ML20248D549
| ML20248D549 | |
| Person / Time | |
|---|---|
| Issue date: | 03/30/1989 |
| From: | Jordan E Committee To Review Generic Requirements |
| To: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20245C946 | List: |
| References | |
| NUDOCS 8904110506 | |
| Download: ML20248D549 (33) | |
Text
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March 30, 1989 MEMORANDUM FOR:
Victor Stello, Jr.
IU Ufr p g Executive Director for Operations FROM:
Edward L. Jordan, Chairman Committee to Review Generic Requirements
SUBJECT:
MINUTES OF CRGR MEETING NUMBER 157 The Committee to Review Generic Requirements (CRGR) met on Wednesday, February 8,1989 from 1:00 p.m. - 6:00 p.m.
A list of attendees for this I
meeting is attached (Enclosure 1).
The following items were addressed at the meeting:
1.
B. Grimes (NRR) and W. Brach (NRR) presented for CRGR review a proposed generic letter requesting licensees to develop and implement programs to preclude introduction of nonconforming (including fraudulent) products into their plants and to implement dedication orograms for commerical grade items.
The Committee recommended in favor of issu Ng the proposed generic letter, subject to redirecting the focus of the letter only to fraudulent materials.
These changes are to be coordinated with the CRGR staff.
2.
F. Miraglia (NRR) and L. B. Marsh (NRR) presented for CRGR review a proposed generic letter providing guidance to licensees regarding NRC requirements for in-service testing programs.
The Committee recommended against issuance of the generic letter without revising it to reflect related guidance being generated through EPRI, INP0 and other industry groups.
These changes are to be coordinated with the CRGR staff.
In accordance with the ED0's July 18, 1983 directive concerning " Feedback and Closure to CRGR reviews," a written response is required from the cognizant office to report agreement or disagreement with the CRGR recommendations in these minutes.
The response, which is required within five working days after receipt of these minutes, is to be forwarded to the CRGR Chairman and if there is disagreement with CRGR recommendations, to the EDO for decisionmaking.
Questions concerning these meeting minutes should be referred to Jim Conran (492-9855).
Original Sica '
4 E. L jorden E(. ward _L. Jordan, Chairman Committee to Review Generic Requirements
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Enclosures:
As stated l
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OFFICIAL RECORD COPY
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Commission (5)
SECY Office Directors Regional Administrators CRGR Members Distribution: w/o enclosures Contral File POR (NRC/CRGR)
S. Treby W. Little M. Lesar B. Grimes F. Miraglia P. Kadambi (w/ enc.)
CRGR SF (w/ enc.)
M. Taylor (w/ene.)
E. Jordan (w/ enc.)
J. Heltemes (w/ enc.)
J. Conran (w/ enc.)
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Attendance List - CRGR Meeting No. 157 February 8, 1989 CRGR Members E. Jordan J. Sniezek J. Goldberg Z. Rosztoczy (for D. Ross)
R. Cunningham (for R.' Bernero)
C. Paperiello NRC Staff J. Conran C. Sakenas D. Brinkman J. Hayes P. Hopkins L. Wharton J. Lieberman-W. Troskoski B. Brach B. Grimes E. Baker J. Huang E. Suliivan L. Marsh J. Richardson P. Kadambi F. Miraglia
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. to the Minutes of CRGR Meeting No. 157 Draf t Generic Letter, " Nonconforming (Including Fraudulent)
Products and Dedication of Commercial-Grade Products" l
TOPIC B. Grimes (NRR) and W. Brach (NRR) presented for CRGR review a proposed generic letter requesting licensees to develop and implement programs to preclude introduction of nonconforming (including fraudulent) products into their plants and to implement dedication programs for commercial grade items.
BACKGROUND The package submitted by the staff for CRGR review of this matter was transmit-ted by roemorandum dated January 23, 1989, J. H. Sniezek to E. L. Jordan and included the proposed generic letter and the information required by the CRGR Charter.
In addition, the members were provided with a copy of a letter from NUMARC to B. Grimes dated January 19, 1989 regarding this issue.
CONCLUSIONS / RECOMMENDATIONS The Committee expressed concern that issuance of this generic letter could stifle industry initiatives which are ongoing in this aree and recommended that the letter be revised to address only the agency's concern with the use of fraudulent material.
