can an MOV or power-operated valve have a dual classification under " rapid acting" and "less i

Questions than 10 seconds?" For example, we have valves that stroke closed in less than 2 seconds and Generic Letter 89-04 states that previous analysis open in less than ten seconds. Therefore, is the (IWV-3417(a)) can be replaced with a classification and the previous test (or reference conservative " reference value" comparison.

test) percentage based on opening time or Generic Letter 894)4 states this should be closing time?

documented in the IST program. Should this change be made by relief request or by a text

Response

change to the program body?

If the valve performs a safety function in both Generic letter position on power operated valve positions, and the stroke time in one direction is stroke times of greater than ten seconds is to less than two seconds, then for that stroke place the valve in increased frequency if stroke direction, the licensee may use either the time is greater than 25% of the base line stroke acceptance criteria of ASME Code or the staff's time.

position for rapid acting valves. Where the stroke time for the valve in the other direction is

Response

greater than two seconds, the acceptance criteria for that stroke time range, as identified in the When the staff prepared the discussion in Code, should be followed when testing the valve Position 6 of Generic Letter 89-04, the objective in the greater-than-two-second direction.

of the first paragraph was to set the stage for the Similarly, the alternative concerning discussion on " rapid acting" valves, and it was measurements of changes in stroke time allowed not intended to address all aspects of stroke time by Generic Letter 89-04 may be used for the NUREG-1482 A-28 l

Ten-'-~

e m

m

.m

stroke direction that has a stroke time of less Current Considerations for Position 6 than ten seconds. [ NOTE: Although both MOVs and power +perated valves are Paragraph 4.2.1.8(e) of OM-10 includes the 2-mentioned, the question is more applicable to second limiting value for stroke time air-operated valves. Normally, MOVs do not measurement. Sections 4.2.2 and 4.2.3 relate to i

have widely different stroke times for the open rapid-acting valves.

and close directions.]

j A-29 NUREG-1482

w NRC STAFF POSITION 7 TESTING INDIVIDUAL CONTROL ROD SCRAM VALVES IN BOILING WATER REACTORS (BWRs)

Position 7 However, for those control rod drive system valves where testing could result in the rapid BWRs are equipped with bottom-entry insertion of one or more control rods, the rod hydraulically driven control rod drive scram test frequency identified in the facility TS mechanisms with high-pressure water providing may be used as the valve testing frequency to the hydraulic power. Each control rod is minimize rapid reactivity transients and wear of operated by a hydraulic control unit (HCU),

the control rod drive mechanisms. His alternate which consists of valves and an accumulator.

test frequency should be clearly stated and The HCU is supplied charging and cooling water documented in the IST program.

from the control rod drive pumps, and the control rod operating cylinder exhausts to the Industry experience has shown that normal scram discharge volume. Various valves in the control rod motion may verify the cooling water control rod drive system perform an active header check valve moving to its safety function function in scramming the control rods to rapidly position. This can be demonstrated because rod shut down the reactor.

motion may not occur if this check valve were to fail in the open position. If this test method is The NRC has determined that those ASME Code used at the Code required frequency, the licensee Class valves that must change position to provide should clearly explain in the IST program that the scram function should be included in the IST this is how these valves are being verified to program and be tested in accordance with the close quarterly.

requirements of Section XI except where relief has been granted in a previously issued Safety Closure verification of the charging water header Evaluation Report or as discussed below.

check valves requires that the control rod drive pumps he stopped to depressurize the charging The control rod drive system valves that perform water header. This test should not be performed an active safety function in scramming the during power operation because stopping the reactor are the scram discharge volume vent pumps results in loss of cooling water to all con-and drain valves, the scram inlet and outlet trol rod drive mechanisms and seal damage valves, the scram discharge header check valves, could result. Additionally, this test cannot be the charging water header check valves, and the performed during each cold shutdown because cooling water header check valves. With the the control rod drive pumps supply seal water to exception of the scram discharge volume vent the reactor recirculation pumps and one of the and drain valves, exercising the other valves recirculation pumps is usually kept running.

quarterly during power operations could result in Therefore, the HCU accumulator pressure decay the rapid insertion of one or more control rods test as identified in the facility TS may be used more frequently than desired.

es the charging water header check valve alternate testing frequency for the reasons stated Licensees should test these control rod drive above. If this test is not addressed in the licensee's TS this closure verification should be system valves at the Code-specified frequency if they can be practically tested at that frequency, performed at least during each refueling outage, NUREG-1482 A-30

and this alternate test frequency should be Questions and Answers for Position 7 specifically documented in the IST program.

No questions.

The scram inlet and outlet valves are power-operated valves that full-stroke in milliseconds Current Considerations for Position 7 and are not equipped with indication for both positions; therefore, measuring their full-stroke At many plants, certain of the valves described time as required by the Code may be in Position 7 are non-Code class valves. The impractical. Verifying that the associated IST program typically designates the Code class control rod meets the scram insertion time limits of each of the valves included in the program, defined in the plant TS can be an acceptable and those not in a Code class system. Most alternate method of detecting degradation of licensees have used the guidance in Position 7 these valves. Also, trending the stroke times of with no variation. (See Section 2.2).

these valves may be impractical and unnecessary since they are indirectly stroke timed, and no meaningful correlation between the scram time and valve stroke time may be otr ~

and fur-thermore, conservative limits ar vs n the control rod scram insertion times. It the above test is used to verify the operability of scram inlet and outlet valves, it should be specifically documented in the IST program.

i l

I i

I 3

1 A-31 NUREG-1482 k

NRC STAFF POSITION 8 STARTING POINT FOR TIME PERIOD IN TS ACTION STATEMENTS Position 8 The above position, which has been stated in terms of pump testing, is equally valid for valve ASME Section XI, IWP-3220, states "All test testing.

data shah be analyzed within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> after completion of a test", IWP-3230(c) states, in In summary, it is the staff's position that as soon part, "If the deviations fall within the ' Required as the data is recognized as being within the Action Range' of Table IWP-3100-2, the pump Required Action Range for pumps or exceeding shall be declared inoperative. "

the limiting value of full-stroke time for valves, the associated component must be declared In many cases pumps or valves covered by inoperable and the TS ACTION time must be ASME,Section XI, Subsections IWP and IWV, started.

are also in systems covered by TS and, if declared inoperable, would result in the plant if a test is under way (regardless of whether test entering an ACTION statement. These data have been taken) and it is obvious that a ACTION statements generally have a time gauge is malfunctioning, the test may be halted period after which, if the equipment is still and the instruments should be promptly l

inoperable, the plant is required to undergo some recalibrated. One example might be a wildly specific action such as commence plant fluctuating gauge. It should be noted, however, shutdown.

that, in many situations where anomalous data are indicated, it may not be clear that the The potential exists for a conflict between the problem lies with the gauge. In these cases, the aforementioned data analysis interval versus the licensee should attribute the problem to pump TS ACTION statement time period.Section XI, performance. The licensee would then declare.

IWP-6000 requires the reference values, limits, the pump inoperable and evaluate the condition and acceptance criteria to be included in the test of the pump during the time allotted by'the 1

plans or records of tests. With this infemation applicable Technical Specification.

available, the shift individual (s) responsible for conducting the test (i.e., shift supervisor, reactor Questions and Answers for Position 8 operator) should be able to make a timely determination as to whether or not the data Question Group 42 meets the requirements.

Questions When the data is determined to be within the Required Action Range of Table IWP-3100-2 the 10 CFR 50.55a(g) states that IST programs pump is inoperable and the TS ACTION comply with Section XI.Section XI states for statement time starts. The provisions in IWP.

valves that "If the condition is not, or cannot be,.

3230(d) to recalibrate the instruments involved corrected within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the valve shall be and rerun the test to show the pump is still declared inoperative." This is in direct capable of fulfilling its function are an disagreement with the Generic Letter which alternative to replacement or repair, not an states that the LCO must be declared additional action that can be tAen before immediately. How do you justify this declaring the pump inoperable.

disagreement with the Code?

NUREG-1482 A-32

Generic Letter 89-04 implies that the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by the required action range, then that valve time period for declaring valves operable versus must be declared inoperable at thnt time and not inoperable does not apply. Can the utility 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> later. This elimination of the 24-hour continue to use the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before declaring a grace period before declaring a valve inoperable valve inoperable?

is consistent with the requirements of ASME Standard OM-10.

Position 8 specifically states that licensees cannot use the 24-hour grace period for declaring a Question Group 43 valve inoperable (IWV-3417(b)) and must make such declaration immediately upon recognition of Question exceeding a stroke time limit. Position 5 states that the intent of developing more restrictive When a piece of equipment enters the required stroke time limits is to identify a valve problem action range, why must the Tech Specs action "before the valve reaches the point where there statement be entered without some time to reflect is a high probability of failure to perform if its on why it has entered the required action range?

safety function is called upon." Per Position 5, A reasonable approach would be to establish a exceeding the more restrictive limit does not limited reflection time, for example the existing imply that the valve is inoperable but that the shift, to review how the test was conducted and probability of failure is increased. With this review previous tests to see what the problem is.

philosophy, the 24-hour grace period is even In declaring equipment inoperable when it really more reasonable.

may not be upon review of how the test was conducted, generates needless paperwork and This question is in reference to item 8 of impacts INPO availability statistics (i.e., HPCI, : ' Starting point for time period in RCIC, RHR).

Technical Speci6 cations ACTION statement."

This item eliminates the 24-hour clock for valves

Response

which exceed Section XI limits. In most cases,

~

the Technical Specifications limits are higher For some time, the NRC staff has been than the Section XI limit. This item needs -

concerned with the unrestricted grace period for discussion.

declaring a component inoperable allowed by the

+

ASME Code. One example of this grace period

Response

is the 24-hour delay allowed by IWV-3417 of Section XI following a failure of a valve to The Standard Technical Specifications in Section exhibit the required change of disk position.

4.0.5 speci6cally state that the more restrictive The staff's concern in this area has been requirements of the Technical Specifications take expressed to individuallicensees on many precedence over the ASME Code. For example, occasions. In order to provide guidance that is the Technical Specification definition of consistent with the Standard Technical t

OPERABLE does not grant a grace period Speci6 cations and that can be applied generi-before a device that is not capable of performing cally, the staff developed Position 8 of Generic j

its specified function is declared inoperable.

Letter 89-04 which states that the unrestricted -

That definition takes precedence over the ASME grace period in the ASME Code is unacceptable.

Code, which allows up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before Once a component is declared inoperable, the declaring inoperable a valve that (1) is incapable action statement in the Technical Specifications of exhibiting the required change of disk position would provide time for evaluation of the or (2) has exceeded its limiting value of full situatica, including performing the test, before stroke time. Therefore, if a valve is tested and change is required in plant operating mode. A the data indicate that it is inoperable as defined licensee may propose alternatives to the NRC NUREG-1482 A-33 1

]

h staff's position. For example, a valve stroke

Response

time that is less than the limiting stroke time could be established as an alert time. If the alert Accuracy of the instrumentation is an important time is exceeded and the limiting time is not, the consideration in the performance of a test. In licensee would initiate a 24-hour period for addition, the test must be performed in a manner evaluating the condition of the valve before that allows the test results to be compared for declaring it inoperable.

trends. This consistent performance of a test is i

sometimes referred to as " repeatability." Where Question Group 44 instruments with different characteristics (such as with respect to range and accuracy) are used for i

Question each test, the ability to monitor the results for.

trends may be lost. Therefore, the staff prefers Address the conflicts between the background of that the same set of instruments be used in per--

the generic letter which states "The intent of forming tests on a particular component. This testing is to detect degradation affecting can be accomplished most readily by use of operation and assess whether adequate margins properly calibrated process instruments installed l

are maintained" and Position 8 regarding the in the system. The installation of test f

starting point for Technical Specification instrumentation that are more accurate than the ACTION statements. This will require declaring process instruments is allowed by the ASME components inoperable which are capable of Code. For the example cited by the question, fulfilling their safety function (i.e., operable).

after declaring the pump inoperable because of the test results from process instruments, the

Response

operability of the pump may be verified by more accurate test equipment. Because the same The staff does not see a conflict between the instruments should be used for tests to monitor statement in the background and Position 8 of the results for trends, the licensee should Generic Letter 89-04. Testing is intended to recalibrate the process instruments for their detect degradation of a component and to continued use or should establish a procedure to provide assurance that adequate margins are use the more accurate test instruments from that maintained. Where testing indicates that a point forward.

component has undergone such degradation that its operability is in question (e.g., the limiting Current Considemtions value of full stroke time for a valve has been exceeded), Position 8 of the generic letter Paragraph 4.5 of OM-10 discusses establishment requires that the component be declared of new reference values as may be necessary inoperable.

when using different instruments. Paragraph 6.1, " Acceptance Criteria," of OM-6 allows that Question Group 45

"[w] hen a test shows deviations outside of the acceptable range... the instruments involved Question may be recalibraed and the test rerun.".(Yee Section 5.6).

Referring to paragraph 8, after testing a pump and declaring it inoperable, is it acceptable to Question Group 46 replace the process instruments with test instruments which are more accurate then retest, Questions rather than recalibrating process instruments?

In reference to Item 8 of Attachment 1, it states that the provisions to recalibrate in IWP-3230(d)

NUREG-1482 A-34

s can only be done after the component is declared Current Considemtions inoperable. What if, during a pump test, before test data is taken, it is clearly observed that a Section 3.1.2 and Section 6 discuss further gauge is malfunctioning. Do I need to declare information. After issuing GL 91-18, the pump inoperable, or can I stop testing and "Information to Licensees Regarding Two NRC recalibrate?

Inspection Manual Sections on Resolution of Degraded and Nonconforming Conditions and on If it is obvious that a test has been run Operability," the NRC held workshops for incorrectly (i.e., a recorded parameter is out of regional offices and industry representatives and the range of the device being tested), do we still gave guidance on nonconforming conditions that enter the action statement before re-running the apply to IST requirements.

test?

Response

if a test is under way (regardless of whether test data have been taken) and it is obvious that a gauge is malfunctioning, the test may be halted and the instruments should be promptly recalibrated. One example might be a wildly fluctuating gauge. It should be noted, however, that, in many situations where anomalous data are indicated, it may not be clear that the problem lies with the gauge. In these cases, the licensee should attribute the problem to pump performance. The licensee would then declare the pump inoperable and evaluate the condition of the pump during the time allotted by the applicable Technical Specification.

l NUREG-1482 A-35

v NRC STAFF POSITION 9 PUMP TESTING USING MINIMUM-FLOW RETURN LINE WITII OR WITIIOUT FLOW MEASURING DEVICES Position 9 required testing, it should be documented in the IST program.

