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Forwards NRC Guidance for Preparing Pump & Valve Testing Program Descriptions & Associated Relief Requests Per 10CFR50.55a(g).Suppls 761124 Guidance Re Compliance W/ Inservice Insp Requirements
	ML20126E620
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	01/16/1978
From:	Desiree Davis; Office of Nuclear Reactor Regulation
To:	Bixel D; CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
References
	NUDOCS 8102060726
	Download: ML20126E620 (15)
	v • d • e

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l Docket No. 50-155 JAN 161978 t

Consumers Power Company ATTN: Mr. David A. Bixel l

Nuclear Licensing Adminstrator 212 West Michigan Avenue Jackson, Michigan 49201 1

.l Gentlemen:

RE: BIG ROCK P0!HT By letter dated November 24, 1976, we sent you a document entitled.

"lRC Staff Guidance for Complying with Certain Provisions of 10 CFR 50.5Sa(g), Inservice Inspection Requirements".

In addition to clarifying the proper methods for complying with the regulation, this cuidance provided a general outline of the type of infomation that the NRC staff would need to review inservice inspection and testing programs, and to evaluate requests for relief from ASME Code requirerients that

, j are determined to be impractical for a facility.

After reviewing a number of submittals relating to s50.55a(g) requirements from various licensecs, we have concluded that additional guidance would be useful to all licensees to aid in the preparation of these submittals.

('and any requests for relief from certain ASME Code requirementsand to The need for this quidance is particularly evident for the pump and valve testing requirements.

Enclosed for your use is the "NRC Staff Guidance for Preparing Punp and Valve Testing Program Descriptions and Associated Relief Requests Pursuant to 10 CFR 50.55a(g)". This enclosure defines the reouired scope of a pump and valve testing program, iter.lizes the specific infomation needed for staff review, and provides guidelines for submitting infomation to support requests for relief from any ASME Code requirements found to be impractical for a facility. The same information is being sent to all nuclear power plant licensees and is intended to complement and expand on the guidance we provided to i

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you in our previous letter. Although.the enclosure specifically addresses pump and valve testing requirements only, the same level of detailed information identified in this guidance should also be provided in inservice inspection program sutaittals.

j We request that you follow the enclosed guidance to the greatest extent possible when submitting proposed inservice inspection and i

i testing programs and requests for relief from ASME Code requirements, and when responding to additional inforr.ation requests from the staff.

Your adherence to this guidance will minimize the NRC staff review time needed to approve your proposed programs and associated relief requests.

If you have any questions regarding implementation of 10 CFR 50.55a(g) at your facility, please contact us.

Sincerely, i

e Don K. Davis, Chief l

Operating Reactors Branch $2 Division of Operating Reactors DISTRIBUTION:

Enclosure:

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Charles F. Bayless l

Of Counsel Consumers Power Company l

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NRC STAFF GUIDANCE FOR PREPARING PUMP AN TESTING PROGRAM DESCRIPTIONS AND ASSOCIATE RELIEF REQUESTS PURSUANT TO 10 CFR 50.55a(g)

The guidaace provided-in this enclosure is intended to illustrate pump and valve testing program descriptions requests for relief from ASME Code requirements.

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

1.

Pump and Valve Testing Program Description I

A.

Scope of the Program:

1.

The pump testing program should include all safety related*

Class 1, 2 and 3 pumps that are provided with an emergenc power source.

2.

The valve testing program should be limited to the safety related* valves.

program and should include.. as' a minimum, those i following systems.

Valves in these systems which are used for operating convenience only --such as manual vent, drain, instrument and ' test valves, and valves-used for maintenance only should be excluded.

For PWR's:

High Pressure Injection System a.

't b.

Low Pressure Injection System Accumulator Systems c.

d.

Containment Spray System Primary and Secondary System Safety and Relief Valves e.

f.

Auxiliary Feedwater Systems

Safety related are those pumps and valves necessary to safely shut down the plant or mitigate the consequences of an accident

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Reactor Building Cooling System h.

Active Components in Service Water and Instrument Air Systems which are required.to-support safety system functions 1.

Containment Isolation Valves-that'are required to change position on a containment isolation signal i

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j. Chemical and Volume Control System k.

Other key valves in Auxiliary Systems which are required to operate to directly support plant shutdown or safety system function; such as, emergency diesel starting air valves, component cooling water supplies, etc.

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Residual Heat Removal System

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Reactor Coolant System For BWR's:

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High Pressure Coolant Injection System b.

Low Pressure Coolant Injection System c.

Residual Heat Removal System (Shutdown Cooling System) i d,

Emergency Condenser System (Isolation Condenser System) e.

Low Pressure Core Spray System f.

Containment Spray System g.

Safety, Relief, and Safety / Relief Valves h.

RCIC (Reactor Core Isciation Cooling) Systen

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Standby liquid control system (Boron System) 1.

Automatic Depressurization System (any pilot or control I

valves, associated hydraulic or pneumatic systems, etc.)

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Control Rod Drive Hydraulic System (" Scram" function) n.

Other key valves in Auxiliary Systems which are required to operate to directly support plant shutdown or safety system function; such as, emergency diesel starting air valves, component cooling water supplies, etc.

o.

Reactor Coolant System B.

The following information should be provided for NRC staff review of the Pump and Valve Testing Programs:

1.

Three sets of P&ID's, that are large and clear enough to be read easily, and which include all of the systems listed above, with the ASME code class and system boundaries clearly marked. The drawings should include all of the components present at the time of submittal and a legend of the P&ID symbols.

2.

Identification of the applicable ASME Code Section XI Edition and Addenda.

