ML20247G248

Part 21 Rept Re Hydro Test of Inboard Isolation Valve.Disc in Valve in RHR Sys Not Tested for Pressure Retention Capability During ASME Test.Item Not Reportable Per Part 21

ML20247G248
Person / Time
Site:	Browns Ferry
Issue date:	02/06/1989
From:	Recasha Mitchell GENERAL ELECTRIC CO.
To:	Berlinger C Office of Nuclear Reactor Regulation
References
REF-PT21-89, REF-PT21-89-029-000 IEIN-88-070, IEIN-88-70, MFN-008-089, MFN-8-89, PT21-89-029-000, PT21-89-29, NUDOCS 8904040175
Download: ML20247G248 (12)

Text

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' GE Nuclear Energy 1 l r

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MFN-008-089 February 6, 1989 j

U. S. Nuclear Regulatory Commission Office of Reactor Regulation Washington, D.C. 20555

Subject:

Hydro Test of Inboard Isolation Valves Attention: Carl H. Berlinger, Chief Generic Communications Branch Please find the attached memo of the discussion with the NRC on February 9,1989 on the subject evaluation performed by General EMi.ric.

Very truly yours, C-R. C. Mitchell, Manager Nuclear Products Licensing cc: L. S. Gifford (GE-Rockville)

P. W. Marriott attachment

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8904p40175 890206 P M M D O C.# EMVGENE 89 PDC

Memo of Discussion

Subject:

Hydro Test of Inboard Isolation Valve l Dater, February 9, 1989 Attendance: E. Baker L. Gifford B. Grimes R. Mitchell l E. Rossi l

The Licensing and Consulting Services (L&CS) organization of GE Nuclear Energy completed a safety evaluation under our 10CFR21 reporting program on the subject of hydrostatic testing of inboard isolation valves. Our eval- ,

uation concluded that it was not a reportable issue. There was no defect 1 identified and, correspondingly, no substantial safety hazard involved. I l

The discoverer has pursued this concern through both the utility and GE where it has undergone extensive evaluation. Both parties concluded it was not reportable. Even in light of these confirming conclusi.ns, the dis-coverer still does not agree that it is non-reportable. He stated that opinion at the recent completion of the GE evaluation. While it is be- j lieved that the NRC has a fairly thorough knowledge of this concern, there  !

are no NRC communintions which have been identified by us which explicitly i address this issue. In the spirit of being responsive to your concern that {

our threshold of deportability should not be too high, and in the spiri'. of i j openness of communications, we believed it proper to communicate the con- t cern and our reasons for finding it to be not reportible.

( Backaround l

l While on a field assignment, the discoverer identified a condition where the disc of the inboard isolation valve in the RHR system was not being tested for pressure retention capability during the ASME hydro test of the )

Reactor Coolant Pressure Boundary. He interpreted this to be a failure to '

meet applicable regulations and codes. This condition was submitted to the utility evaluation process and rejected on the basis that their procedure meets all applicable codes.

This concern was then raised to GE management as a potentiall / reportable condition (Reference 2). It was given a thorough evaluation nainst appli-  !

cable codes (Reference 3) and closed by the discoverer's manager (Reference 4). The closure basis was the same as the utility's.

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l The discoverer appealed under the revised GE procedure 70-42 which calls for submittal directly to Licensing. Upon receipt in Licensing this was automatically entered into the PRC evaluation process.

Basis The concern has been concluded to not represent a substantial safety hazard. No new evidence surfaced in the Licensing evaluation which would indicate that there is a deviation from regulatory or industry require-ments. Valves are required to be hydrostatically tested, leak tested, and functionally tested. These requirements have been judged sufficient to have a high degree of assurance of the operability of the valve when its function is necessary.

The subject of valve testing has long been recognized as impor m to safety and has been thoroughly considered by the NRC. Standard Review Pla 3.9.6 entitled "In-Service Testing of Pumps and Valves" (Rev. 2, July 1981 describes testing of valves to Section XI of the ASME code. This is the basis on which the PRC was rejected by the utility and GE engineering management. A draft Regulatory Guide entitled " Identification of Valves for Inclusion in In-Service Testing Programs" (November 1981) stated that "These valves are required to be leak tested at system functional differen-tial pressure to verify their pressure isolation capability". It went on ,

to say that the NRC recognized the philosophy of leak testing valves at a lower pressure and extrapolating the data to full pressure. This' indicates an acceptance of hydro testing to the outermost isolation valve where its l

disc simply completes the boundary of the hydrostatic test.