An inservice pump test requires that the pump parameters shown in Table IWP-3100-1 be in cases where only the minimum-flow return measured and evaluated to determine pump line is available for pump testing, regardless of condition and detect degradation. Pump the test interval, the staff s position is that flow differential pressure aH flow rate are two instrumentation which meets the requirements of parameters that are measured and evaluated IWP-4110 and 4170 must be installed in the mini ' low return line. Installation of this together to determine pump hydraulic performance.

instrumentation is necessary to provide flow rate measurements during pump testing so this data Certain safety-related systems are designed such can be evaluated with the measured pump that the minimum-flow return lines are the only differential pressure to monitor for pump flow paths that can be utilized for quarterly hydraulic degradation.

pump testing. Purthermore, some of these systems, do not have any flow path that can be NRC Bulletin 88-04, dated May 5,1988, utilized for pump testing during any plant advised licensees of the potential for pump operating mode except the minimumdow r eturn damage while running pumps in the minimum-

~

4 lines. In these cases, pumping through the path flow condition. The above guidelines for designed for fulfilling the intended system safety meeting the Code or performing alternative function could result in damage to plant testing is not intended to supercede the thrust of equipment. Minimum-flow lines are not this Bulletin. Licensees should ensure that if designed for pump testing purposes and few pumps are tested in the low flow condition, the have installed flow measuring devices.

flow is sufficient to prevent damage to the pump.

In cases where flow can only be established through a non-instrumented minimum-flow path Questions and Answers on Position 9 during quarterly pump testing and a path exists at cold shutdowns or refueling outages to Question Group 47 perform a test of the pump under full or substantial flow conditions, the staff has Question determined that the increased interval is an acceptable alternative to the Code requirements With reference to the Generic Letter item 9, in provided that pump d:fferembi pressure, flow cases where only the minimum flow return line rate, and bearing vibration measurements are is the available path, would the generic letter be taken during this testing and that quarterly test-revised to consider reducing the 5-minute time ing also measuring at least pump differential required for stabilizing the pump as required by pressure and vibration is continued. Data from IWP-3500(a) to a lesser time such as 2 or 3 both of these testing frequencies should be minutes in order to minimize the possibility of trended as required by IWP-6000 Since the pump damage occurring during the pump's above position is a deviation from the Code-operational test?

NUREG-1482 A-36

ll

Response

Question Group 49 The staff does not intend to revise Generic Question Letter 89-04 to change any current positions or to address additional issues. If there is a Many mini-recirculation lines have no means to problem concerning compliance with the ASME adjust flow u> a reference value prior to taking '

(

Code, requests for relief from the Code may be data. Thus, i:J: m:irculation flow is relatively submitted.

fixed. Since Table IWP 3100-2 limits are placed i

in differential pressure, what criteria should be l

Current Considemtions used to place limits on flow? Even with a fixed-I flow system, measured flow will demonstrate-Paragraph 5.6, " Duration of Tests," of OM4 some variation test-to-test due to instrument specifies the minimum run time as 2 minutes.

repeatability, operator interpolation of needle Refer to Section 5.8 of the guidelines, position on meter face, etc. Table IWP 3100-2 limits do not seem appropriate for flow in this Question Group 48 case. To allow both flow and differential pressure to vary within 13% ranges does not Guestion appear to meet the intent of Section IWP.

If mini-flow recirculation lines are instrumented

Response

for flow, are quarterly tests alone, which measure flow, differential pressure, and in most cases, mini-flow recirculation lines do vibration, acceptable?

not have flow adjustment capability. The ASME Code recognizes this in IWP-3110, which

Response

permits the use of one'or more fixed sets of reference values for pump testing. The Code Mini-flow recirculation line tests are not identifies acceptance criteria for both differential prohibited by Section XI of the ASME Code, pressure and flow rate in Table IWP-3100-2. It

'The staff, however, believes that a mini-flow test is not permissible for both parameters to vary can be detrimental to a pump and is not a during a test. With one parameter set at a desirable test configuration.' These tests produce

' reference value, the other parameter is compared data of marginal value and provide little to the acceptance criteria.

confidence in the continued operability of the pump. The staff would prefer a more Current Considemtions '

comprehensive test performed at some reduced-frequency rather than relying only on the mini-Refer to Section 5.3 of the guidelines.

flow test that is performed quarterly. This Paragraph 5.2(c) of OM-6 allows that "[w]here particular issue may be a topic of another system resistance cannot be varied, flow rate and generic letter addressing inservice testing in the pressure shall be determined and compared to future.

their respective reference values."

Current Considem:fons Question Group 50 I

' Paragraph 3.2, " Bypass Loops," of OM4 allows Questions that "lal bypass test loop may be used, provided the bypass is designed to recognize the pump It is more desirable to test pumps at substantial manufacturer's operating conditions for flow conditions than on mini-recirculation lines.

minimum flow operation "

Should entire trains of safety systems be A-37 NUREG-1482

l t

declared inoperable and 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> action one train of a safety system will be disabled for statements entered solely to realign these systems an extended period or both trains of the system for inservice testing? Does the obtaining of must be made inoperable to perform a test, the "better" pump data justify the increased risk to licensee should propose a testing schedule that the public during the time the system cannot provides for verification of component perform its safety function?

operability with testing performed during periods (e.g., refueling outages) when availability of the

Response

system is not essential to plant safety.

As stated in the question, it is more desirable to Current Considerations test pumps with substantial flow than in mini-flow recirculation configurations. The NRC Refer to Section 3.1.2.

staff, however, does not agree with the questioner that the performance of inservice Current Considerations for Position 9 testing results in increased risk to the public.

Inservice testing is intended to provide assurance The OM committee has prepared, and will of the continued operability of pumps and include in the OM Code, a " comprehensive valves. To provide this assurance, it is pump test" for testing at full or substantial flow considered acceptable for a Technical Specifi-conditions to monitor Code parameters.

cation action statement to be entered on infrequent occasions in order to test a com-ponent. Where a system mus' be taken out of service to perform a test. i: is likely that, in the event of a plant emsgency, the system could be realigned for operation in short order. Where NUREG-1482 A-38

NRC STAFF POSITION 10 CONTAINMENT ISOLATION VALVE TESTING Position 10 Do PIVs have relief from IWV-3427(b)? Item 10 on Attachment 1 only discusses CIVs.

All containment isolation valves (CIVs) that are included in the Appendix J, program should be

Response

included in the IST program as Category A or A/C valves. The staff has determined that the The relief from IWV-3427(b) of the ASME leak test procedures and requirements for Code granted through Generic Letter 89-04 only containment isolation valves specified in applies to CIVs under containment leak rate 10 CFR 50, Appendix,I are equivalent to the testing. This position was written in response to requirements of IWV-3421 through 3425.

numerous relief requests concerning CIVs from However, the licensee must comply with the licensees that cited difficulties in trending leak rate data. We were not aware of similar Analysis of Leakage Rates and Corrective Action requirements of Paragraph IWV-3426 and difficulties with PlVs during reactor coolant 3427(a).

syr m leak testing. The relief from the explicit requirements of IWV-3427(b) should not be taken as an indication that the NRC staff is IWV-3427(b) specifies additional requirements on increased test frequencies for valve sizes of disregarding the value of trending CIV leak six inches and larger and repairs or replacement testing data. Until more information is available over the requirements of IWV-3427(a). Based on appropriate leak rate limits and on reasonable on input from many utilities and staff review of scatter of data, however, Position 10 will remain testing data at some plants, the usefulness of in effect for CIVs. The NRC staff anticipates IWV-3427(b) does not justify the burden of developing a more comprehensive position of the complying with this requirement. Since this subject in a future generic communication to licensees.

position represents a deviation from the Code requirements, it should be documented in the Curnnt Considerations IST program.

Questions and Answers for Posillon 10 Alternatively, the licensee may conduct leak-rate IST in accordance with OM-10, which does not include the IWV-3427(b) requirement. Refer to Question Group 51 Section 4.4.5.

Questions Current Considerations for Position 10 in regard to Attachment 1, Position 10, why can't valves other than containment isolation In revising 10 CFR 50.55a(b), the NRC valves (CIVs) that are 6 inches or larger be incorporated, by reference, the 1989 edition of exempt from the needless requirement of IWV.

Section XI, and created an exception to the requirements for containment isolation valves in 3427(b)?

paragraph 4.2.2.2 of OM-10. Until this Does the exemption from iWV-3427(b) pertain exception is deleted from the regulation, leakage rates for containment isolation valves are to pressure isolation valves (PIVs) as we'l as Appendix J valves 7 required to be monitored in accordance with A-39 NUREG-1482

IWV, Position 10, or paragraph 4.2.2.3 of OM-

10. Recently, the OM committee created a task force to respond to the staff's concerns and a paper was presented to the OM Subcommittee on Performance Testing in Baltimore, Maryland, September 1993. (See Section 4.4.5).

i NUREG-1482 A-40

NRC STAFF POSITION 11 IST PROGRAM SCOPE Position 11 The intent of 10 CFR 50 Appendix A, GDC-1, and Appendix B, Criterion XI, is that all The 10 CFR 50.55a requires that inservice components, such as pumps and valves, testing be performed on certain ASME Code necessary for safe operation are to be tested to Class 1,2, and 3 pumps and valves.Section XI demonstrate that they will perform satisfactorily Subsections IWP-1100 and IWV-1100 defines in service. 'Iherefore, while 10 CFR 50.55a the scope of pumps and valves to be tested in delineates the testing requirements for ASME terms of plant shutdowns and accident Code Class 1,2, and 3 pumps and valves, the mitigation. The plant's FS AR (or equivalent) testing of pumps and valves is not to be limited provides definitions of the necessary equipment to only those covered by 10 CFR 50.55a.

to meet these functions. The staff has noted during past IST program reviews and inspections Questions and Answers for Position 11 that licensees do not always include the necessary equipment in their IST programs.

Question Group 52 Licensees should review their IST programs to ensure adequate scope. Examples that are Question frequently erroneously omitted from IST programs are as follows:

IWV-1200 specifically exempts control valves from testing. Why are these valves included in (a)

BWR scram system valves the list of examples in IST program scope as part of Attachment I?

(b) control room chilled water system pumps and valves

Response

(c) - accumulator motor operated isolation IWV-1200 of the ASME Code does not exempt valves, or accumulator vent valves valves that have a required safety function from the provisions of Section XI. Code l

(d) auxiliary pressurizer spray system valves interpretation XI-1-83-59 states that it is a l

requirement of Section XI that flow control (e) boric acid transfer pumps valves that have one or more def'med safety-related functional requirements be classified (f) valves in emergency boration flow path Category A or B, as applicable, and tested in accordance with the requirements of Subsection (g) control valves that have a required fail-safe IWV. This philosophy applies to all control position valves that have one or more defined safety-related functional requirements.

(h) valves in mini-flow lines Cument Considerations It should be recognized that the above examples of pumps and valves do not meet the IWP and On October 8,1985, the ASME Code committee IWV scope statement requirements for all plants.

revised interpretation XI-1-83-59R with the reply stating "[ijt is the Owner's responsibility to categorize valves as required by IWV-1400 and A-41 NUREG-1482

l l

in accordance with the criteria IWV-2200."

components. Paragraph (g) of 10 CFR 50.55a Refer to Section 4.2.9.

requires the use of Section XI of the ASME Code for inservice testing of components Question Group 53 covered by the Code. For other components important to safety, the licensee also has the bur-Questions den of demonstrating their continued operability.

The list provided in Position 11 contains Please clarify the last three lines of Generic examples of components that have been shown Letter item 11 of Attachment 1.

by our experience to be frequently omitted from a routine testing program. The licensee should The scope statement of Position 11 is much too review the safety significance of these identified vague. The position with respect to program components to ensure that the inservice testing is scope must be clarified and explained to provide adequate to demonstrate their continued further guidance and should also address the operability. NRC inspectors will evaluate the backfit issue. In addition, in the past, it has adequacy of such testing. The Code-required been the practice of adding additional IST program is a reasonable vehicle to provide a components to the scope of IST Programs via periodic demonstration of the operability of the authority of 10 CFR 50.55a(g)(ii). How will pumps and valves not covered by the Code. If this be addressed in the future?

non-Code components are included in the ASME Code IST program (or some other licensee-Do safety-related components outside of Class 1, developed inservice testing program) and certain 2, and 3 need to be tested in accordance with the Code provisions cannot be met, the Commission Code and be included in the IST program, or is regulations (10 CFR 50.55a) do not require a it the intent to have some form of testing to

" request for relief" to be t,ubmitted to the staff.

demonstrate operability?

Nevertheless, documentati1n that provides assurance of the continued coerability of the In reference to Item 1I of Attachment 1, please non-Code components througn the performed clarify the intent of the last sentence of this item:

tests should be available at the plant site.

"Therefore, while 10 CFR 50.55a delineates the testing requirements for ASME Code Class 1,2, Current Considerations and 3 pumps and valves, the testing of pumps and valves is not to be limited to only those Refer to Section 2.2.

covered by 10 CFR 50.55a."

Question Group 54 How will the NRC review pump and valve testing not included in the scope of the IST Questions program? Will the ASME Code requirements he applied to these components?

The Diesel Generator air start system direction that was in the initial draft of Generic Letter 89-

Response

04 has now been dropped. Can we remove the testing from our program?

Criterion 1 in. Appendix A to 10 CFR Part 50 requires, among other things, that components in Position 11, why were the emergency diesel important to safety be tested to quality standards generator support system components deleted commensurate with the importance of the safety from the list in the final version of the letter?

functions to be performed. Appendix B to Part 50 describes the quality assurance program, which includes testing, for safety-related NUREG-1482 A-42

I i

Response.

Response

Typically, the Emergency Diesel Generator air.

He listed items were not intended to apply to start system is not Code Class 1,2, or 3 and, every plant. Each licensee should review the list therefore 10 CFR 50.55a does not require the and determine those items applicable to its testing of these components to be performed facility. In response to the specific question,

.7 under the provisions of the ~ASME Code.

items 11c, d, and e do not apply to BWRs.

Emergency Diesel Generator air start, cooling water, and fuel oil transfer systems, however, Current Considerations for Position 11 are considered safety related. As such, Appendices A and B to Part 50 require that they Refer to Section 2.2.

undergo component testing.

Current Considemtions Refer to Sections 2.2 and 3.4.

i Question Group 55 Quenion Are the items listed in Attachment I number lle, d, and e specific to PWRs?

r A-43

, NUREG-1482

OTIIER QUESTIONS SUBMITTED DURING GENERIC LETTER 89-04 MEETINGS Schedule for Implementing the resolve any requested relief requests outside the Generic Letter generic letter (prior to required test frequency) to obtain approval and avoid violation after suMual, or wm mere be a grace peM Question Group 56

Response

Questw.ns With regard to plants not listed in Table 1 or 2 The scope of the Generic Letter is broad and of Generic Letter 89-04, the intent has been that,

~

requires more than the allotted 6 months for by the end of six months, (1) the IST program response. What guidance can be given for would be revised to incorporate all the extension of the response date?

requirements of the generic letter, (2) the procedures would be written and implemented, How much.is expected to be done at the end of (3) the confirmation letter and any necessary 6 months?

additional relief requests would be submitted to the NRC, and (4) a schedule would be provided What is the schedule requirement for for any plant modifications necessary to comply implementing additional or revised test.mg arismg with the requirements. It has been additionally a

from the activities related to the generic letter 7 in, ended that any necessary equipment Keep m mmd that the results of reviews anf modifications be completed within 18 months of evaluations must be available prior to revismg the date of the confirmation letter or the first and implementing the related procedures.

scheduled refueling outage following the Do the requirements to conform to the stated positions of the generic letter within 6 months of We have received several comments stating that the date of the letter mean that all procedures this schedule may not be achievable. For have to be rev, sed and approved within this 6 example, one licensee noted that acceptance i

month period, or is it acceptable to have criteria need to be developed before procedures procedures in the process of bemg revised with,in can be prepared and implemented. Following the 6 month period?

preparation of the procedures, several weeks were said to be needed to provide the necessary Due to outage schedules and constraints, are training to plant personnel on various shifts, there any provisions for not completmg all Another licensee indicated that the resources egmpment modifications within 18 months of the necessary to implement the generic letter had to date of confirmatory letter, or the first scheduled be determined to justify to management the need refueling outage following the confirmation for contractor assistance. Even where licensee I "" *'7 management accepts the justification for contractor assistance, it was said that few highly How are extensions of the October 3,1989 qualified contractors in the area of inservice deadime viewed; what factors are considered on testing are available. With respect to equipment such requests?

modifications, one licensee hypothesized a situation where a refueling outage began sooa Do utilities have to contact the. Proj.ect after the confirmation letter and the next ir Managers to schedule immediately a meeting to NUREG-1482 A-44

refueling outage would be a month or two

Response

beyond the 18-month limit.