The members stated that since there is an advance notice c, proposed rulemaking presently under review by the Commission, action by the ;taff now on issues which will be addressed by the rulemaking is unwarranted and may produce negative results should staff positions change, based on the answers to questions raised in the ANPR, and any subsequent rulemaking.
In addition, several specific comments were provided and are as follows:
1.
In the first sentence of the generic letter, the phrase, "...take immediate action... " should be revised to read "... take prompt action...."
2.
Delete the second paragraph under the section Actions Requested, since the first paragraph is sufficient to -describe the basis for the requested actions.
3.
Also in the section Actions Requested, item B, the first sentence states that acceptance programs should be implemented so there is a good probability of identifying fraudulent materials.
This should be changed to something more appropriate (i.e., likelihood).
The Committee recommended in favor of issuing the proposed generic letter, subject to incorporation of the preceding comments which are to be coordinated with the CRGR staff.
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. to the Minutes of CRGR Meeting No. 157 Proposed Generic Letter on In-Service Testing February 8,1989 TOPIC F. Miraglia (NRR) and L. B. Marsh (NRR) presented for CRGR review a proposed generic letter providing guidance to licensees and permitees regarding NRC I
regulatory requirements for in service testing (IST) programs in areas where programmatic weaknesses i, ave been identified by IST program reviews or NRC inspections.
A collateral purpose of the proposed letter is to clarify the status of a large number of unreviewed IST programs with respect to Technical Specification requirements.
Copies of briefing slides used by the staff to guide their presentation and the discussions with CRGR at this meeting are attached (Attachment 1).
BACKGROUND 1.
The package submitted initially by the staff for CRGR review was transmitted by memorandum dated January 23, 1989, J. H. Sniezek to E. L.
Jordan; that package included the following documents: - Oraft Generic Letter (undated), " Guidance on Develop-a.
ing Acceptable In-Service Testing Programs"; and, " Potential Generic Deficiencies Related to IST Programs and Procedures."
- b.
" Contents of Package Submitted to CRGR" (in accordance with CRGR Charter Item IV.B.).
- c. - Memorandum dated December 12, 1988, L. Shao to F. Miraglia, " Planned Actions on In-Service Testing Programs in Operating Plants - Revision to Original November 29, 1988 Memorandum; and Enclosure 1,
" Mechanical Engineering Branch Planned Actions on In-Service Testing Program for Operating Plants."
2.
The Nuclear Utility Backfitting and Reform Group (NUBARG) submitted comments on an earlier (December 1988) draft of the proposed generic letter for consideration by CRGR in their review of this matter.
The comments were transmitted by letter dated February 7,1989, N. S. Reynolds to E. L. Jordan.
Copies of those documents are attached to these minutes (Attachment 2).
3.
The staff provided directly to CRGR members revised versions of Items 1.a.
and 1.b. above at Meeting No. 157.
Copies of those revised documents are attached to these minutes (Attachment 3).
CONCLUSIONS / RECOMMENDATIONS After much discussion of the proposed package at this meeting, the Committee recommended against issuance of the proposed generic letter in its current form.
The Committee recognized the need to provide guidance to licensees on
the narrow IST compliance issues addressed in the proposed letter; but they felt strongly that the letter should also-include greater recognition of, and reference to, (a) other related current activities within NRC (e.g., develop-ment of a comprehensive maintenance rule and another proposed generic letter providing additional detailed guidance on M0V testing), and (b) important related current industry initiatives (i.e., by NUMARC,- INP0,, EPRI, and NMAC),
which bear on the same underlying component reliability / operability concern but
-treat the fundamental issues involved much more broadly and comprehensively than the proposed letter.
The Committee considered it important to encourage licensees, even while they are addressing the narrower ASME Section XI compli-ance concerns in accordance with the guidance provided in this proposed generic letter, to begin to think more broadly about the improved programs that will be needed for better assuring component operability / reliability in the future, and to consider information on improved valve testing methods / techniques avail-able now from recent and ongoing industry programs and regulatory activities that address these problem areas.
The staff agreed that the proposed letter and attachment could be modified to address this Committee recommendation; and the AE00 staff will work closely with NRR in drafting the intended changes.
The staff agreed to circulate a revised version of the proposed generic letter and attachment to CRGR members to achieve endorsement by the Committee on a negative consent basis, if possible, prior to final issuance.