Generic Safety Issue II.E.6 (In Situ Testing of Valves, 11/30/83) had the  ;

objective of evaluating whether current requirements _ for valve testing provided adequate assurance of performance ~ under design conditions.

Generic Safety Issue 105 (Interfacing Systems LOCA at BWRs, 6/30/85) also addressed the testing of valves. Generic letter 87-06 (3/13/87) stated that "each licensee's quality assurance program must include planned and systematic actions which will provide adequate confidence that these ,

components will perform satisfactorily in-service". These components are identified in the letter as pressure isolation valves (PIV). We note a TVA response to this generic letter and the NRC accepted that response in their July 6,1988 letter to Mr. S.A. White. In their acceptance the NRC stated that they were still looking at addressing the two generic issues in '

another generic letter which would address the scope of PIV testing.

Finally, the NRC recently addressed Check Valve In-Service Testing Program Deficiencies in Information Notice 88-70. .

From the above, it is evident that the NRC is on top of the issue of valve l testing, recognizes how valves are tested, and is continuing to specify  ;

further actions as they feel necessary. The draft Regulatory Guide indi-cates a clear understanding of their knowledge of testing practices on the inboard isolation valve. j 1

References Complete documentation of the employee concern and our evaluation is included in the following correspondence:  !

1) Letter to P. W. Marriott from G. H. Heinold, dated 9/19/88 on same subject.

2) Letter to H. Ehsan from G. H. Heinold, dated 2/1/88 on same subject.

3) Letter to H. Ehsan from J. C. Major, dated 2/26/88 on same subject.

4) Letter to G. H. Heinold from H. Ehsan, dated 8/9/88 on same subject.

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l 9-19-88 cc: R. C. Mitchell

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From: G. H. Heinold, Valve Design fcw -

SEP 101988 Subj.: Potentially Reportable Condition - TVA RHR/RCPB System Ref.: 1. CAQR dated 8-10-87 t. w.-:f u. u k .):,-g..

2. TVA Memo dated 1-4-88

3. PRC Letter to H. Ehsan dated 2-1-88

4. H. Ehsan Letter Reply to PRC dated 8-9-88

5. GE RHR System Spec. No. 22A1345 Rev. 2 (Applicable to TVA Brown's Ferry While working on contract to TVA on Brown's Ferry 2 Systems, I '

identified the RHR 2 valves in series as RCPB (Reactor Coolant Pressure Boundary) to be hydro tested and when it was not included as a requirement I wrote a CAQR (Condition Adverse to Quality Report) see Ref. 1. This was answered by TVA as not required by Codes and not -

practical to perform, Ref. 2. This was not a satisfactory response so I wrote a PRC, Ref. 3, through GE and it is answered similarly, see Ref.

4. I do not concur that the ASME Code excludes this testing. The closed first valve disk is the limiting barrier of the RCPB for part of the test and the second valve disk is the limiting barrier for the other part of the test.

I am resubmitting this PRC for your consideration and also pointing out the Ref. 5 paragraph 4.2.7.1 which requires the utility to design in the capability for testing even while the plant is operating.

The Brown's Ferry Safety Analysis Report (SAR) (BFNP-67) paragraphs i 1.2-1.b., 1.5.2.2-3., 4.6.1 and 4.6.2-c. attached, direct the correct alproach.

i , ....

USAS B31.1.0 1967 paragraph 122.3.3 (a) is attached, as are Article IWV-2000 and 10CFR 50.2, 50.55a and Part 50 Appendix A.

5 All of the documentation require two isolation valves in series, each to i be capable of isolating the reactor coolant.  !

Some utilities apparently do not presently check each of the two isolation valves on each leg leading away from the reactor as a high pressure isolation device every ten years. It may also be that some utilities d9 not check these devices on a quartely basis.

Not testing for the capability of each isolation device to properly -

perform is a fundamental violation of the Code of Federal Regulations and the ASME Code ,

l RECEIVED Attachments SEP 191988 P. W " iRRIOTT

+ *

. NUCLEAR FUEL &' ENGINEERING SERVICES DEPARTMENT.