The positions in Generic Letter 8944 address Several reasons that the NRC staff does not both program and procedural issues. Positions consider sufficient to justify not meeting the 4,5, and 8 are related to procedures and would schedule in the generic letter were also given by not be covered by a review of the IST program.

meeting attendees. These insufficient reasons ne remainder of these positions are related to include (1) the lack of activity relative to both the IST program and the procedures. For Generic Letter 8944 until the NRC meetings Table i plants, we believe that it would be took place and (2) the lack of a desiguted reasonable for the generic letter provisions to be individual responsible for IST at the plant when implemented within six months of issuance of the generic letter was issued. If any particular the SER. The precise schedule, however, will plant anticipates a problem in meeting the be specified in the SER. The schedule for Table schedule, this should have been discussed with 1 plants is keyed to the SER because the licensee the NRC Project Manager. In determining the needs an opportunity to review the SER before necessary schedule extensions, licensees should having to commit to an implementation schedule.

have limited the request for schedule relief to the Nevertheless, the staff encourages Table 1 plants smallest set of revisions to the IST program and to begin verifying that plant procedures are procedures, and modifications to equipment.

consistent with the generic letter before receipt The information submitted to the NRC by the of their SER. Table 2 licensees should verify licensee to justify a delay in meeting the that plant procedures are consistent with the schedule established in Generic Letter 89-04 generic letter positions within six months of should have contained at least (1) a description issuance of Generic Letter 89-04.

of the actions to be completed by October 3, 1989, including an interim schedule of Confirmation Letter accomplishments by system and component, (2) a description of the action for which an Questlou Group 58 extension in the schedule is being requested with the specific proposed schedules for the program, gy,,,f,,,

procedures, and any necessary equipment modifications, and (3) a discussion of the With our confirmation letter will be a couple of specific reasons for the need to extend the relief requests. How will they be handled? Can schedule, including the hierarchy of tue pioposed we assume relief is granted? Do we have to schedule extensions as established by their wait for your SER7 importance and dependence on the completion of other actions.

What is the level of information expected in the response to the generic letter? How detailed Question Group 57 must it be?

Questions Is " relief" required for items per Generic Letter 89-04 which differ from the ASME Code?

Does the NRC expect the licensee to take any specific action prior to receipt of the SER?

Response

is it the intent to have all implementing A confirmation letter from a particular licensee procedures of changes required by Attachment 1 may contain several forms of information, be completed within 6 months? Does this apply depending on the IST program, ne i

to Table 1 and Table 2 plants?

confirmation letter should address the extent to t

A-45 NUREG-1482 m.

which the licensee's program and procedures Verification of Generic I2tter meet the positions attached to Generic Letter 89 Implementation

04. It is anticipated that most licensees will have to modify their IST programs as a result of the generic letter. The revised program should Question Group 59 accompany the confirmation letter. In cases where a generic letter position that approves an Questions alternative to the ASME Code is being followed, a relief request is not required, but the deviation When and how is guidance going to be provided from the Code should be documented in the IST to the Regional offices on inspection and program along with its method of approval (i.e.,

enforcement of the issues stated in the Generic through the relevant generic letter position). As Letter?

a suggestion, licensees may reserve the use of the term " relief request" for those cases where Regarding the approval of the IST Program specific staff review and approval are needed scope and related relief requests, it appears that before implementation.

NRC is not planning to perform detailed review and is merely stating that their responsibility re.

If a licensee cannot meet one of the generic 10 CFR 50.55a is satisfied by the generic letter letter positions, an alternate test method may be supplemented by plant site inspections. This performed, providing the provisions of eliminates the pre-approval discussions done Paragraph B of the generic letter are met. ' Itis previously; however little guidance is provided Paragraph B approach for generic letter positions to give licensees's confidence that the subjective does not require a relief request but the opinions of the various inspectors can be justification should be retained in the IST anticipated before the fact. It would help if program. In that the generic letter does not there were some mechanism whereby a utility supersede the regulations in any way, the option could receive an official opinion / determination still exists to submit requests for relief from the with respect to program scope and relief request Code for program-related positions in the queries in a timely manner.

generic letter. For plants not listed on Table 1 or 2 (i.e., plants that will be submitting a con.

With respect to inspections, will there be an firmation letter), any requests outside the scope inspection module developed, or is this to be an of the generic letter that were submitted before "ad hoc" type of inspection?

April 3,1989 are approved by the issuance of the Generic Letter. If a relief request is To what extent is the NRC planning to make submitted after April 3 or a relief request their guidance uniform policy for all inspections?

submitted before April 3 is modified, the It is very important that uniform policy be requested relief may not be implemented until applied at all facilities, regardless of the receipt of staff approval. The date by which composition of inspecting teams.

these relief request approvals are needed should be specified in the confirmation letter so that Many alternatives that are given seem vague and their review may be prioritized.

subject to interpretation. Who decides adequacy and what are the ramification of differences between licensees and the NRC7 What guidance will Region /NRR auditors use in accessing IST Programs for Table 1 or 2 plants?

Will they use the SER or the generic letter?

NUREG-1482 A-46

Response

Response The NRC staff has been performing activities to It is recognized that the positions in Generic provide assurance that application of the generic Letter 89-04 go beyond the areas covered by letter by the inspectors will be consistent. For past SERs on inservice testing. Positions 4,5, example, a meeting to discuss the generic letter and 8 deal with procedural matters that are not was held in Rockville, Maryland, in April 1989, reflected in the IST programs and SERs.

and each NRC Region office was represented.

Therefore, it cannot be expected that an SER A temporary instruction (TI) will be written by would constitute concurrence that all of the NRC/NRR, providing guidance to the regional generic letter positions have been met. The inspectors on prioritized inspection activities for SERs for Table I and 2 plants explicitly contain IST and the Generic Letter 89-04. It is intended approval only for relief requests. These SERs that the Tl will be completed in six to eight can be considered as providing IST program months. Periodic NRR/ Region counterpart approval only in that the practice has been to meetings will be held to ensure consistency on perform a thorough review and identify problem the IST subject matter. Additionally, the areas that need resolution, inspection teams are expected to be made up of NRC/NRR, NRC Region, and contractor Updates and Revisions of the IST personnel, thereby providing for consistent Progrant communication. These inspections will assist the staff in verifying the adequacy of the IST program rather than verifying adequacy by the Question Group 61 traditional staff review. It is intended that the inspectors will rely on the generic letter, the Guestions temporary instruction, and the particular SER for Table I and 2 plants. These inspections will not if relief requests exist that do what one, or any, be performed on an ;tihag basis. Although only of the positions state, should these requests be retracted with the confirmation /resubmittal?

relief requests will receive NRC review before their implementation, licensees may direct questions concerning interpretation of Do " changes ti the program" include requirements on the IST program and procedures administrative i langes such as referencing to the NRC staff through their Project Manager.

different procedures, or just intent of program?

in instances when a licensee modifies their IST Question Group 60 program beyond that currently submitted to the l

NRC, [as discussed in] Paragraph D of the

Guestion, generic letter, and reviews the modification against the positions found in Attachment 1, is it l -

If the SER does not c<mstitute NRC concurrence required that the IST program modifications be that the generic letter requirements (at least those submitted to the NRC7 that are routinely addressed in the program sub.

mittal) are met, then how will issuance of SERs Our plant is on Table 1. We have revised the to Table 1 or Table 2 plants constitute NRC program to identify Generic Letter 89-04 as a approval of the IST program?

reference and made some minor changes consistent with the letter. Do we need to l

Will all SERs issued in the near future, or resubmit the program 7 recently issued, incorporate all the issues in the generic letter?

Are all future revisions to the IST program required to be submitted to the Commission?

NUREG-1482 A-47

Section D of the generic letter is silent on this position should not be retracted but the source of subject.

approval (i.e., the generic letter) should be identified in the IST program. Non-technical Does the generic letter mean that program and minor typographical changes may be held submittals are no longer required? Under what until the licensee has collected several such circumstances are submittals still required?

changes. This is considered to meet the intent of 10 CFR 50.9 for complete and accurate Should we provide changes to the NRC as so(m information. For plants not listed in Table 1 or as made even if numerous " trivial" or " typo" 2, revisions to the IST program should be sent changes are being issued? What about the when the confirmation letter is submitted.

" complete and accurate" requirement in 10 CFR 50.97 Question Group 62 Should updated plans document specific relief Questions requests that were approved on a prior date?

If valves are added to or removed from the Since programs are revised frequently and in a system, does the change to the program require piece-meal fashion, does the NRC expect each resubmittal? Can components be deleted without change to be submitted as soon as it's made, or prior NRC approval?

is once per year, once per two years, etc.

adequate 7

Response

Response Neither the Commission regulations in 10 CFR 50.55a(g), in general, nor Generic The NRC staff should have the current IST Letter 89-04, in particular, require the licensee program being implemented at each plant even if to obtain NRC approval on each test on every this means that a licensee sends multiple component in the IST program. As long as the submittals to the NRC each year. The most up-program is consistent with the regulations, the to-date version of an IST program will not be ASME Code, and the Generic Letter, relief is used for the purpose of the staff performing not required. To amplify, deletions from or complete program reviews as has been done in additions to the IST program do not necessarily the past. Rather, it is needed to prepare for IST require NRC approval. The burden is on the inspections and to assist in the review of relief licensee to verify that their IST program is requests. The staff would prefer to have a complete and all components that require IST are complete program rather than individual changed included and tested to the extent practical. If a pages. The identification in the program of the particular component is deleted from the IST mechanism for approval of specific relief program, documentation of the reason in an requests would be particularly helpful. That is, appropriate place is recommended, the program should indicate whether the approval is (1) through a position in Generic Question Group 63 Letter 89-04, (2) by virtue of the relief request being outside the scope of the positions in the Questions Generic Letter and submitted before April 3, 1989, (3) through the mechanism described in Please clarify the intent of the last sentence of Paragraph B in the generic letter, or (4) obtained

[Section D]: "The modified program should using a relief request that will need staff comply with the disposition of relief requests in approval by a specific date. Currently-approved any applicable SER based on a previously relief requests that follow a generic letter submitted IST program." The sentence quoted 1

1 NUREG-1482 A-48 l

above seems to apply to Table 1 or Table 2 Question Group 65 plants only. Also, the sentence seems to allow the use of an extension of a previously granted Questions relief request.

For plants with SERs, can changes to NRC

Response

reviewed and approved programs be made without additional submittals to the NRC7 What Section D of the Generic Letter 89-04 applies to if changes are in accordance with the generic all plants. Previously approved relief requests letter?

remain valid. However, if a relief request has been denied in an SER, the SER usually

Response

provides information on the reason the relief request was denied and recommendations on As described in the response to Question 61, appropriate actions for the licensee. The last licensees need to send any changes to their IST sentence of Section D is indicating that these program to the NRC. If these changes are in recommended actions should be followed.

conformance with Generic Letter 8944, NRC review and approval are not necessary. The IST Question Group 64 programs submitted to the NRC as a result of program changes should indicate the reasons for Guestions the changes and the relief requests, if any, that require staff review.

It is clear that if an NRC position is covered by, then the licensee must either Relief Requests comply with or follow the alternate provisions contained in Section B of the generic letter. But Question Group 66 for program changes not covered by Attachment 1, [Section D] states that the provisions of Gunh.ow 10 CFR 50.55a(g) should be followed. This infers that a relief must be submitted. Further, If a relief request issued for one unit has been in'accordance with the plant Technical appr ved, can, or will the turnaround time for Specifications, relief must be granted prior to approval of the same relief request on a second implementation.

unit (for a two unit plant) be reduced?

For future relief requests outside the scope of, what is the perceived ability of It is correct that, where an IST program change the NRC regardmg turnaround time?

is proposed that is outside the scope of the l

positions in the Generic Letter and does not meet RnPonse the Section XI requirements, the licensee must submit a relief request to the NRC for review.

N*. relief requests will be evaluated on a The program change may not be implemented pn nty basis. Therefore, the licensee should

- prior to staff approval' specify the date by which the relief is needed, and where possible, should provide additional information to assist in this review, such as "this relief request is identical to relief request number

[

X in the Unit 1 IST program." The staff l

recognizes that, on occasion, there will be a l

need for rapid NRC response.. The staff will i

l NUREG-1482 A-49

make every available effort to be responsive to Question Group 69 such needs.

Questions Question Group 67 Is a continuous feedback system required to Questions provide a mechanism to reverify that relief requests are still valid based on ongoing If revised relief request submittals are not maintenance and plant modification activities?

considered approved, then do we continue working to the presently approved request?

Response

Response The licensee is expected to have a feedback system that will maintain the IST program as a The approved relief request is controlling until living document that will be updated to be the licensee receives approval of a revised relief consistent with changes in plant configuration, request. As we have indicated above, if plant if a particular relief request is no longer required operations and ASME Code requirements dictate because of changes in hardware, system design, relief request approval by a certain date, the or new technology, the licensee is expected to licensee should indicate that date in the submittal revise the program to withdraw the relief containing the relief request.

request. Conversely, if a system modification results in the addition of a component to the IST Current Considerations program, the feedback system should ensure that the Code requirements or Generic Letter 89-04 For discussion on updates to the IST program provisions are met, or that a relief request is for the 120-month revision, see Section 3.3.3.

submitted, as appropriate.

Question Group 68 Question Group 70 Questions Questions Does a relief request that is grandfathered but no Relief request requirements are changed in the longer required still need approval?

Generic Letter. Previously approved relief requests are now being challenged because the

Response

NRC uses a different reviewer. This appears to be a back6t issue.

By grandfathered relief request, we assume that the question is referring to a relief request not If relief was granted by the NRC for an item covered by the positions in Generic Letter 89-04 during the first interval, is the san.e relief but submitted before April 3,1989. Withdrawal -

granted during the sec(md interval even though of relief requests, regardless of the prior the relief is not in compliance with GL 89-047 approval status, is permitted without NRC review, presuming the IST program remains In the 1st 10 Year submittal, an SER approved a consistent with the regulations, the ASME Code, relief request which is not consistent with the or Generic Letter 8944.

alternative positions in Generic Letter 89-04.