In addition to the general recommendation above for revising the content of the proposed generic letter, the Committee also recommended the following specific changes:
A section should be added to the generic letter containing a generic a.
safety evaluation conclusion corresponding to the relief guidance provided in Attachment 1 to the letter.
b.
A listing of those licensees for which the staff has completed the IST program reviews and issued SERs should be added to the generic letter.
c.
The statement of intended scope of this proposed generic letter should be reviewed by the staff and revised as appropriate, in accordance with the discussions at this meeting.
Specifically, the statement of scope should reflect properly all generic correspondence / guidance regarding pump and valve operability testing previously provided to licensees.
The staff also agreed to these recommended changes; and all the above changes to the proposed letter and attachment will be coordinated with the CRGR staff.
Finally, as a collateral recommendation in this matter that is not intended to affect in any way issuance of the proposed generic letter, the Committee recommended that the staff implement expeditiously the planned follow-on actions outlined in the presentation to the Committee at this meeting (see
, to this Enclosure), including a possible second generic letter to provide improved in-service testing of all safety-related pumps and valves, and a rulemaking to address more broadly and comprehensively in-service testing and assured component operability /reliabilty.
Specifically, in the context of the planned rulemaking, the Committee recommended that the staff reexamine critical-ly the role and adequacy of Section XI in meeting regulatory objectives in the IST area.
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IST PROBLEM AREAS TECHNICAL-INADEQUATE / DEFICIENT. TESTING. REQUIREMENTS IN ASME CODE N0 STAFF OR ASME GUIDANCE EXISTS ON CODE IMPLEMENTATION NO CERTIFIED INSPECTORS LEGAL 10 CFR 50.55A INCONSISTENT WITH TECH SPECS P0ORLY. WORDED.10.CFR 50.55A (SELF-CONTRADICTORY)
TS.4.0.5 REGUIRES STAFF APPROVAL PRIOR TO IMPLEMENTING-RELIEF REQUESTS
-1 ADhlNISTRATIVE INTERIM RELIEF EXPIRED OR NONEXISTENT
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LARGE VOLUME OF PROGRAMS / REVISIONS / RELIEF RECUESTS LICENSEES IMPLEMENT NEW PROGRAM REVISIONS WITHOUT
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NRC APPROVAL OR PRIOR NOTIFICATION
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COMPLEX PROBLEMS / RESOURCE INTENSIVE-l LARGE CONTRACT - EG8G, 4 PEOPLE, $550K ENFORCEMENT TECHNICAL SPECIFICATION PROBLEM LACK OF SERs HAMPERS INSPECTION EFFECTIVENESS REGIONAL VARIATIONS IN INTERPRETATIONS Attachment I to Enclosure 3 n
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PLAN FOR RESOLVING IST ISSUES-
IMPROVEMENTS IN CURRENT PROCESS 1987/1988
- ALL REVIEW MEETINGS AT SITES l
- IMPROVED C00RDINAT10fLWITH PMs AND CONTRACTORS
- GENERAL OGC COMMENTS RESOLVED NRR REPRESENTATION ON ASME CODE 1987-PRESENT BETTER NRR COORDINATION WITH RES 1987-PRESENT
. REQUEST FOR RULEMAKING 5/88 REQUEST TO ASME FOR JOINT ASME/NRC 5/88 SYMPOSIUM l
l ISSUE FIRST GENERIC LETTER 2/89 CONDUCTING REGIONAL COUNTERPARTS -
3/89 MEETING CONDUCT ROAD SHOWS TO DISCUSS FIRST GL 4/89
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_3-H0LE NRC/ASME IST SYMPOSIUM 8/89 ISSUE SECOND GL 9/89 CONDUCT ROAD SHOWS TO DISCUSS SECOND GL 11/89 ISSUE RULEMAKING CHANGES / PROPOSED 12/90 REGULATORY GUIDE CONDUCT IST INSPECTIONS / AUDITS, START 9/89, COMPLETE ALL PLANTS 12/94 REVIEW AS NECESSARY THOSE RELIEF REQUESTS NO APPLICABLE INVOLVING A SIGNIFICANT SAFETY CONCERN SCHEDULE OR AN EXIGENCY SITUATION v
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CURRENT ~1ST REVIEW PROCESS MILESTONE CUMULATIVE TIME (MONTH)
REVIEW /RAI 1
WORKING MEETING WITH LICENSEE 3
UTILITY SUBMIT MODIFIED PROGRAM 7
DRAFT TER 9
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MAJOR OBJECTIVES OF-10 CFR 50.55.A RULEMAKING ELIMINATE DETAILED REVIEWS OF IST PROGRAMS AND RELIEF REQUESTS THROUGH SELF IMPLEMENTATION OF DETAILED TECHNICAL AND PROGRAM GUIDANCE IMPLEMENT FOUR TIERED SYSTEM
-(1) ASME CODE + RULE REQUIREMENTS (2) APPROVED ALTERNATIVES (3) SELF EVALUATION (4) NRC REVIEW INCORPORATE BY REFERENCE NEW ASME IST STANDARDS REQUIRE UNIFORM ONE TIME UPDATE RULE REQUIREMENTS TWO YEARS AFTER FINAL RULE
- - SEEK PUBLIC COMMENT ON MANDATORY UPDATING PROVISION ISSUE ACCOMPANYING REG GUIDE ON CODE IMPLEMENTATION EXTEND OM 6 & 10 REQUIREMENTS.