San Jose, California ,

February 1, 1988 1

i T0: H.Ehsan, Manager Valve Design FROM: G.H. Heinold A 1

SUBJECT:

' POTENTIALLY REPORTABLE CONDITION - PRC OF TVA RHR SYSTEM RCPB 10 CFR Part 50A Criterion 55 addresses the requirement for 2 isolation '

valves. 10CFR paragraph 50.2 defines the Reactor Coolant Pressure Boundary (RCPB) as up to and including the outermost valve. 10CFR paragraph 50.35a g 4 i requires -inservice examination---- " tests to verify operational readiness of pumps and valves whose function is required for safety"---- .

The Browns Ferry Units 1, 2 a 3 (TVA).RHR system has slanned pressure tests through the first and second valve as an RCPB.(with tie first valve open and.

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the second valve closed). This tests the' function of the second valve-as an isolation device and the integrity of containment of the RCPB (hydrostatic-test) as required every ten years. This does not test the first valve to function as an' isolation' device as required by Paragraph 50.55a g 4 i above.

It is conceivable that the wording of Paragraph 50.2 up to and including the outermost valve may' lead your thoughts away,from the first valve. The valve leak checking may fuzz up your thinking also but the Icak checking is at approx. 50 psid pressure and the leakage ~ rate is extrapolated up to the operating pressure, this does not test the isolation capability of the first valve. ..

The condition exists'that the first valve is not tested for function of isolation capability and is considered a serious oversight, a Potentially Reportable Condition and a Substantial Safety Hazard due to not testing every ten years a basic component necessary to the integrity of the RCPB. Thare are'three such first valves on each TVA BF unit that are not tested. This PRC may be relevant to other systems, other BWRs and other PWR plants. 1 This additional test will add scme time to the hydro but the time duration could probably be 30 minutes, not a doubling of hydro time."

Enclosed is TVA's answer to a (CAQR) Potential Condition Adverse to Quality Report on this topic. The CAQR was signed off on 8-10-87 by me, apparently lost in a TVA office move until November or December 1987 and reported as not a CAQ on 1-4-88.

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, ENGINEERING SERVICES' Plant & Equipment Design ec: J. Jacobson-G.H. Heinold C.T. Nieh -

E.0. Swain February 26, 1988 T0: H. Ehsan, Manager -

. Valve Design FROM: J.C. Major Program Management

SUBJECT:

PRC OF TVA RHR SYSTEM RCPB

Reference:

Letter G. Heinold to H. Ehsan "Potentially Reportable Condition - "

PRC OF TVA RHR SYSTEM RCPB" Per your request I have reviewed Section XI of the ASME Code as it applies to the referenced report of a potentially reportable condition. It is my conclusion that a violation of Section XI did not occur and therefore does not form the basis for a PRC. I find nothing in Section XI requiring a separate hydrostatic test of the inboard isolation valve disc'as.a part of the periodic (10 year) system hydrostatic test.

A call was made to T.F. Hoyle, Chairman of the ASME Operations and Maintenance, Working Group on Inservice Testing of Pumps and Valves, who is a Senior Engineer with Q.A. and-Testing background at WPPSS. He stated that they test the inboard isolation valve body as an inline pressure boundary component during hydrostatic testing of the system and examine for external leakage, but do not-interpret the Code'to require separate hydrostatic .

testing of the inboard valve disc.

ASME Section XI, Rules for I'nservice Inspection of Nuclear Power Plants

- becomes effective as'soon as all the requirements of the Construction Code (ASME Sectiori III or B31.1) have been met.

Under Section XI:

1) Subsection IWA provides General Requirements.

2) Subsection IWB provides inservice examination requirements for Class I components.

3) Subsection IWV provides requirements for inservice testing to assure operational readiness of valves.

IWS-5000 (IWB-5210) requires Class I pressure retaining components to be

' Hydrostatic tested and visually examined per table IWB-2500. Table IWB-2500, l reiterates that the examination method is " Visual, VT-2" and requires one l test per (10 year) inspection interval. Per note 2, all Class I components within the system boundary must be included in the test.

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Page 2 H. Ehsan February 26, 1988 The emphasis of the 7.bove and additional referenced paragraphs (IWA-5240, IWA-2212) is on txsminina external exoosed surfaces of pressure retaining components for evidence of leakage.

IWV, addresses inservice testing of valves and includes two types of requirements, valve seat leakage tests for those (Category A) valves where seat leakage is limited to a specific maximum amount when closed, and valve exercising tests to determine that the valves are functional. Isolation valves fall in Category A and require both types of testing.

The above testing is not related to the system hydrostatic test of IWB. The exercising frequency for Category A valves is once every three months and the valve seat leakage test frequency -is once every two years. Additionally, the seat leakage test is permitted to be run at a low pressure and the leakage rate extrapolated to the function maximum differential pressure.