Does the generic letter void previously approved alternatives / relief requests (via an SER) or may these alternatives / relief requests not consistent NUREG-1482 A-50

with Generic Letter 89-04 still be considered some time in the future, issue additional valid and so documented in the IST program?

guidance to provide a pre-approval mechanism much as the generic letter does in certain of its When will it be known what the staffs position positions.

is on SER approved relief requests that contradict Generic Letter 894)4 dictated testing?

Current Considerations

Response

Though the NRC did not " pre-approve" relief requests through the guidelines, several sections We assume that the questions are not referring to in the guidelines allow the licensee to use certain interim reliefs but rather relief requests on which OM-6 and OM-10 requirements pursuant to the NRC staff prepares an SER. Assuming that 10 CFR 50.55a(f)(4)(iv). (See Section 1).

the reviewed information was complete, accurate, and remains up-to-date, an approved Question Group 72 relief request may be currently followed even if it conflicts with the Generic Letter. These types Guestions of situations will be reviewed in preparation for inspections. Safety significant differences To conform to generic letter positions, what between the approved relief request and the does " document in the program" mean? Should Generic Letter will be discussed in an effort to relief requests be generated with the obtain licensee agreement to adopt the Generic understanding that the ger.eric letter grants them?

Letter position. Where agreement cannot be Or does a statement included in the program reached, the staff may consider initiation of describing how the deviation conforms to the backfit procedures. Relief requests are subject generic letter suf0ce?

to review by the NRC staff at the ten-year update for consistency with current NRC

Response

regulatory positions, including those contained in Generic Letter 89-04. Reliefs that are..

The IST program should include the deviation.

inconsistent with the generic letter would likely from the ASME Code that the licensee intends to not be approved for a succeeding ten-year take, and the basis for the change just as a interval.

program would normally contain. There should be suf0cient information in the program to Question Group 71 demonstrate that Generic Letter 89-04 is applicable to the situation in question and that Guestions the testing being performed conforms to the generic letter.

What is the long term status of the " relief" system?

Current Considemtions Although the documents need not be in the

Response

format of a relief request, the position would The section of the Commission's regulations typically be clearly referenced for each pertaining to the relief request system is applicable component. If the format is a relief 10 CFR 50.55a. This regulation is not, and request, the licensee would typically state that it cannot be, superseded by Generic Letter 8944.

is considered approved by the GL 89-04

. A revision to this regulation is under considera-position. (See Section 2.5.3).

tion. With respect to the " relief" system as described in the regulation, the staff may, at NUREG-1482 A-51

Question Group 73 detailed regulatory analysis may be addressed in future generic guidance.

Questions Question Group 75 Is the following statement correct? A relief request submitted prior to April 3,1989 but not Questions discussed in any SER and is not a subject of generic letter attachment 1 is approved for use Regarding a multi-site, if one unit has an t

without any further utility reviews.

approved SER which grants relief on items which do not meet all the criteria of the generic

Response

letter, can the approved SER provide a basis for the other unit to go ahead and implement the Relief requests that were on the docket t)cfore relief request prior to NRC re-review (assuming April 3,1989, for plants that are not in 'iable 1 design differences do not exist between the two or 2 in Generic Letter 89-04 and aa 'opics that units)?

were not discussed in Attachment I are approved by this generic letter. Any relief requests

Response

outside of the Generic Letter positions that are submitted after April 3,1989, will require staff When relief is granted in an SER for one review and approval before implementation.

particular unit on a multiple unit site, that relief The response to Question 74 explains the basis applies only to the one unit even if the other unit for this approach. Other statements regarding is c watially identical. If an SER is written for utility's required actions for the review of two e r more) units, the relief would apply to all implementing procedures additionally apply.

units specified in the SER. The SER for one unit may not be used as a basis for implementing Question Group 74 the request before staff approval. See also the response to Question 66.

Question What is the NRC's basis for stating that approval is by virtue of the generic letter for previously Questions submitted relief requests when such reliefs could be outside the scope of the positions in the if an SER that ia eceived by a plant on Table 1 generic letter and have not undergone NRC after the generic alter was issued denies a relief, review?

and another plant that is not getting an SER has the same relief request grandfathered (approved),

Response

is this fair?

From the general knowledge of the relief

Response

requests, the NRC staff selected the technical issues considered the most significant to be Such situations will be considered by the NRC addressed by Generic Letter 89-04. The NRC staff when preparing for plant inspections.

staff checked a sampling of the current IST Safety significant differences between the programs to provide confidence that those issues approved relief request and Generic Letter 89-04 not addressed in the Generic Letter were not will be discussed at that time to try to obtain highly safety significant. Additional issues that licensee agreement to follow the generic letter.

would require the NRC staff to perform a If agreement cannot be reached, the staff will consider the need to initiate backfit procedures.

NUREG-1482 A-52

'l Question Group 77 been met. In that case, a follow-up SER would f

not be issued. Where the relief request is denied Questions and the staff asks for more information (e.g.,

additional analysis or basis), then a specific Does the first sentence of [the IST PROGRAM request must be made to the staff for its review APPROVAL] section apply to Table I and Table and approval before implementation by the 2 plants? The last sentence infers it does not, licensee.

i

Response

Recent and Upcoming SERs The first sentence of the "!ST PROGRAM Question Group 79 APPROVAL" section of Generic Letter 8944 states that "[t]his generic letter approves gue,ffon, currently submitted IST program relief requests for licensees who have not received an SER For a Table 1 plant, can changes be made to the provided that they (1) review their most recently IST program in accordance with the generic submitted IST programs and implementation pro-letter, even though the SER has not been cedures against the positions delineated in received?

Attachment I and (2) within 6 months of the date of this letter confirm in writing their

Response

conformance with the stated positions

• This sentence applies only to plants not listed in Table Any licensee may revise its IST program to 1 or 2.

conform to Generic Letter 8944. The licensee should provide changes to the IST program to Question Group 78 the NRC as discussed in the responses to Questions 61 and 65.

Questions In the approval process, when an SER conditionally gives relief and requires further Questions plan changes, is an SER supplement provided, or is relief approved by letter, or is the relief W 11 the implementation schedule for procedure granted based on conformance to the SER changes and hardware changes be specified in stipulations 7 the SER? Will this schedule be similar to the generic letter; e.g., will the licensee have six Diablo Canyon's SER grants several relief months to effect procedure changes and 18 requests with c(mditions. We are revising reliefs months /next refueling outage to make hardware to meet these conditions. Will we need NRC changes?

approval of revised reliefs prior to implementation?

Response

The implementation schedule for procedure and hardware changes will be contained in the SER.

If the conditional approval specifically identifies The NRC staff expects the schedules to be what must be done to obtain relief, then similar to those in the Generic Letter 89-04. See conformance with the c<mdition is complying also the response to Question 57.

with the relief. A revised program should be sent to the NRC stating that the conditions have NUREG-1482 A-53

Question Group 81 Alternatives to Positions in the Generic Letter Questions Before the SER is issued or for the first six Question Group 83 months thereafter, is it permissible for the licensee to use its current IST program as 0 "'#'l888 submitted to the NRC7 Are the new criteria always to be used even if it is not applicable? Can it be partially

Response

implemented if the licensee feels the relief Licensees should use the current version of their request is sufficiently justified by specific in IST program. The generic letter, in effect, house experience?

provides interim approval of the existing program for Table I licensees until the SER is R'#Ponse issued.

Certain positions in the Generic Letter 89-04 are n t fully applicable to all plants. For example, Question Group 82 the components listed in positions 3 and 11 are n t applicable to all plants. Further, Position 7 Questions is applicable only to BWRs. Alternatives to the p siti ns f the generic letter, or partial If a plant with an SER on its IST program has a implement tion as this question suggests, should 10 year review up coming, how should that be be justified in accordance with Paragraph B of handled? Resubmittal?

the letter. Specific in-house experience is only ne of the sources of information that should be

Response

utilized when evaluating alternative testing, and is not a substitute for the criteria in Paragraph B A plant with an SER that is preparing a revision f the generic letter.

for the 10-year update should revise the program to be in conformance with the provisions of Generic Letter 89-04. The licensee does need to Question Group 84 submit the program update to the NRC. The program should indicate which relief requests Questions require NRC review and approval and which relief requests are already approved through the Will any deviations from the requirements in the Generic Letter be reviewed and an SER issued generic letter. Staff review and approval of the unapproved relief requests are required before for those relief requests?

the licensee implements the new program.

Is a relief request required when only 2 or 3 of the 4 items identified in Generic Letter item B, page 3, can be met?

Generic Letter 89-04 states in Paragraph B, that when licensees are unable to comply with the positions of Attachment 1, evaluation of alternate testing should address [four criteria). Is it mandatory for each instance to address all 4 of the above items? In some instances or situations, the above items may not apply, or NUREG-1482 A-54 x

only a portion may apply. When evaluating an may be implemented. The specific justification alternate test to one of the Positions of is expected to be documented in the IST of Generic Letter 8944, may the program submitted to the NRC, but need not be alternate test be implemented without prior NRC documented in the form of a relief request. This approval providing an evaluation is performed documentation will be subject to review for and documented and retained in the IST completeness, accuracy, and applicability during Program? Does the documented alternative test NRC in,pections.

evaluation in the IST program have to be formally submitted to the NRC as an IST If at some time, the circumstances change such program revision, and if so, in what time frame 7 that the justification obtained through Paragraph B is no longer valid, then the licensee must On Page 2 of Ted Sullivan's review, he submit a relief request for staff review before indicated that the NRC will not issue SERs in continuing the alternate test. Paragraph B may items and justified alternatives.

also be used when future revisions to the IST

]

Are the justified alternatives the 4 points on past program relating to the generic letter positions

.I component history? Can I use these 4 alter-are prepared. If all four criteria cannot be met, 1

natives to justify a deviation from the then a relief request must be submitted to the positions? If so, are these then NRC and the alternate test method cannot be approved by the generic letter? After issuing a implemented until staff approval is received.

confirmatory letter, can I go through the above For technical issues outside the scope of the process to get " automatic" or pre-approval of positions in the generic letter, the alternative Attachment i exceptions in the future? Can the provisions of Paragraph B may not be applied 4 points be used for non Attachment 1 items and, in these cases, a relief request must be following a similar process?

submitted for NRC approval before implementation.

For relief requests not covered by this generic letter, is (in accordance with Technical Current Considemtions

)

Specification 4.0.5) specific written approval required prior to implementation?

Refer to Section 6 for additional information.

Response

Question Group 85 Assuming that Section XI will.not be followed, Guestions -

Paragraph B of the Generic Letter 8944 provides guidance for the situation in which a Since 10 CFR 50.55a(g) is a top tier document, licensee is unable to comply with one of the is it still permissible to use its provisions of the positions of the generic letter because of design relief request process when the requirements of considerations or personnel hazard (as opposed the Code / generic letter cannot be met? Must to inconvenience). In such a situation, a licensee

' these relief requests be approved prior to may develop an alternative testing method implementation in accordance with plant provided an evaluation is performed that Technical Specification 4.0.57 If a required test 1

addresses four specific crheria. The alternate cannot be done, should the utility use the test would not be acceNable unless the data exigency provision?

associated with those criteria are sufficient to justify its adequacy for detecting degradation and

Response

ensuring continued operability. Where the four criteria are satisfied, the alternate test is

- The provisions of 10 CFR 50.55a(g) remain; considered approved by the generic letter and available for the licensee's use for submitting 1

NUREG-1482

]

A-55 1,

o

i relief requests and obtaining approvals. In Does the Generic Letter or the RAI take accordance with the Technical Specifications, precedence and which one must be complied approval of relief requests is required before with?

I implementation. Relief requests should indicate the date by which approval is needed. Generic We received 86 questions (RAI from NRC) of Letter 89-04 is providing another method of which some were general in terms. A couple receiving approval of deviations from the ASME dealt with justification wording in which the Code requirements. The licensee may prepare a questioner recommended a more detailed case to justify postponement of a particular test justification, although the alternate method on the basis of exigency. At this point, we are would remain the same. Would we have to unaware of any aspect of Generic Letter 89-04 make these recommended changes and resubmit, that would qualify for the exigency provision.

or can we leave them alone? If revision is more of an administrative wording issue, then are they Current Considerations considered to require an SER7 Refer to Section 6 for additional information.

What do I do about an RAI that I received prior I

to the generic letter and issues in the RAI are Question Group 86 outside Attachment !?

Questions

Response

Was the generic letter issued as opposed to There are a small number of plants that have changing the regulation? Prior to regulation received RAls and that have not had an IST changes, will comments he solicited from the review meeting to discuss the RAI. Utilities in licensees?

this category are plants not on either Table 1 or 2 and are expected to respond to Generic Letter

Response

89-04 with a confirmation letter. Utilities that have received RAls do not need to respond Generic Letter 89-04 is not considered an explicitly to the RAls, but should use them to alternative to the regulation but is a vehicle to assist in responding to the generic letter. The obtain preapproved relief from certain ASME RAls provide an indication of possibly weak or Code requirements. If the regulation is changed, questionable aspects of an IST program. For the normal rulemaking process will be followed those cases where the intent of an NRC question and comments will be solicited.

is unclear, licensees may obtain clarification through the NRC Project Manager.

Requests for Additional Information (gy)

Question Group 88 Question Group 87 Some questions in a recent RAI are in conflict Questions with previously approved relief requests. Which one must be complied with7 liow do plants which have received requests for additional information (RAI) from the NRC but Response,

are not on the list of plants to receive an SER get RAI items resolved that are not addressed in Previously approved relief requests remain valid the Generic Letter?

despite what might appear to be a conflicting NUREG-1482 A-56

position in an RAL This statement assumes that the staff's experience, most continuously moni-the previously approved relief was granted on tored leakage detection systems do not verify the the basis of accurate and complete information leaktight integrity of each valve in the flow path available to the NRC staff at that time.

and the staff does not consider these systems to meet the Code requirements.

Modification of the Generic Letter Current Considerations Question Group 89 The Code requirements allow that the licensee need not leak test valves which function during l

Guesh.ons of plant operation in a manner that demonstrates functionally adequate seat tightness; however, is a NUREG to be issued on this Generic Letter the valve record shall provide the basis for the to clarify underly.mg issues 7 conclusion that operational observations

*'Y**"*"**~

Response

Ilack it Concerns There is no current plan to prepare a NUREG document to clarify any underlying issues with i

Generic Letter 89-04. These minutes will be Question Group 91 sent to all licensees and attendees who provided i

their address.

Questions Question Group 90 The Generic Letter states that "In cases where conformance with the stated positions would Questions

- result in equipment modifications, the licensee should provide in his conformation letter a Will Generic Letter 89-04 be updated from time schedule for completing the required modifica-

+

to time to provide additional positions on IST tions " The Generic Letter goes on to state programs in areas such as the following? The

' acceptable schedules for completion of these ASME Section XI Code does not require leak mods. Are these modifications subject to the testing for valves where leakage is continuously provisions of 10 CFR 50.109 backfitting?

l monitored, however, for PWR plants the NRC often requires leak testing for Category A valves Please confirm that the NRC's opinion and such as the RCS accumulator / core flood present position is that the generic letter is not discharge check valves which are monitored considered a backfit for all utilities.

continuously for seat leakage.