1.E., MOVs, PIVs, CHECK VALVES, PUMPS, AS NECESSARY CLARIFY CONFUSING AND CONTRADICTORY RULE LANGUAGE CONDUCT REGION BASED WORKSHOPS
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CONDUCT IST INSPECTIONS AS A MAJOR CHECK ON ENSURING ADEQUATE IST PROGRAMS AND IMPLEMENTATION
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l PLANTS WITH SIGNIFICANT REVIEW COMPLETED 1
l D.C. COOK 182 ZION 182 FORT CALHOUN ROBINSON 2 RANCHO SECO RIVER BEND CLINTON NCGUIRE 182 KEWAUNEE CALVERT CLIFFS 182 WOLF CREEK PEACH BOTTOM 283 BRUNSWICK SONGS 233 HATCH 182 MILLSTONE 2 BEAVER VALLEY I SURRY 182 FARLEY 182 LIMERICK 182 V.C. SUMMER GINNA HOPE CREEK NINE MILE POINT 1
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SUMMARY
OF SIGNIFICANT COMMENTS COMMENT #1 - SCOPE OF IST PROGRAMS (NUBARG/0M)
PROPOSED GENERIC LETTER (GL) REQUIRES MORE COMPONENTS TO BE IN THE IST PROGRAMS THAN 10 CFR 30.55A(G) AND ASME CODE SECTION XI.
STAFF SHOULD RECONSIDER POSITION IN PROPOSED GL ON THE SCOPE OF IST PROGRAMS.
TO THE EXTENT THE STAFF FEELS JUSTIFIED IN MAINTAINING ITS POSITION, IT SHOULD CONSIDER IMPLEMENTING THIS NEW POSITION THROUGH APPROPRIATE RULEMAKING PROCEDURES.
COMMENT #2 - RELIEF REQUESTS (NUBARG)
THE PROPOSED GL APPEARS TO MAKE IT MORE DIFFICULT TO OBTAIN RELIEF FROM SECTION XI REQUIREMENTS (THAT liAVE BEEN ASSOCIATED WITH ThE STAFF POSITIONS CONTAINED IN THE PROPOSED GL).
COMMENT #3 - OTHER NEW STAFF POSITIONS (NUBARG/0M)
IN ADDITION TO COMMENT #1, IT APPEARS THAT SEVERAL ADDITIONAL STAFF POSITIONS HAVE NOT PREVIOUSLY BEEN IMPOSED ON A GENERIC DASIS.
THE STAFF SHOULD CONSIDER WHETHER THESE REPRESENT NEW POSITIONS THAT SHOULD BE CONSIDERED IN ACCORDANCE WITH SECTION 50.109 OR THROUGli RULEMAKING.
ALSD, OM REQUESTS ADDITIONAL GUIDANCE THAT MAY BE NEEDED ON HOW T0 IMPLEMENT TilESE POSITIONS IF HARDWARE CliANGES ARE INVOLVED.
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SIGNIFICANT COMMENTS (CONT'D)
COMMENT #4 - SCHEDULE (NUEARG/0M)
TliE PROPOSED GL REGUESTS TilAT THE LICENSEE'S IST PROGRAMS BE CERTIFIED WITHIN SIX MONTHS AFTER THE PROPOSED GL IS ISSUED.
