ML20127G765
| ML20127G765 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 01/16/1978 |
| From: | Desiree Davis Office of Nuclear Reactor Regulation |
| To: | Mayer L NORTHERN STATES POWER CO. |
| References | |
| NUDOCS 9211170423 | |
| Download: ML20127G765 (15) | |
Text
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Docket flos. L -?C JAtt 101979 50-r oe' and 50-306
/b Northern States Power Campany
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ATTN
'Mr. L. 6. Meyeri Manager Huclear Support Services 4.
414 Nicollet Mall - 8th Floor s
Minneapolgs Minnesota 56401 g ys; ryg,.c,
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4 Gentlemen:
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P.E: liotiTICELLO litJCLEAR GCNERAT!M PLANT PRAIRIC ISLA@ Nt! CLEAR COCRATIl!G PLAliT WII 1205.1 AG 2 Dy letter dated Hoveaber 24,1Ht, we sent you a document entitled "MC Staff Guidance for complying with Certain Provisions of 10 CTR 50.55a(g), Inservice Inspection Requirements".
In addition to clarifying p
the proper methods for complying with the regulation, this guidance provided a general outline of the type of infortsation that the @C staff would need to review inservice inspection and testing prograc:s, and to evaluate requests for relief from ASMC Code reouireecnts that are deterained to be impractical for a facility.
Af ter reviewing a nucher of sutetttals relating to 550.5Sa(c) requirements from various licensees, we have concluded t.hst additional guidance would be useful to all licensees to aid in the preparation of these submittals, and to expedite the !JRC staff review and approval of the proposed prograns and any reauests for relief from certain ASPE Codo renuircrents. The need for this guidance is particularly evident for thc pucp and valve testing requirenents.
Enclosea for your use is the "et Stef f Guidance for Preparino Puup and Valve Testing Progran Descriptions and Associated Relief Recuests Pursuant to 10 CFR 50.55a(91". This enclosure defines the reouf red-scope of a pump and valve testing progran, itenires the specific inforpation needed for staff review, and provides guidelines for subeitting information to support requests for relief fros; 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 intendec to complettent and expand on the guidance we provided to 9211170423 780116-
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NRC FORAf SIS (9 76) NRCM 0240 W u, s. oovs==uswv PasattNo omcas tote - ess.eas
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JAN 161978 liorthern States Power Compe.ny you in our previous letter. Although the enclosure specifically addresses pump and valve testing requirements on y, the some level l
of detailed infomation identified in this guidance should~also be
- provided in inservice inspection program. submittals.,,,,q;..,,;.g y g g, wu g.
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We request t. hat you follow the enclosed guidance to the greatest,
extent possible when submitting proposed inservice insp and when responding to additional information requests from thetsteff.
I Your adherence to this evidence will minimize the NRC staff review. _.
tive needed to approve your proposed programs and associated relfet :'
reove sts.
If you hava any cuestions recarding implenentation af 10 CFR 50.55a(g) at your facility, please contect us.
Sincerely, o
Don K. Davis, Acting Chief Operating Reactors trench #2 Division of Operating Peactors DIS B
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NRC STAFF GUIDANCE FOR PREPARING PUMP AND VALVE TESTING PROGRAM DESCRIPTIONS AND ASSOCIATED RELIEF REQUESTS PURSUANT T0 10 CFR 50.55a(9)
The guidance provided in this enclosure is intended to illustrate the type and extent of information that should be provided in proposed pump and valve testing program descriptions and to support associated requests for relief from ASME Code requirements.
By utilizing these guidelines, licensees can significantly reduce the need for having to respond to additional information requests from the NRC staff.
1.
Pump and Valve Testino Program Description 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 emergency power source.
2.
The valve testing program should be limited to the safety related* valves. All such valves must be addressed in the program and should include, as a minimum, those in the 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:
f a.
High Pressure injection System b.
Low Pressure Injection System c.
Accumulator Systems d.
Containment Spray System e.
Primary and Secondary System Safety and Relief Valves f.
Auxiliary feedwater Systems
- Safety related are those ;mmps and valves necessary to safely shut down the plant or mitigate the consequences of an accident.
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i 2-g.
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 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.
1.
Residual Heat Removal System m.
Reactor Coolant System For BWR's:
a.
High Pressure Coolant Injection System b.