Does the staff intend to do a backfit analysis

Response

regarding this position? We currently have approved relief requests for the first Ten Year The staff has no plan to issue a supplement to Interval in which the staff has found our lack of Generic Letter 89-04. Another generic letter on instrumentation acceptable. His applies to other IST may be issued in the future, but would positions as well.

cover new topics or expand on the current scope of components covered by the IST program Do the modifications that are needed to conform required by the ASME Code. The Code does with the stated positions require a backfit? If require that valves whose leak tight integrity is modifications are necessary to' comply with the important for performance of their safety stated positions, are relief requests necessary if it function be individually leak rate tested. From is deemed impractical to make the modifications?.

l A-57 NUREG-1482

If not through relief, how do we deal with these statements, operations personnel frequently ask issues? What if no maintenance history is what is the NRC's definition of a cold shutdown available to substantiate relief 7 of sufficient duration. Is cold shutdown testing expected to be back to back tests or can 1 or 2 Defend or explain your basis for sayir r the days breaks be acceptable (i.e. shall continue is generic letter does not require a backfit.

not easily defined)?

Response

in 1987 and early 1988, the NRC rejected a general relief request to use OM4 criteria for Generic Letter 89-04 was presented to the flow and delta pressure for pumps. Can we now NRC's Committee to Review Generic revise our program to use the criteria of OM4 Requirements (CRGR) as a backfit issue, and and OM-107 If the answer is yes, do we need a certain positions were identified as changes to relief request?

past staff positions. As discussed with the CRGR, the staff determined that those positions What is the time frame for the in the generic letter that represented changes 10 CFR 50.55a(g) change 7 1s the NRC willing from previous staff positions were necessary in to accept the currently approved OM4/OM-107 order to bring licensees into compliance with the Commission's regulations. Therefore, according Will any of the guidance provided in the generic to 10 CFR 50.109 (a)(4)(i), a backfit analysis letter change with the implementation of Part 6 was not required to justify issuance of the and Part 10 of O&M7 generic letter. If the positions in the generic letter cannot be met, the option discussed in Once OM4 and OM-10 are approved, will it be Paragraph B may be available. Further, if the required to implement them immediately (within licensee will not be following the generic letter 6 months) or will they be implemented at the positions, Paragraph B of the letter, and the next program update?

ASME Code, the licensee must submit to the NRC staff a request for reli?f from the ASME

Response

Code. Where a licensee is following a provision of its operating license or a particular exemption Rulemaking to reference ASME standards OM4 from the ASME Code that was granted by the and 10 in the regulations is underway at this NRC staff, a backfit analysis would need to be time. It can be said, however, that, in some performed by the NRC staff before requiring any recent relief request evaluations, the use of the change to that licensee practice. With respect to pump allowable range limits identified in OM4 the staff review of previously approved relief for flow rate and differential pressure has not requests at the ten-year update of the IST been found acceptable to the staff. The staff has program, however, a backfit analysis would not not completed its assessment of the inter-be necessary. See the response to Question 70.

relationship of Generic Letter 89-04 and OM4 and 10. When appropriate references to OM4 Use of OM-6 and 1()

and 10 are incorporated in the regulations, these standards may be used by the licensee as the regulat ns pennit the usg gf nue recent refyn Question Group 92 enced standards. We anticipate that rulemaking to reference these standards will be issued for 0""*."#

public comment in the near future.

When addressing cold shutdowns, OM-10 uses statements like " sufficient duration" and "shall continue." When trying to implement these t

l NUREG-1482 A-58

Current Considemtions General Questions On September 8,1992, the revised rule tock Question Group 94 effect, as discussed m several sections of the guidelines. The NRC did not require plants to 0"##U.#"#

update on an accelerated schedule. (See 10 CFR 50.55a)'

Please clarify what is meant by "one part of a broad effort" in the Background section of the Soleno.d-Operated Valves (SOVs)

Generic Letter.

i Question Group 95

Response

Questions Generic Letter 89-04 is part of a larger program to improve IST throughout the industry and to To perform position indication testing on provide aMitional information and clarification solenoid operated vdves, is a light check on the s#ect to all affected parties. The joint acceptable or must the position verification be ASME/NRC Symposium on IST held in performed by runnir g the system or injecting Washington, D. C., in August 1989 is also part air, etc. to prove salve 1,osition? Is a remote of this effort. Additional generic regulatory position verification required for SOVs with no guidance may be prepared on other IST aspects.

positive means available?

For a discussion of the " broad effort" that NRC is pursuing, refer to the summary of the

Response

presentation by Tad Marsh provided in these meeting minutes.

Verification of remote position indication by IWV-3300 is required to ensure that the Question Group 95 indication accurately reflects actual valve position. ' Itis could take the form of a Questions differential praure test, flow rate measurement, or other change in some parameter that How do the Generic Letter 89-04 requirements positively shows that the valve is in the indicated differ from the ASME requirements?

position. An indirect verification, using techniques such as radiography, may also be

Response

acceptable.

Generic Letter 89-04 is intended to provide Current Considerations fundamental information on the NRC's interpretation of certa 5 Technical Specifications Refer to Sections 4.2.5,4.2.6, and 4.2.8 for and ASME Code requoementt and to 1dentify additional infanation.

certain alternative testing that the NRC staff finds acceptable. The generic letter also goes beyond the ASME Code in that it covers procedural issues in addition to programmatic issues.

The generic letter may contain Code interpretations that differ from those of certain licensees. The one area that we are aware of in the generic letter that is different from the Code NUREG-1482 A-59

-~

~-

..~

is contained in Position 8 on the starting point Question Group 98 for the time period in Technical Specification action statements. This position is consistent Questions with other Technical Specification starting points. This position is also articulated in the Most plants have been given relief from bases for certain of the Standard Technical measuring pump bearing temperatures per IWP-Specifications.

4310. Is it the policy of the NRC that this will continue to be an item of " generic" relief?

Question Group 96

Response

Questions It is true that some plants have been given relief In a refueling outage that is greater than 3 from measuring pump bearing temperatures on months, how is the cold shutdown frequency the basis of the impracticality of measuring handled? Can we perform the cold shutdown temperature for specific pump designs. This.

procedure once during the outage or do we issue has not been treated as an item of " generic perform the cold shutdowri procedure every 3 relief" because each relief request has been months during the outage?

individually evaluated. For the foreseeable future, NRC will continue to evaluate these

Response

relief requests on a case-by-case basis.

When a component is required to Se in service Current Considemtions during the outage, the testing is expected to be performed quarterly during the outage. When a Refer to Section 5.1.2.

component is not required to be operable during i

an outage, the testing need not be performed Question Group 99 i

quarterly. In accordance with IWV-3416 of the ASME Code, however, those valves must be.

Questions tested within 30 days before return of the system o

to operable status. Further, as required by IWP-Where pump parameter measuring instruments 3400(a), pumps must be tested within one week do not meet the specific requirements of the after the plant is returned to normal operation.

Code but do satisfy the fundamental technical requirements for testing, would it be acceptable Current Considemtions to allow relief 7 Refer to Section 3.1 for additional information.

Response

Question Group 07 It would be difficult to answer this question without more specific information. :There have Questions

_ been cases where relief requests in this area have been approved. In those cases, however, the Is radiography on check valves an acceptable basis for relief has been that the instrumentation-method for determining valve position?

has been adequate to meet the fundamental objective of detecting degradation. In relief

Response

requests of this type, the licensees should

~ ddress the reason that the ASME Code a

Radiography may be utilized if it indicates the requirements are not currently being met and the 4

' position of the valve disk.

NUREG-1982 A-60

basis for concluding that the fundamental Question Group 102 objectives of IST are being accomplished.

Question Current Considemtions How do we handle cold shutdown justifications Refer to Section 5.5.

in the future?

Question Group 100

Response

Questions Cold shutdown justifications were previously reviewed by NRR for adequacy. In the future, Tne schedule for exercising manual valves they will be reviewed during IST inspections.

should be extended to something less than once The cold shutdown justifications are expected to each quarter. Is this feasible?

be described in the IST program the licensee provides to the NRC staff.

Response

Current Considerations We are not aware of a basis for exercising manual valves at a frequency different frorn Refer to Section 3.1.1.

I other valves. Because this subject is not specifically related to Generic Letter 894)4, it Question Group 103 was not addressed at any length during the meet-ing, if the licensees are aware of reasons why Question the frequency should be changed, we recommend that this subject be explored with the After this meeting, what is the process for ASME O&M Working Group on Valves.

getting further questions answered regarding the generic letter?

Current Considerations

Response

The licensees for certain plants disregard manual valves in planning the IST programs; however, These meeting minutes will be distributed, which manual valves that have a safety function that should answer most of the industry's questions.

requires repositioning are required to be stroked If after reading the meeting minutes you still at the Code-specified frequency. To date, no have questions, you may contact the cognizant changes have been made by the OM Committee.

personnel through the NRC Project Manager.

.See Section 4.4.6.

Question Group 104

. Question Group 101 a

1 Questions Question Does "needed to mitigate the consequences of an it has been said that some plants have excellent accident" mean an accident as described in IST organizations. Who are they?

Chapter 14 of the Final Safety Analysis Report (FSAR)?

Response

Dresden is one example of a facility with'a good IST organization.

A-61 NUREG-1482

Response

Question Group 105 We assume that the question is directed to the Questions chapter of the FSAR describing accident analyses performed by the licensee. Those This question is in reference to analyses are iatended to provide confidence that 10 CFR 50.55a(g)(4):

"...to the extent practical the public health and safety will be protected in within the limitations of design, geometry, and the event of certain accidents and anticipated materials of construction of the components." In transients at a nuclear power plant. The term reviewing this wording, along with the state-

" accident" is also used in different sections of ments of consideration, do you think this rule the Commission's regulations. For example, was intended to impose plant modincations as a Appendix B to 10 CFR Part 50 establishes result of meeting subsequent editions and quality assurance requirements for the design, addenda? That is, once the staff evaluates a construction, and operation of " structures, licensee's determination of impracticality, will systems, and components that r event or the NRC impose plant modifications as alternate mitigate the consequences of postulated accidents requirements 7 that could cause undue risk to the health and safety of the public." Part 100 describes

Response

structures, systems, and components that must be designed to remain functional during a " safe The NRC staff in the Mechanical Engineering shutdown earthquake" as those necessary to Branch of NRR has had lengthy discussions with ensure:

the NRC Office of the General Counsel on this matter. The current interpretation of the rule is (1) the integrity of the reactor that it is not intended to require a blanket coolant pressure boundary, (2) the imposition of all plant modifications that would capability to shut down the reactor be necessary to comply with subsequent editions and maintain it in a safe shutdown and addenda. The rule does require an evalua-condition, or (3) the capability to tion of the impact on the licensee, that is the prevent or mitigate the consequences impracticality of making the modifications, as of accidents which could result in part of an assessment of the requests for relief potential offsite exposures compar-from the ASME Code requirements. The legal able to the guideline exposures of staff has stated that there is nothing in the this part.

regulations that relieves licensees from making all hardware modifications to the plant to comply As can be seen, the term " accident" is used by with changes to IST requirements throughout a the Commission to describe a broad range of plant's life in later editions of Section XI. Some possible adverse events at a nuclear power plant.

hardware modifications can be required. The

'Iherefore, although most of the accidents of difficult issue to resolve is how much may be concern to IST are addressed in the accident required. For example, major equipment or analyses chapter, licensees should be aware that piping modifications may be beyond the there may be other accident analyses in the limitations of practicality in meeting subsequent FSAR that need to be considered.

editions of the Code. We, however, regard modifications such as the installation of instrumentation to be practical as used in 10 CFR 50.55a(g)(4).

NUREG-1482 A-62

Question Group 106 inspection, it was determined that if these check valves failed open, adequate flow to the Questions containment would still be achieved. We are also converting the manual va:ves upztream of For plants that do not have operating licenses, ICS 3A(B) into motor operated valves in order 10 CFR 50.55 requires that you apply the codes to prevent sump water from getting in o the that are in effect 12 months prior to plant RWST. Do these check valves need ta be leak startup. Where does the 6 month conformance tested?

letter stand for construction plants in this situation?

Should Category A be applied to valves other than containment isolation valves (e.g., valves

Response

which isolate HVAC damper air accumulators:

checks /SOVs)?

There are only two plants expected to receive operating licenses for which the staff's review of

Response

the IST program has not been completed. These plants are Comanche Peak and Watts Bar.

The NRC staff has a generic concern with the These two plants will be treated essentially as current practice of categorization of check Table 1 plants in that a review will be completed valves. The ASME Code assigns all check and an SER issued. The reviews of the valves as Category C. If seat leakage of a check Comanche Peak and Watts Bar IST programs, valve is limited to a specific amount, the Code however, may not be completed in the same time also requires that valve to be assigned to frame as the reviews for plants listed in Table 1.

Category A. Whereas Category C check valves To obtain the scheduled completion dates er the are required by the Code only to be exercised on IST program reviews, the Comanche Peak and a periodic basis, Category A/C check valves Watts Bar organizations should contact their must be leak tested in addition to being respective NRC Project Managers.

exercised. The NRC staff has found that, in many instances, check valves are not being Question Group 107 assigned to Category A/C despite the fact that credit is taken by the licensee for the check Guestions valve providing an essentially leak tight function.

The categorization of a check valve is not Currently, we only test the ICS pump suction dependent solely on the function performed by check valves ICS 3A(B) to verify they open as the valve, such as whether it is a containment part of the ICS pump test. Originally, the only isolation valve. When determining the proper safety function recognized was for the valves to categorization of a check valve, a licensee open to provide a water source, the RWST, to should take all applicable aspects into account.

the ICS pumps. During an independent review For example, the licensee should determine (1)-

of the IST program, it was determined that these whether the flow requirements for connected valves may also have a safety function to close systems can be achieved with the maximum when the pumps are taking suction from the possible leakage through the check valve, (2) the RHR system. These valves, if they failed open, effect of any reduced system flows resulting could provide another flowpath (to the RWST) from the leakage on the performance of other besides the normal flowpath to containment.

systems and components, (3) the consequences This flowpath would also allow potentially of the loss of water from the system, (4) the contamineM. water from the containment sump _

effect that backflow through the valve may have into the RWST (NOT. DESIRABLE). As part of on piping and components, such as the effect of our company's in-house safety system functional high temperature and thermal stresses, and (5)

A-63 NUREG-1482 1

j

the radiological exposure to plant personnel and revision to its IST program was subsequently the public caused by the leak, if any of the submitted for NRC review. De NRC staff above considerations indicate that Category C determined that a review of the IST program testing may not be adequate, licensees should could not be completed in the necessary time assign the check valve to Category A/C and frame. In the context of Generic Letter 89-04, should comply with the associated leak testing LaSalle, therefore, has been classined as a plant requirements.

that does not possess a current SER and will not be receiving an SER. As a result, LaSalle is Question Group 108 expected to respond to the generic letter in accordance with the implementation provisions Questions for plants not listed in Table 1 or 2.