TliE SCHEDULE APPEARS TOO SHORT AND A MORE REALISTIC SCHEDULE SHOULD DE ADOPTED.
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IST PROGRM4 SCOPE 10 CFR 50.55a requires that inservice testing be performed on certain ASME Code Class 1, 2, and 3 pumps and valves.Section XI Subsections IWP-1100 and IWV-1100 defines the scope of pump and valves to be tested in terms of plant shutdowns and accident mitigation. The plant's FSAR (or equivalent) provides definitions of the necessary equipment to meet these functions. The staff has noted during past IST progran reviews and inspections that licensees do not always include the necessary equipment in their IST programs.
Licensees should review their IST programs to ensure adequate scope. Examples that are frequently erroneously omitted from IST programs are:
a.
control room chilled water system pumps and valves, c.
accumulator motor operated isolation valves, or accumulator vent valves, d.
auxiliary pressurizer spray system valves, e.
boric acid transfer pumps, f.
valves in emergency boration flow path, g.
control valves that have a required, and fail-safe position, h.
valves in mini-flow lines.
It should be recognized that the above examples of pumps and valves do not meet the IWP/and IWV scope statement requirements for all plants.
ATTACHMENT 1 TO GENERIC LETTER POSITION'1 FULL FLOW TESTI'G 0F CllECK VALVES
-A CHECK VALVE'S FULL-STR0KE TO THE OPEN POSITION MAY BE VERIFIED BY' PASSING THE REQUIRED ACCIDENT FLOW THROUGH THE VALVE ANY FLOW LESS THAN THIS IS CONSIDERED A PARTIAL STROKE EXERCISE
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POSITION 2 ALTERNATIVE TO FULL FLOW TESTING OF CHECK VALVES FOR SOME CHECK VALVES, FULL FLOW TO EXERCISE CHECK VALVE CANNOT BE ESTABLISHED OR VERIFIED FOR THESE VALVES CONDUCT A DISASSEMBLY AND INSPECTION
~~ PROGRAM
- GROUP SIMILAR VALVES
- TESTING ONE VALVE IN EACH GROUP DURING EACH REFUELING OUTAGE SAMPLING TECHNIQUE REQUIRES THAT EACH VALVE IN THE GROUP BE THE SAME DESIGN AND HAVE THE SAME SERVICE CONDITIONS AT EACH DISASSEMBLY THE LICENSEE MUST VERIFY THAT THE DISASSEMBLED VALVE IS CAPABLE OF FULL-STROKING AND THAT THE INTERNALS OF THE VALVE ARE STRUCTURALLY SOUND (N0 LOOSE OR CORRODED PARTS)
IF POSSIBLE, PARTIAL VALVE STR0 KING SHALL BE PERFORMED QUARTERLY, DURING COLD SHUTDOWNS OR AFTER REASSEMBLY 1
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POSITION 3 EACKFLOW TESTING OF CHECK VALVES CATEGORY C CHECK VALVES:
VALVES THAT ARE SELF-ACTUATED IN RESPONSE TO A SYSTEM CHARACTERISTIC THOSE PERFORMING A SAFETY FUNCTION IN THE CLOSED POSITION
- EACKFLOW TESTING REQUIRED
- BACKFLOW TEST TO SHOW THAT DISK TRAVELS TO THE SEAT PROMPTLY ON CESSATION OF FLOW CATEGORY A/C CHECK VALVES:
VALVES THAT HAVE A SPECIFIED LEAK RATE LIMIT AND ARE SELF-ACTUATED IN RESPONSE TO A SYSTEM CHARACTERISTIC THOSE VALVES MUST BE LEAK TESTED TO SPECIFIC MAXIMUM AMOUNT l
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POSITION 4 PRESSURE ISOLATION VALVES (PIVs)
PIVs.ARE DEFINED AS TW0.NORMALLY CLOSED VALVES IN SERIES THAT ISOLATE THE REACTOR COOLANT SYSTEM FROM AN ATTACHED LOW. PRESSURE SYSTEM PIVs ARE LOCATED AT ALL RCS LOW PRESSURE SYSTEM INTERFACES PERIODIC TESTING 0F PIVs SHOULD BE SPECIFIED IN-PLANT TSs AND THE IST PROGRAM STAFF POSITIONS:
- LICENSEE SHOULD REVIEW THEIR TESTING PROCEDURES TO ENSURE THAT THE PIVs IN THE TECHNICAL SPECIFICATIONS.