Low Pressure Coolant Injection Systs c.
Residual Heat Removal Sys+.em (Shutdown Cooling System) d.
Emergency Condenser System (Isolation Condenser System) e.
Low Pressure Core Sprey System f.
Containment Spray System g.
Safety, Relief, and Safety / Relief Valves h.
RCIC (Rea,:tn sr Isclation Cooling) Syster 1.
Containment Cooling S; stem
'j. Containment isolation valves that aro required to chanqe position on a containment isolation <.ignal 1.
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i 3-k.
Standby liquid control system (Boron System) 1.
Automatic Depressurization System (any pilot or control valves, associated hydraulic or pneumatic systems, etc.)
Control Rod Drive Hydraulic System (" Scram" function) m.
4 Other key valves in Auxiliary Systems which are n.
required to operate to directly support plant shutdown or safety system function; such as, emergency diesel j
starting air valves, component cooling water supplies, 1
etc.
o.
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 casily, 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.
?.
Identification of the applicable ASME Code Section XI Edition and Addenda.
l The eeriod for which the program is applicable.
Identification of the component ASME Section III Code Class.
5.
For Pump testing, identification of:
Each pump required to be tested (name and number) 4 a.
b.
The test parameters to be measured c.
The test frequency l
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6.
For valve testing, identification of:
Each valve in ASME Section XI Categories A and 0 that a.
will be exercised every three months during normal
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plant operation (indicate whether partial or full stroke exercise, and for power operated valves list the limiting value for stroke time),
4 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).
Each valve in ASME Section XI Categories C and D
- c. -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.
1 e.
The following additional information, if practical:
4 1.
The valve location coordinates or other 1
appropriate location information which will expedite locating the v61ves on the P& ids.
l ii.
Identification of all valves-that are provided I
with an interlock ~ to other con'ponents and a 4
brief description of that function.
4 II.
Requests for Relief from Certain Pump or Valve Testing Requirements q
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 imposed on the licensee in complying with the code requirements is not justified by the increased level of safety obtained from l
the testing.
1 Relief requests which arc submittee with a just. fica; ion sucn as
" impractical", " inaccessible", or ar.y othe, categorica! Dasis, require additional information to allow the staff to make an evaluation of that relief request. The intention of the guidance
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set forth below is to illustrate the extent of the information e
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 l
information is provided in the licensee's submittal, subsequent requests for additional information-and delays in completing the review, and granting the relief, can be considerably reduced.
A.
Specific information required fo,r NRC review of requests for relief from testing requirements:
1.
Identification of the component for which relief is requested:
a.
Name and number as given in FSAR i
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.
i 3.
Information to support the determination that the requirement in (2) is impractical; i.e., state and explain the basis 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:
1.
" Accessibility":
The regulation allows relief to be granted fror code requirements because of insufficient access prnvision..
However, a detailed discussion of actual physi < al arrange-ment of the cnmponent in question to illustratt the insufficiency of space for conducting the requ" red test is necessary.
f-
l In addition, discussion of the alternative surveillance techniques that have been considered should'be provided.
If these alternative techniques have been detemined to i
be impractical, the basis for this determination should be provided.
I 2.
" Environmental Conditions Prohibitive" (e.g., high radiation i
level, high temperature, high humidity, etc.):
Although it is prudent to maintain occupation radiation 4
exposure for inspection personnel as low as practicable, the request for relief from code requirements cannot 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 be provided. Alternative testing techniques that have been considered shoul'd be discussed.
If these alternative techniques have been determined to be impractical, the basis for this detemination should be protided.
3.
" Instrumentation Not Originally Provided":
Information to justify that installation of the needed instrumentation to comply with the code requirement: would result in undue burden or hardships without a compensating increase in the level of plant safety should be provided.
Alternative testing techniques that have been considered should be discussed.
If these alternative techniques have been detemined to be impractical, the basis for this detemination should be provided.
4
" Valve Cycling During Plant Operation Could Put the Plant in an Unsafe Condition":
A detailed explanation as to why exercising tests d iring plant operation could jeopardize the plant safety.
Examples of the type of valve that the staff considers to be in this category are: va.ves whose failure in a non-conservative position during the cycling tent would tause a loss of total system function; valves whose failure to close during the i
1
7-cycling test would cause a loss of containment integrity; and valves, which when cycled, could subject-a system to pressures in excess of their design pressures. A plant specific explanation must be provided.