What is the NRC's op.nior., per Generic Letter Question Group 110 89-04, of non-quantifiable demonstrations of performance? For example, a solenoid valve has Questions no position indication that can be observed or timed, but bearing temperatures show no What additional NRC guidelines can be provided overheating.

on testing skid-mounted pumps and valves (i.e.,

diesel generator systems: lube oil pumps / valves,

Response

internal engine cooling; RCIC systems -

condensate vacuum pumps with only one source The NRC staff is discouraging the use of of power, etc.)7 Most of these pumps and qualitative criteria as an alternative to the Code-valves do not have the necessary test required component testing. Licensees should instrumentation to support ASME Section XI strive to develop a quantitative method of tesjng and do not fall within the scope determining the ability of a component to statements of IWP and IWV. Will modifications perform its required functions. This need to be performed?

recommendation is based on the goal of IST to detect degradation prior to failure of the

Response

component. For specific examples, see the response to Question 1. With respect to the The purpose of inservice testing is to provide specific question, more details would be assurance of the operability of components and necessary before arriving at the acceptability of to detect degradation in their performance.

the suggested method.

Where a particular component is integrated with other components in a system, it may be difficult Question Group 109 to perform an individual test of that component.

In specific cases for which individual testing is Questions not feasible, an alternate test should be proposed by the licensee. In developing an alternate test, Should LaSalle County Station be on Table 2 of the licensee should attempt to develop Generic Letter 89-047 If not, why? Zion quantitative criteria to evaluate the operability Station underwent the same review 2 months and condition of the component.

after LaSalle and they appear on Table 2.

Response

Although the LaSalle nuclear power plant received an SER about a year ago, a significant NUREG-1482 A-64 x

possibly maintenanct, where the leak rate of a Current Considerations large valve increases beyond a specified amount from one test to anot ur. In Position 10 of the Refer to Section 3.4.

generic letter, the NRC stad explains its view that this provir. ion of tha Code may not be Question Group 111 worthwhile and may be suspended. - Although the ASME Code is weak in the area of trending,

~

Guestions the NRC staff remains of the view that trending is a valuable tool in the IST program. The Is temporary flow instrumentation (i.e., portable Commission's regulations can be interpreted to flow meter) permitted in lieu of a modification require efforts in this area. More explicit to install permanent flow instrumentation? If so, guidance for trending may be developed in the is relief required?

future. In the meantime, we recommend that <

licensees analyze IST data to take advantage of

Response

the benefits of trending.

The staff does not interpret the ASME Code as excluding the use of portable flow rate instrumentation, such as ultrasonic. We have seen difficulty, however, in meeting the Code-specified accuracy requirements with these instruments.

Question Group 112

)

Questions is trending a requirement for pumps? 'Is it a requirement for valves? The Code and the regulations do not address this, nor does the generic letter.

)

Resnonse We define "tre. ding" as the analysis of test data to detect degradation of the tested component and to enable preventive maintenance to be performed before significant challenges to component operability occur. The ASME Code contains few requireme e, for trending of test 1

data. For example, the ASME Code in IWV-

,l 3417(a) provides for more frequent stroke-time J

testing of power-operated valves where an increase in stroke time is seen from a previous j

test. The NRC staff allows a reference value to be used for this comparison in Position 6 of Generic Letter 89-04. In IWV-3427(b), the Code provides for more frequ(, testing, and

- A-65 '

NUREG-1482

,_~

- i f

i APPENDIX B VALVE TABLES a

h a

f NUREG-1482 '

B.1

-c

Z POINT BEACli NUCLEAR PLANT INSERVICE TESTING PHOGRAM tT1 INSERVICE TESTING PROGRAM Revision 4 March 30,1993 g

APPENDIX E VALVE PROGRAM TABLE UNIT 2 SYSTEM:

Containmens Spray DRAWING NO.:

M-110ED35, Shees 3 VALVE CORD FUNCTION CIASS CAT SIZE TYPE ACT POS REQMT FREQ REMARKS S3410860C ClO CS Pump l-P1451 -

2 B

6 GA MO C

BT-O QR Disch PIT QR SI4100600 CIO CS Pump I-P14B 2

B 6

GA MO C

BT-O QR Disch PIT QR 5140862A Ill CS Puig l-P14A 2

A/C 6

CK SA C

CV-O QR Disch SLT-I RR V RR-23, 29 CD ab SI408628 Cil CS Pump I.Pl4B 2

A/C 6

CK SA C

CV-O QR Disch SLT-l RR VR R-23, 29 SI40862G Hit Train *A* Test 2

A 6

GA MA C

SLT-1 RR Passive laolation V RR-23 5140062H Dil Train *8* Test 2

A 6

GA MA C

SLT-1 RR Passive Isolation VRR-23 S840064A Hit CS Pump Test Recirc 2

A

.75 GL MA C

SLT-1 RR Passive VRR-23 S14(18648 Cll CS Pump Test Recirc 2

A 75 GL MA C

SLT-1 RR Passive VRR-23

$140068A Ill CS Nor13e A Hdr 2

A 6

GA MA O

SLT-1 RR Passive isolation VRR-23 S140068B Cl2 CS Noule B Hdr -

2 A

6 GA MA O

SLT-1 RR Passive Isolation VRR-23 Page 16 of 52 l

Quad Cities Nuclear Power Station, Units 1 and 2 INSERVICE TESTING PROGRAM - VALVES l

Table 1.0 7 l

UNIT 1 VALVE L!5 TING DRAWING. M-0048 DRAWING TITLE HIGH PRE 55tRE COOLANT INJECTION PIP!NG RELIEF NORMAL REQUEST DWG 15T FUNCTION $1ZE 800Y ACTU-P051-TIST TEST OR COLO TECHN!tAL VALVE NUMBER COOR CLASS CATEGORY (INCN) STYLE ATOR T!0N TYPE FREQ $4/T00WN P051 TION 2301 003 -M0 A-7 2

8 10.000 GA M0 C

BTO M3 FIT Y2 FUNCTION HPCI STEAM SUPPLY / BLOCKING VALVE, PSE-MEATS TR $UPPLY LINE 2301 004 -M0 C-9 1

A 10.000 GA M0 O

AT-01 Rt l

BTC C5 C5 23A B70 CS C5-23A Plf Y2 FUNCTION HPCI STEAM $UPPLY F110M THE REACTOR VE5SEL TO THE Tut 91NE j

2301-005 -M0 8-10 1 A

10.000 6A MO O

AT-01 At BTC CS C5 23A B70 CS C5 23A PIT Y2 FUNCTION HPCI STEAM $UPPLY FROM T4 REACTOR VE5SEL TO T4 TLRBINE J

2301-007 -AD E-6 2

C 14.000 CK A0 SYS CTO C5 C5-00A P!T Y2 FUNCTION HPCI INJECTION LINE TO FEE 0 WATER BACKFLOW PREVENTION 2301-008 -No E-6 2

8 14.000 GA N)

C BTO M3 P!T Y2 FUNCTION HPCI INJECTION LINE TO FEE 0 WATER !$0LAfl0M

)

2301-009 -M0 E-5 2

8 14.000 GA MO 0

BTO M3 PIT Y2 I

FUNCTION HPCI INJECTION LINE TO FEE 0 WATER 150LAT!0N I

2301-010 -MO E5 2 8

12.000 GL M0 C

BTC M3 PIT Y2 FUNCTION HPCI FULL FLOW TEST RETLRu TO CONDEN5 ATE STORAGE TANK 2301-014 -M0 C6 2 8

4.000 GL MD C

5fC M3 1

870 M3 P!T Y2 FUNCTION, WCl MIN! MUM FLOW RECitCULATION LINE !$0LAT!0N i

2301-020 E-1 2

C 18.000 CK SA SYS CTC 1A RV-00F FUNCTION + *Cl TO C0eENSATE STORA4E TANK BACKFLOW PREVENT 10N 2301 023 -av 8-3 2

C 1.500 RV SA C

CT SP YA FUNCTION : WC1800$TER SUCTION LINE OVERPRESSI.RE Pt0TECTION 2301-C28 D-10 1 A/C 1.000 KFC 1A STS AT-02 Rt CTC RR RV-006 FlacTION t MAlu $TM TO HPCI OP/P HI 110E EXCE55 FL N CK VLV 2301-027 0-10 1 A/C 1.000 KFC 1A Sf3 AT-02 Rk CTC Rt tv-006 FLE.CTION MAIN STM TO HPCI OP/P LO $10E EXCESS FLOW CK VLV Revision 4 VALVES 1-62 B-3 NUREG-1482

Z Sw?S 1 R$T VALVE TESTIsso OUTLMtf f

SYSTEM MAME: umn Steam SYSTf M NUMBER 21 Vafwe Draus4m3 CSJer g <

g w

Wasve Marti Vapw.

Waeve Stas Vaeve Tees Renee m *_

3auseer Casa Category (kk)

Type NSA OM fee Caere Rogueresseru Rewis Ceemments g y PCV-1MS-101 A 2

8 8

Glee A

21 1 A5 QST CSJ23 10ST 110 Stroke & Time OpenfCkned (CSDMRPV) y z

a SV-1MS 101 A 2

C 5 a 10 Rehef 21-1 34 SPT 1BVT 1211 m 1BVT 121.2 (R)

,a e

d

• TV-1MS-101A 2

B/C 32 inverse O

21-1 84 QST CSJ24 10ST-214 Stroke & Time Oosed (CSDMRPV)

O Chedt a

3 O

MOV-1MS-1018 2

8 2

cm S

21-1 E4 QST 10ST 4T.3A(38) Stroke & Time Oosed (QMRPV) gn>

MRV-1MS-1018 2

BC 32 Ched O

21-1 D-4 QS CSJ22 10ST-1.10 f S.RD (CSOMRPV)

E wO PCV-tuS-1018 2

8 8

Gaee A

21-1 C5 QS1 CSJ23 10ST-1.10 5troke & Time open#Oosa1(CSDMRPv) 3 DC SV tuS-1018 2

C S a to Rehef 21-1 D4 SPT 1BVT 1211 or 1BVT 1.212 (R) 5 h

C 3

C1 2

g TV-1MS-1018 2

B7C 32 inverse O

21 1 D-4 QST CSJ24 10ST 215 Stroke & Trme Oosed (CSDNRPV)

Chada o

MOV-tus-101C 2

8 2

Gacco S

21 1 Ge QST 10ST 47.3A(38) Stroke & Time Oosed (QMRPV) h r-<

NRV-1MS-101C 2

B/C 32 Check O

21-1 F -4 QS CSJ22 10ST 1.10 f S.RD (CSDMRPV)

PCV-1MS-10lC 2

0 8

Globe A

21-1 E-5 QST CSJ23 10ST-1.to Stroke & Time open/Gosed (CSDMRPV)

SV-1MS-101C 2

C 5 m 10 Reasof 21 1 E4 SPT 1BVT 1.211 m 1BVT 1.21.2 (R)

TV-1MS-101C 2

B#C 32 Inverse O

21-1 FG QST CSJ24 1OSI 218 Stroke & Time Oosed (CSD)(RPV)

Cher.k SV-1MS-102A 2

C 8 m 10 Repet

• 11 04 SPT 1BVT 1211 or 1BVT 1.212 (R)

SV-1MS-102B 2

C 8 m 10 Rehef 21-1 IN SPT 1BVT 1211 or 1BVT 1212 (R) en SV-1MS 102C 2

C 8 x 10 Rehet 21 1 E4 SPT 1BVT 1211 m 1BVT 1212 tR)

$!e 0.L o..

=*

SV 1MS-103A 2

C 6m10 Rehef 21 1 B4 SPT 1BVT 1211 or 1BVT 1212 (R) 3 m

I 6 ".

i CO %HCHE PEAK STEAM ELECTRIC STAtl0N UNIT 1 & 2 INSERVICE VALVE TE511NG PLAN TABLE 4 - CMMICAL and WIUME C(NTRCL PAGE 9 0F 12 Test Parameters / Schedule Flos Valve /

Safety fail Fosition Valve Diagram A twater Code

.Cate-F unc-Func.

Leak

[sercise Safe Indicator

$l g (ing gg_ry_

tion Pos.

Int fest Tnt TelLt Rmarks NWp (Coord,)

Tvoc t

8378A Mi-0253-A CK/5A 3

1 C

A 0

N/A CV/Q N/A N/A Boration F bpath (B-5)

(8) l2 M2-0255 (G-3)

C N/A CV/C5 N/A N/A Reactor Coolant Pressure (2)

Boundary RR V5 83788 M1-0253-A CK/5A 3

1 C

A 0

N/A CV/Q N/A N/A Boration Fleth (B-5)

(8) l2 M2-0255 (G-3)

C N/A CV/C5 N/A N/A Reactor Coolant Pressure (2)

Boundary RR V5 9

83794 M1-0253-A CK/5A 3

1 C

A 0

N/A CV/Q N/A N/A Boration M owpath (B-5)

(8) l2 M2-0255 (G-3)

C N/A CV/05 N/A N/A Reactor Coolant Pressure (2)

Boundary RR V5 83798 M1-0253-A CK/SA 3

1 C

A 0

N/A CV/Q h/A N/A Boration Flowpeth (B-5)

(8) l2 M2-0255 (6-3)

C N/A CV/05 N/A N/A Reactor Coolant Pressure (2)

Boundary RR VS bel M1-0253-A CK/5A 3

2 A,

A 0

N/A CV/Q N/A N/A Boration Flowpath (E-3)

M2-0255 C

LIJ/IS CV/C5 N/A N/A Contairnent Isolation (E-2)

(2)

Zd b9 Rev. 2 E

ApriI 30. 1993 co g

i' ASME SECTION XI VALVES UNIT 2 Z

-: Test TeFt'. Test D h

AW, Mvv y u c & Q % a y [ Code..hhfh1D.lVh'D&hi_l&& i^{$dnctioEllO lfiscl Typs S&$i s

f}&Q$ggy%

h Agh.

gg6 "np Vetve :,

>+m 7 s

ygdhll tT1 j$$l$2'&l5fn

.w Q

/

2CC-73-1 2CC 21 RCP BRG WTR SUPPLY CHK NF-39 24 6-1 39 C

ACT 4 PEN E

Q sN 2CC-73-2 2CC 22 RCP BRG WTR SUPPLY CHK NF-392481 39 C

ACT-OPEN E

Q CV31253 2CC 21 EXCS LTDWN HT EXCH OUTLET NF-392461 39 B

ACT-CLOSE E

O MV32122 2CC COMP COOLING WTR SUPPLY HEADER NF-39246-1 39 8

ACT-CLOSE SP-2163 E

R MV32123 2CC COMP COOUNG WTR SUPPLY HEADER NF-39 24 6-1 39 B

ACT-CLOSE SP-2163 E

R MV32124 2CC 21 REACT CLNT PUMP BRG CLG WTR SUPPLY NF-3924 6-1 39 B

PAS 4 PEN PV 2Y MV32125 2CC 21 REACT CLNT PUMP BRG CLG WTR RETURN NF-3924 6-1 39 8

PAS 4 PEN PV 2Y MV32126 2CC 22 REACT CLNT PUMP BRG CLG WTR SUPPLY NF-39246-1 39 B

PAS-OPEN PV 2Y MV32127 2CC 22 REACT CLNT PUMP BRG CLG WTR RETURN NF-39246-1 39 B

PASCPEN PV 2Y MV32128 2CC 21 RSOL HT EXGR COMP CLNT *NLT MV NF-39246-1 39 B

ACT-BOTH SP-2155 E

O g

MV32129 2CC 22 RSOL HT EXGR COMP CLNT INLT MV NF-392461 39 B

ACT-BOTH SP-2155 E

O MV32130 2CC 21 EXCESS LETDOWN HT EXCH SUPPLY NF-3924 6-1 39 B

ACT-CLOSE E

O MV32211 2CC 21 COMP CLG PMP $UCT MV NF-39246-1 39 B

ACT-BOTH SP-2155 E

O MV32212 2CC 22 COMP CLG PMP SUCT MV NF-3924 6-1 39 B

ACT-BOTH SP-2155 E

O MV32268 2CC 21/22 RCP COMP CLG INLT ISOL MV B NF-3 9246-1 39 8

ACT-BOT 9 SP-2163 E

R MV32269 2CC 21/22 RCP COMP CLG INLT ISOL MV A NF-39240-1 39 B

ACT40TH SP-2163 E

R 2CL-121 2CL 21 CONTAINMENT FAN COlLS-SUPPLY NF 39217-3 36 C

ACT-OPEN E

Q 2CL 12-2 2CL 23 CONTAINMENT FAN COtLS-SUPPLY NF-39217-3 36 C

ACT-OPEN E

O 2CL 12-3 2CL 22 CONTAINMENT FAN COtLS-SUPPLY NF-39217-3 36 C

ACT4 PEN E

O 2CL 12-4 2CL 24 CONTAINMENT FAN COtLS-SUPPLY NF-39217 3 36 C

ACT-OPEN E

Q 2CL-43-1 2CL 21 CLG WTR PUMP D!SCH NF-39216 36 C

ACT-CLOSE SP-11068 E

O Pt IST 2.3 -6 l

3vd to Year Program Rev 2 8/20!93 g

APPENDIX C RELIEF REQUESTS i

I C-1 NUREG-1482 -.

n ILLINOIS POWER COMPANY Clinton Power Station ASME Section XI Relief Request RELIEF REQUEST 2014 (Revision 3)

'rhese testable check valves COMPONENT INFORMATION (1E12-F041 A/B/C,1E21-F006, and 1E22-F005) provide isolation from the reactor coolant system and the emergency core cooling systems (Residual Heat Removal, Low Pressure Core Spray, High Pressure Core Spray). These valves are ASME Section III Code Class 1,

Section XI Category A/C valves.