ARE INDIVIDUALLY LEAK TESTED l
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POSITION-51 l
LIMITING VALUE OF FULL-STR0KE TIMES ASME CODE REQUIRES LICENSEE TO SPECIFY LIMITING VALVE OF FULL-STROKE TIME (LVFST)
LVFST OF CODE
- STROKE TIME LIMIT FOR TAKING CORRECTIVE ACTION
- POINT WHERE 0PERABILITY 0F VALVE, IF CALLED UPON, IF.0 QUESTIONABLE IF TECH SPEC STROKE TIME IS GREATER TilAN CODE LVFST
- CORRECTIVE ACTION TO BE TAKEN PER CODE IF TECH SPEC STR0KE TIME IS LESS TilAN CODE LVFST
- CORRECTIVE ACTION TO BE TAKEN PER TECH SPECS
- ~ _ _. _ _ _ _ _ _ _ - _. - - _ _ _. _ _ _
POSITION 6 STROKE TIME MEASUREMENT FOR RAPID-ACTIhG VALVES FOR POWER OPERATED VALVES WITH STROKE TIME OF 10 SECONDS OR LESS, THE CODE REQUIRES THAT:
(A)
IF THE STROKE TIME INCREASES BY 507. OR-MORE FROM
.THE PREVIOUS TEST, THEN-THE TEST FREQUENCY IS INCREASED UNTIL CORRECTIVE ACTION IS TAKEN (IWV-3417(A))
(B)
IF THE LIMITING VALUE OF FULL SlROKE TIME (LVFST)
IS EXCEEDED, VALVE DECLARED INOPERABLE MOST PLANTS HAVE MANY VALVES THAT STR0KE IN 2 SECONDS OR LESS - REFERRED TO AS RAPID-ACTING VALVES AB0VE CODE REQUIREMENTS MAY BE IMPRACTICAL FOR RAPID ACTING VALVES
. POSITION 6 (CONT'D)
STAFF ACCEPTS AS AN ALTERNATIVE:
- SPECIFYING A 2 SECOND LVFST
- ELIMINATE TREl4 DING REQUIREMENT OF (A) AB0VE
- DECLARE VALVE INOPERADIE IF STROKE TIME EXCEEDS 2 SECONDS 4
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1 POSITION 7 l
-TESTING OF INDIVIDUAL ROD SCRAM VALVES IN BWRs I
THE FOLLOWING SCRAM VALVES ARE TO BE INSERVICE TESTED:
SCRAM DISCHARGE VOLUME VENT AND DRAIN VALVES THE SCRAM INLET AND OUTLET VALVES
-THE SCRAM DISCHARGE HEADER CHECK VALVES THE CHARGING WATER HEADER CHECK VALVES THE COOLING WATER HEADER CHECK VALVES THE PLANT TS SURVEILLANCE OF SCRAM SYSTEM (1AY BE USED AS AN ALTERNATIVE TESTING FREQUENCY AND METHOD TO VERIFY THE FUNCTIONING 0F THE AB0VE SCRAM VALVES P
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- 18 POSITION 8 STARTING POINT-FOR TIME PERIOD IN TS ACTION STATEMENTS IWP-3220 REQUIRES TEST DATA TO BE ANALYZED WITHIN 96 HOURS OF TEST IWP-3100-2 REQUIRES PUMP DECLARED INOPERABLE IF DATA IS WITHIN REQUIRED ACTION RANGE SINCE REFERENCE VALUES, LIMITS, AND ACCEPTANCE CRITERIA ARE IN TEST PLANS, TIMELY DETERMINATION CAN BE MADE TilEREFORE, WHEN THE DATA IS DETERMINED TO BE WITHIN THE REQUIRED ACTION RANGE OF TABLE IWP-3100-2 THE PUMP IS i
INOPERABLE AND THE TECH SPEC ACTION STATEMENT TIME STARTS WHEN THE DATA EXCEEDS THE LIMITING VALUE OF FULL-STR0KE TIME FOR VALVES THE ASSOCI ATED VALVE IS INOPERABLE AND THE TECH SPEC ACTION TIME STARTS