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,iuring normal operation. Also, for the valves where a refueling interval is indicated, the licensee should explain in detail why each valve cannot be exercised during each cold shutdown.
C.
The following acceptance criteria for granting relief are utilized by the staff:
The licensee must successfully demonstrate with documented 4
information that:
1 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 fomat, 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 4
of this standard format would reduce the time spent by both the staff in its review, and by the licensee in their preparation, of l
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 fomat only and are not necessarily applicable to any _ specific plant.
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ATTACitMENT RECOMMENDED STANDARD FORMAT FOR VALVE INSERVICE TESTING PROGRAM SUBMITTALS t
9 9
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SYSTEM NAE AUXILIARY COOLANT SYSTEM COMPONENT COOLING P&ID NO.
1045-E-2A PAGE B
To e
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REMARKS g
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(Not to be used for relief basis) i E
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R e
a e F u
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E'
- 5 Valve C
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3 31
,4 v Valve.
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Category j
Number 3-8 A
B 0.
D L g g
y e
yt g y
710 3
D-14 X
4 GA M
D-15 X
6 DE NA C
DT CV X
CS 717 3
C-15 X
16 CK SA 702C 3
C-15 X
16 CK-SA CV 707
. 3-E-14 X
3 REL SA CV 834 3
D-11 X
X 4
GL M
C Q
X ET s
MT 60 sec. stroke time 7228 3
B-11 X
B-11 X
A-10 X
B-10 X
3 REL SA SRV 744B 2-D-14 X 10 GA M0 C.
Q t
LT X
~
MT 30 sec. stroke time a-r i
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(s LEGEND FOR VALVE TESTING EXAMPLE FORMAT
- Exercise valve (full stroke) for operability every (3) months Q
- Valves are leak tested per Section XI Article IWV-3420 LT
- Stroke time measurements are taken and compared to the stroke MT time limiting value per Section XI Article IWV 3410
- Exercise check valves to the position required to fulfill their CV function every (3) months a
SRV - Safety and relief valves are tested per Section XI Article r
IRV-3510
- Test category D valves per Section XI Article.IWV-3600 Y
DT
- Verify and record valve position before operations are performed 1
ET and after operations are completed, and verify that valve is 4
locked or sealed.
CS - Exercise valve for operability every cold shutdown j
- Exercise valve for operability every reactor refueling RR 4
j 4
' ' ~ ~ ~ ' ' ~
RELIEF REQUEST BASIS Auxiliary Coolant System, Component Cooling System:
1.
Valve:
717 C
Category:
Class:
3 Prevent backflow from the reactor coolant Function:
pump cooling coils Exercise valve for operability every three Test Requirement:
months To test this valve would require interruption Basis for relief:
of cooling water to the reactor c'oolant pumps motor cooling coils. This action could result in damage to the reactor coolant pumps and thus place the plant in an unsafe mode of operation.
This valve will be exercised for operability Alternate Testing:
during cold shutdowns 2.
Valve:
834 Category:
B-E Class:
3-Isolate the primary water from the component Function:
cooling surge tank during plant operation.
It is normally in the closed position, but routine operation of this valve will occur during refueling and cold shutdowns.
Exercise valve (full stroke) for operability Test Requirement:
every three (3) months.
Basis for Relief:
This valve is not required to change position during plant operation to accomplish its safety function.
Exercising this valve will increase the possibility of surge tank line contamination.
Alternate Testing:
Verify and record valve position before anJ after each valve operation, 1
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. 3.
Valve:
- 7448 J
A Category:
Class:
2 Isolate the residual heat exchangers f rom Function:
the cold leg R.C.S. backflow and accumulator 4
backflow.
Test Requirements: Seat leakage test This valve is located in a high riidiation Bases for relief:
field of mr/hr which would make the required seat leakage test hazardous to test personnel. The estimated yearly man-rem exposure associated with performing the required seat leakage test is We intend to seat leak test two other valves (875B and 8668) which are in series with this valve and which also prevent We feel that by complying backflow.
the seat leakage requirements for 744B we will not achieve a compensatory increase in the level of safety.
No alternative seat leak testing is Alternate Testing,.
proposed for 744B.
4
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