3.

The period for which the program is applicable.

4.

Identification of the component ASME Section III Code Class.

5.

For Pump testing, identification of:

a.

Each pump required to be tested (name and number) b.

The test parameters to be measured c.

The test frequency

6.

For valve testing, identification of:

E a.

Each valve in ASME Section XI Categories A and B that will be exercised every three months during normal plant operation (indicate whether partial or full stroke exercise, and for-power operated valves list the limiting value for stroke time).

b.

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

c.

Each valve in ASME Section XI Categories C and D that will be tested, the type of test and the test frequency.

For check valves, identify those that will be exercised every 3 months and those that will only be exercised during cold shutdown or refueling outages.

d.

Each valve in ASME Section XI Category E that will be operationally checked.

e.

The following additional information, if practical:

i.

The valve location coordinates or other appropriate location information which will expedite locating the valves on the P& ids.

ii.

Identification of all valves that are provided with an interlock to other components and a t

brief description of that function.

II.

Requests for Relief from Certain Pump or Valve Testing Requirements It has been the staff's experience that many requests for relief from testing requirements, submitted by licensees, have not been supported by adequate descriptive and detailed technical information.

This detailed information is necessary to document why the burden I

imposed on the licensee in complying with the code requirements is not justified by the increased level of safet.y obtained from the testing.

e Relief requests which are submitted with a just fication such'as

" impractical", " inaccessible", or any othe, categorica! basis, require additional information to allow the staff to make an evaluation of inat relief request. The intention of the guidance t

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set forth below is'.to' illustrate the extent of the'information

- that is required by the NRC staff to make a proper evaluation and to. adequately document-the basis for granting the relief in the

- safety evaluation report The NRC. staff believes that if this.

information is provided in the licensee's submittal, subsequent i

requests for additional information and~ delays in completing the' review, and granting the relief, can be ' considerably reduced.

A.

Specific. information required for NRC review of' requests for a

relief from testing requirements':

f 1.

Identification of the component for which relief is requested:'

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a.

Name'and number as given in FSAR

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b.

Function c.

ASME Section III Code Class d.

For valve testing, also specify the ASME Section XI valve category as defined in IWV-2000 2.

Specific identification of the ASME Code requirement that has been determined to be impractical for each component..

3.

Information to support the determination that.the requirement in (2) is impractical; i.e., state and explain the basis i

for requesting relief.

4.

Specification' of the inservice testing that will be performed in lieu of the ASME Code Section XI requirements, if any.

5.

The schedule for implementation of the procedure (s) in (4).

B.

Examples to illustrate several possible areas where relief may be granted and the type and extent of information necessary to support the granting of relief:

i 1.

" Accessibility":

The regulation allows relief to be granted from code requirements because of insufficient access provisions.

1 However, a detailed discussion of actual physital arrange-ment of the component in question to illustrate the insufficiency of space for conducting the required test is necessary.

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i k 1 In addition, discussion of-the alternative surveillance techniques that have been considered should be provided.

If these alternative techniques have been determined to be impractical, the basis for this determination should be provided.

2.

" Environmental Conditions Prohibitive" (e.g., high radiation level,hightemperature,highhumidity,etc.):

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

be granted solely on the basis of high radiation levels.

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

Therefore, detailed information regarding the radiation levels at the required test location, along with estimated yearly man-rem exposures associated with the testing,'should i

be provided. Alternative testing techniques that have been considered should be discussed.

If these alternative techniques have been determined to be impractical, the basis for this' determination should be provided.

i 3.

" Instrumentation Not Originally Provided":

Information to justify that installation of the needed instrumentation to comply with the code requirementt would

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result in undue burden or hardships without a compensating increase in the level of plant safety should be provided.

Alternative testing techniques that have been considered should be discussed.

If these alternative techniques have been determined to be impractical, the basis for this determination should be provided.

4.

" Valve Cycling During Plant Operation Could Put the Plant t

in an Unsafe Condition":

i A detailed explanation as to why exercising tests diring plant operation could jeopardize the plant safety.

Examples of the type of valve that the staff considers to be in this category are: valves whose failure in a non-conservative position during the cycling test would cause a loss nf total system function; valves whose failure to close during the f

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

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pressures in excess of their design pressures. A plant specific explanation must be provided, r

5.

" Valve Testing at Cold Shutdown or Refueling Intervals in lieu of the 3 Month Required Interval":

The licensee should explain in detail why each valve cannot be exercised during normal operation. Also, for the valves where a refueling interval is indicated, the licensee should explain in detail why each valve cannot i

be exercised during each cold shutdown.

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C.

The following acceptance criteria for granting relief are utilized by the staff:

The licensee must successfully demonstrate with documented information that:

1.

Compliance with the code-requirements would result in hardships or unusual difficulties without a compensating increase in the level of safety, and noncompliance will provide an acceptable level of quality and safety, or 2.

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

III. Standard Format for Valve Testing Submittals A recommended standard format, for the valve portion of the pump and valve testing program and relief requests, is included as an attachment to this Guidance. The NRC staff believes that the use of this standard format would reduce the time spent by both the staff in its review, and by the licensee in their preparation, of the pump and valve testing program submittals. The standard format includes examples of relief requests which are intended to illustrate the application of the standard format only and

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are not necessarily applicable to any specific plant.

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4 RECOMMENDED STANDARD FORMAT FOR VALVE INSERVICE TESTING PROGRAM SUBMITTALS y

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5 SYSTEM NAE AUXILIARY COOLANT SYSTEM COMPONENT COOLING P&ID NO.

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