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L POSITION 9 PUMP TESTING USING MINIMUM-FLOW'RETURNLINE j
WITH OR WITHOUT FLOW MEASURING DEVICES
.CERTAIN SAFETY-RELATED SYSTEMS ARE DESIGNED SUCH THAT THE MINIMUM-FLOW RETURN LINES ARE THE ONLY FLOW PATHS THAT CAN BE UTILIZED FOR QUARTERLY PUMP TESTING MINIMUM-FLOW LINES ARE NOT DESIGNED FOR PUMP TESTING-PURPOSES AND FEW HAVE INSTALLED FLOW MEASURING-DEVICES STAFF ACCEPTS AS AN ALTERNATIVE:
- QUARTERLY PUMP TESTING THROUGH A NON-INSTRUMENTED MINIMUM-FLOW LINE
- FULL OR SUBSTANTIAL FLOW TESTING DURING COLD SHUTDOWNS OR REFUELING OUTAGES MEASURING PUMP DIFFERENTIAL PRESSURE, FLOW RATE, AND BEARING VIBRATION,
- QUARTERLY TESTING MEASURING AT LEAST PUMP DIFFERENTIAL PRESSURE AND VIBRATION, AND
- DATA FROM BOTH TESTING FREQUENCIES SHOULD BE TRENDED AS REGUIRED BY IWP-6000
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POSITION 9 (CONT'D) l IN CASES WHERE ONLY THE MINIMUM-FLOW RETURN LINE IS AVAILABLE FOR PUMP. TESTING, RE6ARDLESS OF THE TEST INTERVAL, FLOW INSTRUMENTATION WHICH MEETS THE REQUIREMENTS OF IWP-4110 AND 4120 MUST BE INSTALLED IN THE MINI-FLOW RETURN LINE S
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- POSITION-10 L
CONTAINMENT ISOLATION VALVE TESTING L
- ' ALL CONTAINMENT ISOLATION VALVES (CIVs) INCLUDED IN L
THE APPENDIX J PROGRAM SHOULD BE INCLUDED IN THE IST PROGRAM AS CATEGORY A OR A/C VALVES i
LEAK TEST PROCEDURES AND REQUIREMENTS'FOR CONTAINMENT ISOLAT,10N VALVES SPECIFIED IN 10 CFR 50,: APPENDIX J, ARE EQUIVALENT TO THE REQUIREMENTS OF IWV-3421 THROUGH 3425, AND ARE ACCEPTABLE HOWEVER, THE LICENSEE MUST COMPLY WITH THE ANALYSIS OF LEAKt:E RATES AND CORRECTIVE ACTION REQUIREMENTS OF PARAGRAPH IWV-3426 AND 3427(A)
THE USEFULNESS OF IWV-3427(s) DOES.NOT JUSTIFY THE BURDEN OF COMPLYING WITH THIS REQUIREMENT TilIS IS A DEVIATION FROM THE CODE REQUIREMENTS AND SHOULD BE DOCUMENTED IN THE IST PROGRAM
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OBJECTIVE - TO ASSESS OPERATIONAL READINESS OF SAFETY RELATED PUMPS AND VALVES 10 CFR 50,55A REQUIRES PUMPS AND VALVE IST PROGRAM IN ACCORDANCE WITH ASME CODE, SECTION XI UPDATE IST PROGRAMS TO THE CURRENT CODE EDITION AND ADDENDA EVERY 10 YEARS ALLOWS THE GRANTING OF RELIEF REQUESTS FOR
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CODE PCOUIREMENTS THAT ARE IMPRACTICAL STATUS APPR0XIMATELY 42 PLANTS HAVE RECEIVED SERs (35)
APPROXIMATELY 24 PLANTS HAVE SERs THAT ARE OUT OF DATE (SUPERSEDED BY LATTER SUBMITTAL)
PROBLEMS INADEQUATE TESTING REQUIREMENTS IN CODE (TECH)
NO WRITTEN NRC GUIDANCE ON IST (TECH)
HUGE VOLUME OF PROGRAMS / REVISIONS / RELIEF REQUESTS.