Valves 1E12-F041 A,B, and C are 12" diameter and valves 1E21-F006 and IE22-F005 are 10" diameter. All of these v=lves are non-slam check valves. One of these valves (1E12-F041A), which is typical of the group, is circled on the attached drawing.

The ASME

Code,Section XI, CODE REQUIREMENTS Subsection IWV-3520 requires that these valves be exercised every three (3) months unless such operation is not practical during plant operation.

In this situation, the valves may be part-stroke exercised during plant operation and full-stroke exercised during cold shutdown.

Exercising these valves on a RELIEF REQUEST / JUSTIFICATION three month frequency using the emergency core cooling system pumps to inject water into the reactor is not in the interest of plant safety, because this cooler water would create an undesirable power transient.

In addition, neither the Low Pressure Core Spray nor Residual Heat Removal pumps are capable of opening their injection valves against full reactor pressure.

Mechanically exercising these valves during reactor operation is not practical because they are located inside the dryvell and access is restricted due to radiation conditions.

Mechanically exercising these valves on a cold shutdown frequency as allowed by the ASME Code is not practical because the air operator is not designed to perform a full stroke test.

Although the air operator can be removed to perform the full stroke test, this is a significant maintenance activity and could interfere with work which is necessary to restore the plant to service.

This would create an unreasonable hardship for Illinois Power Company.

Using pump pressure to exercise these valves during cold shutdown is also not in the interest of plant safety. Although temperature could be matched fairly closely between the injection source (emergency core cooling systems) and the reactor, a minor thermal mismatch between these temperatures creates an undesirable effect on the fatigue life of the reactor nozzles.

In addition, the injection lines associated with the residual heat removal system nozzles are not equipped with internal spargers.

General Electric Service Inf ormation Letter 401 identifies problems in injecting water through this flow path and the potential damage to nuclear instrumentation or fuel assemblies which could occur if this flow path were used for other than emergency conditions.

Illinois Power Company will full ALTERNATE TESTING PROPOSED stroke exercise the valves during refueling by measuring the torque required to lift the disc and then move the disc through a full stroke.

I NUREG-1482 C-2 L_

eere t~

5gii.riee ggg5 c

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l[st eFMI t(IF495 NUREG-1482 C-3

Pr ge 1 of 3 RELIEF REQUEST PR-12 Third Ten-Year Interval IST Program Revision 3 System:

Service Water Comoonents:

Service water pumps PSWO-1A/B/C/D Comconent Function:

Cooling for safety-related coolers following design basis accident; ultimate heat sink.

Code Reauirements:

IWP-4110 and IWP-4120 for flowrate instrumentation accuracy and full-scale range.

Description of Relief:

Previously, the service water pump testing for pumps PSWO-1A, -18, -1C, and -

10, was conducted at a flow rate approximately one-half accident flow rate in order to utilize flow instrumentation installed to measure service water flow through containment recirculation fan coolers, in response to a recommendation made by NRC during the team inspection of the service water system, November / December 1991, a new test methodology is proposed in PR-12.

This effectively eliminates the need for Relief Request PR-7, and it is withdrawn upon NRC approval of PR-12. The new test method is expected to be implemented in the tests scheduled for November 1992.

The new test method will also provide full flow exercising of the service water pump discharge check valves 4601, 4602, 4603, and 4604.

This will eliminate the need for employing a disassembly and inspection program for these four valves discussed in Relief Request VR-17, and it is withdrawn upon NRC approval of PR-12.

The change also permits reclassification of twelve manual butterfly valves which function as the inlet and outlet valves for the four containment recirculation fan coolers and the two reactor compartment coolers from " Category A - Active" to " Category A - Passive." The appropriate changes to the IST Program for these valves will be made.

These changes do not effect existing or new relief requests.

Basis for Relief:

The present system configuration and instrumentation does not provide permanently installed flow indication at the SW [ service water) pump discharge

\\.

piping to provide a positive means of determining full flow during pump tests.

Employing a clamp-on ultrasonic flowmeter to measure full SW pump discharge flow is not currently addressed in ASME Section XI, Subsection IWP (Code).

g The Code requires an instrument accuracy of 2% of full scale.

The clamp-on ultrasonic flowmeter possesses an instrument accuracy of 3% of actual flow.

Although the percentage error (3% of the actual flow as compared with 2% of l

NUREG-1482 C-4 i..i-

Page 2 of 3 I

full scale) is stated as a larger numerical value, the actual absolute value of instrument inaccuracy at the reference flow rate of 5,600 gpm (approximate SW pump design [ flow rate]) is actually less for the clamp-on ultrasonic flowmeter.

The accuracy of the reading from a 1 - 10,000 gpm analog gauge is 5,600 200 gpm (2% of full scale). The accuracy of the reading from the clamp-on ultrasonic flowmeter is 5,600 168 gpm (3% of actual flow).

Thus the actual maximum instrument error of the flow reading, as read on the clamp-on ultrasonic flowmeter, is less than the error as read on the analog gauge at the specified flow rate of 5,600 gpm.

The full-scale range (calibrated) of the clamp-on ultrasonic flowmeter is 40 ft./sec.

This corresponds to a flow rate of approximately 17,000 gpm (for 14 inch pipe), which exceeds three times the reference value of 5,600 gpm.

Relief is requested to utilize a digital flowrate instrument for inservice testing of the service water pumps.

Relief is required because the accuracy of the measurement will not be 2% over the calibrated range as required by OM-6, Table 1, Nc'e (1).

The accuracy will be 3% over the calibrated range (percent of read ag) based on the piping configuration and the location for placement of the instrument.

However, the accuracy achieved is more accurate than would be achieved with analog instrumentation which is required to be 2% of full scale (no more than three time reference value).

The digital clamp-on ultrasonic flowmeter yields a more accurate flow reading at the specified SW pump test flow rate of 5,600 gpm than an analog instrument and the range of the clamp-on ultrasonic flowmeter meets the requirement of ASME/ ANSI OMa-1988, Part 6, Paragraph 4.6.1.2(b), i.e. reference flow rate <

70% of calibrated range.

Repeatability of the digital readings will be assured by permanently mounting the instrument. With a 3% of reading accuracy, the digital reading will be in the range of 5432 gpm to 5712 gpm.

An analog instrument with a 2% accuracy and a range of three time the reference would provide a reading in the range of i 336 gpm (5264 gpm to 5936 gpm).

In order to meet the recuracy requirements of OM-6 for digital instrumentation, modifications to the piping would be required in order to place the clamp-on flowmeter in a location five pipe diameters from an elbow.

Similar modifications would be required to install permanent flow measurement analog instrumentation which would even then not provide a reading as accurate as will be achieved with the clamp-on flowmeter.

Compliance with OM-6 would be a hardship without a compensating increase in the level of quality and safety, with the hardship being the modifications that would be required, with the accuracy of the reading not being increased.

i l

l i

NUREG-1482 C-5

Page 3 of 3 This substantial improvement in test method provides for the measurement of a sufficiently accurate and repeatable value for SW pump flow rate. By employing this test method and obtaining the pump's corresponding differential pressure, the hydraulic performance of the SW pump can be more accurately assessed.

Repeatability of flow rate measurement will be ensured through the permanent installation of clamp-on ultrasonic flowmeter instrumentation via the [XXX] Station minor modification process.

Alternative Testina l

SW pump flow testing will utilize a permanently installed clamp-on ultrasonic flowmeter to allow rate measurement at a reference flow equivalent to the i

design point of the SW pumps.

I NUREG-1482 C-6

Page 1 of 2 RELIEF REQUEST NO.

V2 SYSTEM Component Cooling Water VALVE NUMBERS ICC-1079/1080 10C-1081/1082 2CC-1091/1092 200-1093/1094 CATEGORY A/C, C CLASS 3

FUNCTION These check valves form the boundary between the non-safety Instrument Air or Nitrogen supply systems and the safety-grade accumulator and receiver tanks. The tanks provide an emergency air or nitrogen supply to certain safety-related components.

The check valves are required to close upon failure of the air or nitrogen supply system in order to contain the compressed gas in the tanks.

TEST REQUIREMENT OM Part 10, para 4.3.2, " Exercising Tests for Check Valves" BASIS FOR RELIEF Each valve listed is one of two check valves in series at the inlet to a safety-grade accumulator or receiver tank.

In each case, only one check valve is required in order to meet the safety class interface criteria of ANSI N18.2a-1975.

However, two check valves are provided for added reliability, not for redundancy. The safety-related components served by the accumulator and receiver tanks are redundant to other similar components which have their own dedicated safety-grade air supplies. As long as one of the check valves in the pair is capable of closure, then the safety analysis assumptions for the check valves are met.

Some of the check valve pairs do not have provisions for testing each valve individually.

However, the closure capability of each pair of check valves can be verified.

i NUREG-1482 C-7

l Page 2 of 2 SUBSTITUTE TEST Each pair of series check valves will be exercise tested at the required frequency by some positive means to verify the closure capability of at least one of the valves. No additional exercise testing will be performed unless there is an indication that the closure capability of the pair of valves is questionable.

In that case, both valves will be declared inoperable and not returned to service until they are either repaired or replaced.

DRAWINGS:

M-2236, SAR Figure 9.2.6-4

REFERENCES:

ANSI N18.2a-1975 i

NUREG-1482 C-8

l Page 1 of2 RELIEF RE0 VEST VR-13 Valve Numbers:

IDG5182A,B 2DG5182A,8 IDG5183A,B 2DG5183A,B 1DG5184A,B 2DG5184A,B 1DG5185A,B 2DG5185A,B Number of Items:

16 ASME Code Cateoorv:

B&C ASME Code Section XI Reauirements:

These valves are not within the scope of ASME Code,Section XI, Subsection IWV requirements.

However, the requirements for stroke timing and trending of the valves associated with the Diesel Air Start System are being included as augmented components for inservice testing. These valves associated with the Diesel Air Start System shall be exercised to the position required to fulfill their function during plant operation per IWV-3412 and IwV-3522. -Additionally, the stroke testing of power operated valves shall be measured to the nearest second and such stroke times trended to document continued valve operational readiness per IWV-3413 (b) and IWV-3417.

Basis for Relief:

The monthly Diesel Generator testing program, outlined in XXXX Station Technical Specifications and implemented by station operating procedures, exceeds the intent of the quarterly valve testing program which would be required by ASME Code,Section XI.

Additionally, the stroke timing of solenoid operated valves associated with the Diesel Air Start System is impractical due to the fast actuation of these valves.

Alternative Testina:

1 The performance of XXX Station's Diesel Generator operability monthly surveillance will verify the operational readiness of the-valves associated with the Diesel Air-Start System. This surveillance testing will require the recording of the air pressures contained in both trains NUREG-1482 C.9

Page 2 of 2 RELIEF RE00EST VR-13 (continued)

A & B of the Diesel Generator Air Start Receiver Tanks both before and immediately after diesel generator start.

By the comparison of these valves between trains, the satisfactory operation of the power operated and self-actuated check valves associated with the Diesel Air Start System can be adequately demonstrated. On an alternating basis, a portion of the air start system will be isolated and depressurized prior to diesel start.

This will allow verification that the air start system check valves in the unisolated portion stroke open.

NUREG-1482 C-10

t RELIEF REQUEST NUMBER GR-4 System:

Various Valve:

Various Category:

A, B Class:

Various Function: Various impractical Test Requirements: IWV 3413; Power Operated Valves Corrective Action, IWV 3417; Corrective Action Basis for Rollef: Generic Letter 89 04 Position 6 recognizes that measuring changes in stroke times from a reference value as opposed to measuring changes from the previous test is a better way to detect valve degradation. Generic Letter 89 04 Position 5 and OMa 1988, Part 1

10 provide NRC approved methodology for establishing a stroke time reference value, an acceptable stroke time band, and a limiting stroke time value. The altemative testing is in accordance with this methodology.

Attornative Testing. The power operated valve testing will be performed in accordance with OMa 1988, Part 10, paragraphs 4.2.1.4, 4.2.1.8, and 4.2.1.9. The acceptable band and Limiting Stroke Time (LST) will be determined as follows (RV time in Sec):

Ooerator Tvoe Ref. Value Acc. Band -

LSI Motor RV > 10 0.85RV - 1.15RV 1.3RV 2 s RV s 10 0.75RV - 1.25RV 1.5RV Other RV > 10 0.75RV - 1.25RV 1.5RV 2s RV s10 0.50RV 1.50RV 2.ORV l

All RV < 2 s2 2

In addition,if a more restrictive value of stroke time exists in the Technical Specifications or the Updated Safety Analysis Report, it will be used as the LST instead of the value l

calculated above.

Approval: Relief granted with provisions in SER dated September 24,1992.

l l

NUREG-1482 C-11 i

l l

Page 3.6-13 Revision 4 RELIEF REQUEST NO. RP-8 System:

Standby Service Water I'lA2E11 Pump Code Class P& I D Dwg. Number SW-P-1A 3

M524, SH 1 SW-PelB 3

M524, SH 2 HPCS-P-2 3

M524, SH 1 i

Section XI Code Recuirements For Which Relief is Recuested:

IWP-3100 requires that the system resistance be varied until either the measured differential pressure or measured flow rate equals the corresponding reference value.