HUGE BALKLOG (ADMIN)
RELIEF REQUESTS IMPLEMENTED WITHOUT PRIOR NRC APPROVAL CONTRARY TO TS 4.0,5 (LEGAL)
INSPECTION EFFECTIVENESS HAMPERED (ENFORCEMENT)
PURPO E OF GENERIC LETTER (GL)
PROVIDES GENERIC GUIDAllCE.ON TEN SIGNIFICANT IST PROBLEM AREAS PROVIDES GUIDANCE ON DEVELOPING ACCEPTABLE IST PROGRAMS CLARIFIES APPROVAL STATUS OF IST PROGRAMS (I.E.,
RESOLVES TS 4.0,5 ISSUE)
APPROACH USED IN GL PROGRAMS CURRENTLY UNDER NRC REVIEW CURRENTLY SUBMITTED PROGRAM APPROVED PROVIDED LICENSEES:
- REVIEW PROGRAMS AGAINST ATTACHED POSITIONS, AND
- CONFIRM CONFORMANCE OR JUSTIFY DEVIATIONS FROM ATTACHED POSITIONS IN SIX MONTHS, AND
- MAKE ANY MODIFICATIONS WITHIN SPECIFIED TIME ALTERNATIVES TO ATTACHED POSITIONS ACCEPTABLE PROVIDED:
- MAINTENANCE AND DEGRADATION HISTORY EVALUATED
- DEVIATION JUSTlFIED AND DOCUMENTED, AND l
f-f PROGRAMS WITH COMPLFTED NRC REVIEW IF STAFF HAS ISSUED A SER ON CURRENT PROGRAM,-STATUS OF
'SER UNAFFECTED'BY GL PROGRAM UPDATES / REVISIONS FOR CHANGES IN TECflNICAL AREAS COVERED BY ATTACHED POSITIONS, FOLLOW GUIDANCE FOR PROGRAMS CURRENTLY UNDER NRC REVIEW
~
FOR CHANGES IN' TECHNICAL AREAS NOT COVERED BY ATTACHED POSITIONS-
- FOLLOW 10 CFR 50.55(A) APPROACH IMPLEMENTING PROCEDURES IST PROGRAMS DO NOT CONTAIN TESTING PROCEDURES TESTING PROCEDURES TO BE REVIEWED AGAINST ATTACHED POSITIONS
- INSPECTION AND ENFORCEMENT INSPECTIONS TO BE CONDUCTED FOR CONFORMANCE WITH 10 CFR 50.55A, AS EXPLAINED IN GL
- FOCUS ON ATTACHED POSITIONS
- OTHER AREAS TO BE INSPECTED, AS PERMISSIBLE 1
IMPACT OF GL CURRENT SITUATION
- NO GENERIC NRC TECHNICAL GUIDANCE
- LARGE NUMBER OF UNAPPROVED RELIEF REQUESTS
- LICENSEES IN EFFECT, CAN IMPLEMENT RELIEFS WITHOUT APPROVAL
- ENFORCEMENT IS DIFFICULT
- EMPHASIS ON PROGRAM REVIEWS IN OFFICE
- MORE EMPHASIS NEEDED ON IMPLEMENTATION ANTICIPATED CHANGES
- APPROVAL GRANTED TO PREVIOUSLY UNREVIEWED IST RELIEF REQUESTS
- GENERIC NRC TECHNICAL GUIDANCE IMPLEMENTED
- NRC TO SHIFT RESOURCES FROM PROGRAM REVIEWS TO INSPECTIONS
- FOCUS OF IST TO S!!IFT FROM PROGRAM DOCUMENTATION TO IMPLEMENTATION I
4 :..
" CHANGES FROM GL SENT TO CRGR
- - APPLICATION OF.GL TO SPECIFIED LICENSEES WHOSE SERs ARE'ALMOST COMPLETE
- ~ NEW POSITION ON SCOPE VARIOUS CLARIFICATIONS
- SCHEDULE FOR MODIFICA' IONS
- WORDING IMPROVEMENTS IN GL AND POSITIONS 2, 5, AND 7 CONCLUSIONS GL IS A NECESSARY'FIRST STEP TO SOLVE IST PROBLEMS GL PROVIDES MUCH NEEDED TECHNICAL GUIDANCE TO INDUSTRY GL WILL SHIFT PROGRAM RESPONSIBILITY BACK TO LICENSEES GL WILL MAKE TS ENFORCEABLE l
GL WILL ENABLE FOCUS TO SHIFT TO IMPLEMENTATION
,