The quantities of Table IWP-3100-1 are then measured or observed and compared to the corresponding reference value.

Basis for Relief:

1.

Service Water systems are designed such that the total pump flow cannot be adjusted to one finite value for the purpose of testing without adversely affecting the system flow balance and Technical Specification operability requirements.

Thus these pumps must be tested in a manner that the service water loop remains properly flow balanced during and after the testing and each supplied load remains fully operable per Technical Specifications to maintain the required level of plant safety during power operation.

2.

The service water system loops are not designed with a full flow test line with a single throttle valve.

Thus the flow cannot be throttled to a fixed reference value every time. Total pump flow rate can only be measured using the total system flow indication installed on the common return header. There are no valves in any of the loops, either on the common supply or return lines, available for the purpose of throttling total system flow.

Only the flows of the served components can be individually throttled.

Each main loop of service water supplies 17-18 safety related loads, all piped in parallel with each other.

The HPCS-P-2 pump loop supplies four loads, each in parallel.

Each pump is completely independent from the others (no loads are common between the pumps).

Each load is throttled to a FSAR required flow range which must be satisfied for i

NUREG-1482 C-12

Page 3.6-14 Revision 4 Relief Request RP-8 (Continued) the load to be operable. All loads are aligned in parallel, and all receive service water flow when the g

associated service water pump is running, regardless of whether the served component itself is in service.

During power operation, all loops of service water are required to be operable per Technical Specifications.

A loop of service water cannot be taken out of service for testing without entering an Action Statement for a Limiting Condition for Operation (LCO).

Individual component flows outside of the FSAR mandated flow ranges also induce their own Technical Specification action statements that in turn can induce full plant

(

shutdown in as little as two hours, depending on the load in question.

3.

Each loop of service water is flow balanced before exiting each annual refueling outage to ensure that all loads are adequately supplied.

A flow range is specified for each load to balance all the flows against each other.

Once properly flow balanced, very little flow adjustment can be made for any one particular load without adversely impacting the operability of the remaining loads (increasing flow for one load reduces flow for all the others).

Each time the system is flow balanced, proper individual component flows are produced, but this in turn does not necessarily result in one specific value for total flow.

Because each load has an acceptable flow range, overall system full flow (the sum of the individual loads) also has a range. Total system flow can conceivably be in the ranges of 9247 - 10,079 GPM for SW-P-1A pump, 9212 - 10,043 GPM for SW-P-1B pump, and 1050 - 1158 GPM for HPCS-P-2 pump.

Consequently, the desire to quarterly adjust service water loop flow to one specific flow value for the performance of inservice testing conflicts with system design and component operability requirements (i.e. flow balance) as required by Technical Specifications.

Alternate Testina to be Performed:

As discussed above in the basis for relief section, it is extremely difficult or impossible to return to a specific value of flow rate or differential pressure for testing of these pumps.

Multiple reference points could be established according to the Code, but it would be impossible to obtain reference values at every possible point, even over a small range.

An alternate to testing requirements of IWP-3100 is to base the acceptance criteria on a reference curve.

Flow rate and discharge pressure are measured during inservice testing in the as found condition and compared to an established reference curve.

Discharge pressure instead of I

C-13 NUREG-1482

l Page 3.6-15 Revision 4 Relief Request RP-8 (Continued) differential pressure is used to determine pump operational readiness as allowed by Relief Request RP-3 (Relief granted per SER/TER Reference 2.3.1, dated May 7, 1991).

The following elements are used in developing and implementing the reference pump curves.

1.

A reference pump curve (flow rate vs discharge pressure) has been established for SW-P-1A and SW-P-1B from data taken on these pumps when they were known to be operating acceptably.

These pump curves represent pump performance almost identical to preoperational test data.

The methodology employed for establishing a reference pump curve is similar to that for performing a comprehensive test being proposed by the OM Code Committee.

2.

Pump curves are based on seven or more test points beyond the flat portion of the curve (at flow rate greater than 4800 gpm).

Rated capacity of these pumps is 12,000 gpm.

Three or more test data points were at flow rate greater than 9,000 gpm. The pumps are being tested at full design flow rate.

3.

To reduce the uncertainty associated with the pump curves and the adequacy of the acceptance criteria, special test gauges ( 0.5% full scale accuracy) were installed to take test data in addition to plant installed gauges and Transient Data Acquisition System (TDAS).

All instruments used either met or exceeded the Code required accuracy.

4.

For HPCS-P-2 pump, the reference pump curve is based on the manufacturer's pump curve which was validated during the preoperational testing.

5.

Review of the pump hydraulic data trend plots indicates close correlation with the established pump reference curves, thus further validating the accuracy and adequacy of the pump curves to assess pumps operational readiness.

6.

The reference pump curves are based on flow rate vs discharge pressure.

Acceptance criteria curves are based on differential pressure limits given in Table IWP-3100-2.

Setting the Code Acceptance Criteria on discharge pressure using differential limits is slightly more conservative for these pump installations with suction lift (Relief Request RP-3, SER/TER Reference 2.3.1, dated May 7, 1991).

See the attached sample SW-p-1A pump Acceptance Criteria sheet.

Area 1-2-3-4 is the acceptable range for pump performance.

Areas outside 1-2-3-4 but within 5-6-7-8 define the Alert Range, and the areas outside 5-6-7-8 define the I

l NUREG-1482 C-14

Page 3.6-16 Revision 4 Relief Request RE-1 (Continued) required Action Range.

These acceptance criteria limits do not conflict with Technical Specifications or Final Safety Analysis Report operability criteria.

7.

Only a small portion of the established reference curve is being used to accommodate flow rate variance due to flow balancing of various system loada.

8.

Review of vibration data trend plots indicates that the change in vibration readings over the narrow range of pump curves being used is insignificant and thus only one fixed reference value has been assigned for each vibration location.

9.

After any maintenance or repair that may affect the existing reference pump curve, a new reference pump curve shall be determined or the existing pump curve revalidated by an inservice test.

New reference pump curve shall be established based cu at least 5 points beyond the flat portion of the pump curve.

Qualitv/ Safety Imoact:

Design of WNP-2 Service Water System and the Technical i

Specifications requirements make it impractical to adjust system flow to a fixed reference value for inservice testing without adversely affecting the system flow balance and Technical Specification operability requirements.

Proposed alternate testing l

using a reference pump curve for each pump provides adequate assurance and accuracy in monitoring pump condition to assess pump operational readiness and shall adequately detect pump degradation.

Alternate testing will have no adverse impact on plant and public safety.

l L

4 I

NUREG-1482 C-15

]

i Page 3.6-17 Revision 4 Relief Request RP-B (Continued)

SAMPLE DATA SHEET SW-P-1A ACCEPTANCE CRITERIA l

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e FLOW-GPM ALE.RT RANGE Area Out de 12-3-4 ACTION RANGE-Aere Outside 5-6-7-8 NUREG-1482 C-16

D i

APPENDIX D I

SAFETY EVALUATION i

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NUREG-1482 -

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1 UNITED STATES i

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NUCLEAR REGULATORY COMMISSION f

wAssinctos.. o c. acess s.,

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION REL ATED TO THE INSERVICE TESTING PROGRAM RE00ESTS FOR RELIEF ARIZONA PUBLIC SERVICE COMPANY. ET AL.

PALO VERDE NVCLEAR GENERATING STATION. UNITS 1. 2. AND 3 DOCKET NOS. 50-528. 50-529. AND 50-530

1.0 INTRODUCTION

Section 50.55a of Title 10 of the Code of Federal Regulations, 10 CFR 50.55a, requires that inservice testing (IST) of certain ASME Class 1, 2, and 3 pumps and valves be performed in accordance with Section XI of the ASME Boller and Pressure Vessel Code and applicable Addenda, except where alternatives are authorized or rel1ef is granted by the Comunission pursuant to 11(a)(3)(1), (a)(3)(11), or (f)(6)ti) of Section 50.55a. In order to obtain authorization or relief, the licensee must demonstrate that (1) the proposed alternatives provide an acceptable level of quality and safety, (2) compliance would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety, or (3) conformance is impractical for its facility.

Section 50.55a authorizes the Commission to approve alternatives or grant relief from the ASME Code requirements upon making the necessary findings.

The NRC staff's findings with respect to the relief that has been requested and alternatives proposed as part of the licensee's IST program cre contained in this Safety Evaluation.

Section 50.55a(f)(6)(1) requires the Commission to evaluate determinations of impracticality and authorizes the Commission to grant relief and impose such alternative requirements as it deterstnes is authorized by law and will not endanger life or property or the coaumn defense and security and is otherwise in the public interest, giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.

By letter dated September 8,1992, Arizona Public Service Company (the licensee) requested approval of a revised relief request for the four safety injection tank discharge check valves V215 V225, Y23',. and V245; and the four sa'?./ injection line discharge check valves V217, V221. V237, and V247, 2.0 DISCUSSION AND EVALUATION The check valves which are the subject t.f this relief request provide NUREG-1482 D-2

! protection for the safety injection tanks and the high and low pressure safety injection lines from the higher pressure reactor coolant system during normal operation. In the event of a loss-of-coolant accident, the valves open to allow water to be delivered to the reactor vessel from the safety injection tanks and the safety injection system to cool the core.

The test requirement for these valves under Section XI of the ASME Code that is relevant to the relief requests is to full-stroke exercise the valves every l

3 month, or part-stroke exercise every 3 months and perfom a full-stroke test during cold shutdown, or perform a full-stroke test during cold shutdown if the valves cannot be part-stroked every three months.

l The licensee was granted relief from these requirements in an NRC letter dated I

November 15, 1988. The testing method approved in that letter is to part-j stroke exercise the safety injectico tank check valves in Mode 3 (hot standby)

(

after each refueling outage when the safety injection tank pressure is above

]

i 600 psig and to disassemble one valve of each type sech refueling outage to verify freedom of disc movement. If it is found that the disassembled valve's full-stroke capability is questionable, then all 3 other valves of that type would have to be disassembled and inspected.

],

In its letter of September 8,1992, APS croposes an alternate testing method which would consist of a full-stroke exwrcise of all 8 valves during each j

refueling outage. This would be accomplished by opening the safety injection i

tank isolation valve with pressure in the safety injection tank and with the reactor vessel head removed. This evo)Jtion would open a pair of the check

{

valves, one of each type. This would be repeated for the other 3 pairs until all 8 are tested. The licensee would monitor the level and pressure drop in i

i the safety injection tank to determine whether or not full opening of the valves was achieved.

The licenses has conducted two tests using the proposed rw ised method.

Acoustic data from both tests provided additional assurance that each valve actually stroked to the full open position during the test.

)

The NRC staff has reviewed the proposed alternate test method and finds it acceptable, s"bject to two conditions discussed below. The preoosed test l

method requires each valve to be tested in the manner in which it performs its i

safety function, and is therefore a s. ore realistic and improved test. It involves full stroking, as opposed to the current partial stroking. It also does not rely on ' valve disassembly, which activity offers the opportunity for reassembly errors. An added benefit of the revised method is the reduced personnel radiation exposure since the valves no longer have to be disassembled.

The NRC staff therefore finds the revised test method to be acceptable, provided that (1) the valves are partial-stroke tested each cold shutdown if i

they have not been tested within the past 3 months, and (2) one valve of each type is confirmed to have opened fully by a non-intrusive method (e.g.,

acoustics) each refueling o'tage on a rotating schedule such that all valves are confirmed in this manner in a series of four refuelings.

i i

NUREG-1482 D-3 h

l The NRC staff concurs with the licensee's continued determination that compliance with the code requirements is impractical in this case. Full-stroke exercising of these valves is not practical in any plant mode other than refueling shutdown when the reactor vessel head is removed. Part-stroke testing every 3 months is not practical since t plant shutdown would be required to perform the test. It is, however, practical to conduct a part-stroke tast at each cold shutdown. During cold shutdown, the safety injection chec' valves can be part-stroked by the normal flow delivered to the reactor coolant system via the shutdown cooling system. The safety injection tank discharge check valves can be tested in the same manner as they are currently being tested by part-stroke exercising in Mode 3 (hot standby) when the safety injection tank pressure is above 600 psig. The licensee has already confirmed in two separate tests that full openig of the valves can be established by acoustics.

As noted in the relief request, these valves also perform a safety function by closing to prevent over pressurization of SI piping from RCS pressure.

Similar to the required valve open exercising requirements, these valves must be verified to be closed every three months or during cold shutdown if the closure verification of these valves cannot be performed every three months.

Since these valves will be part-stroke mrcised at cold shutdowns and since the Technical Specifications requirt ieak testing of these valves after they are disturbed, the closure verification will be performed at cold shutdown through the leak testing. The licensee should either perform the closure verification every three months or prepare a cold shutdown justification if this testing is not practical and revise the IST program to reflect this testing, as appropriate

3.0 CONCLUSION

The revised valve Relief Requests Nos. 33 and 34 transmitted by APS letter dated September 8, 1992 are acceptable for implementation, provided that the check valves are part-stroked each cold shutdown, and provided further that one valve of each type is confir1med to have opene! fully by a non-intrusive method (e.g., acoustics) each refueling outage on i rotating schedule such that all valves are confirmed in this manner in a series of four refuelings.

The NRC staff has determined that granting of this relief pursuant to 10 CFR 50.55a(f)(6)(1) is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest. In making this determination, the NRC staff has considered the alternate testing being implemented and the impracticality of performing the required testing considering the burden if the requirements were imposed.

Date: October 23, 1992 l

NUREG-1482 D-4 l

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NGC Pomu 335 U $. NUCLEAR REGULATORY CoMMif,$loN

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Draf t Report for Coninent 3

DATE REPORT PUBLISHED MONTM VEAR 11 1993 Guidelines for Inservice Testing at Nuclear Power Plants

5. AUTHCH(S)

6. TYPE of REPORT P. Campbe11 Draft

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8 PE R F oRMING oRG ANIZ AT loN - N AME AND ADoH LS5 <t! NRC orove Omvon 0H.ve or Moroon. U.S Nucwar R.raktory Comonowan. and mastens.corees: or eontr.cear. osevede l

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.ad.a Division of Engineering Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Cormission Washington, DC 20555-0001 s svoNsoR nNa ono ANuia r\\oN - N Au e ANo AnaR t ss w sac. avo. s.n.

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10. $UPPLEMENTARY NOTES

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Issued for Public Comments

'1. ABST R ACT (100 word, or km/

In this report, the staff gives licensees guidelines for developing and implementing programs for the inservice testing of pumps and valves at commercial nuclear power plants. The report includes U.S. Nuclear Regulatory Commission (NRC) guidance and recommendations on inservice testing issues. The staff discusses the regulations, the components to be included in an inservice testing program, and the preparation and content of cold shutdown and refueling cutage justifications and requests for relief from the American Society of Mechanical Engineers Code requirements. 'Ihe staff also gives specific guidance on relief acceptable to the NRC and advises licensees in the use of this information for application at their facilities.

The staff discusscr % revised standard technical specifications for the inservice testing program requirements and gives guidance on the process a licensee may follow upon finding an instance of noncompliance with the Code.

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