The testing required by IWV is intended to show operational readiness by demonstrating that the valve will operate to the position required to fulfill its function and that seat leakage is within values specified by the Plant Owner. .

Based on the above, I agree with TVA's interpretation that " Testing as I suggested in the potential CAQR is not required by applicable codes". I do l not believe there is any basis in the Sec. XI Code to conclude that not separately hydrostatically testing the inboard isolation valve seat is a PRC.

Please be aware that I did not review the requirements of 10CFR50 or the TVA test requirement documents to see if they have a bearing on determination of whether a PRC exists.

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IWA 2120-IWA 2212 SECTION XI - DIVISION 1 1983 Edit on requirements of the examination procedures and the IWA.2200 EXAMINATION METHODS -

' quali6 cation procedures of nondestructive eaam- (

" ination personnel. (a) The three types of eneminations used during \

(e) The Inspector may require at any time requrt- inservice '-Ws am dennad as visual, surface, and ification of any procedure or operator if the Inspector volumetnc. The n=mm=aan method to be used is

! has reason to believe the requirements are not being 8peci6ed in Tables IWB , IWC , IWD , IWE , and met. IWF-2500-1. If a component must be examined in a (f) The examination records shall be certified by high radiaria area, reinotely controlled equipment l the Inspector only after verifying that the require- may be advisable.

• nents have been met and that the records are correct. (b) When pnparation of a surface fo< nondestruc-(g) The Inspector shall verify that repairs are tive n==nadon is required, the preparauon shall be performed in accordance with the requirements of the by a mechamcal method. Such surfaces shall be Owner's repair program. blended into the surrounding area as may be required (h) The Inspector shall review the Quality Assur. to Perform the n==nadon. The waU thickness shall ance Program for repairs and its implementation. n t k reduced below the =nimurn thickness required

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by design. \.

IWA 2130 QUALIFICATION OF INSPECTORS, INSPECTION SPECIALISTS, AND INSPECTION AGENCIES IWA 2210 VISUAL EXAMINATIONS ,

(a) The inspection required by this Division shall be IWA 2211 Visual Framin= tion VT 1 performed: -

(a) The VT 1 visun! namination shall be conducted (1) where the power plant is in the United States, to determine the condition of the part, component, or by an Inspector employed by a State or Municipality surface namined, including such coaditions as cracks, of the United States or an Inspector regularly em- wear, corrosion, erosion, or physical damage on the ployed by an insurance company authorized to write surfaces of the part or components.

boiler and pressure vessel insurance in the United (b) Direct VT 1 visual examination may be con. (-

States; -

ducted when access is suHicient to place the eye within (2) where the power plant is in Canada, by an 24 in. of the surface to be namined and at an angle Inspector employed by a Canadian Province or, if not less than 30 deg. to the surface. Mirrors may be authorized by the Province in which the power plant is used to improve the at,gle of vision. Lighting, natural located, by an Inspector regularly employed by an or aruScial, shall be suHicient to resolve a %: in. black insurance company licensed to write boiler and line on an 18% neutral gray card.

pressure vessel insurance in that Province; (c) Remote VT 1 visual namin= tion may be substi-(3) by an Inspector employed by other enforce- tuted for direct examination. Remote namination ment authorities in the United States or Canada may use aid, such as telescopes, bcrescopes, 6ber having jurisdiction over the designated power plant. optics, cameras, or other suitable instruments, pro-(b) The Authorized Inspection Agency, including vided such systems have a resolution capability at least its staff of Authorized Nuclear Inservice Inspector equivalent to that attainable by direct visual exam .

Supervhors and Inspection Specialists, and the Inspec- ination. (

tor., shall meet the requirements of ANSI /ASME N626.1 1975. ~

i IWA 2212 Visual Framination VT-2 IWA 2140 ACCESS FOR INSPECTOR (a) The VT 2 visual namination shan be conducted The Owner shall arrange for an Inspector to have to locate evidence ofleakage from pressure retaimag access to all parts of the plant as necessary to make the components, or abnormal leakage from components required inspections. The Owner shall keep the with or without leakage conection systems as required Inspetoi informed of the progress of the preparatory during the conduct of system pressure or functional work necessary to permit inspections and shall notify test.

the Inspector at a time reasonably in advance of when (b) The VT 2 visual examination shall be conducted the components will be ready for inspection. '

accordance with IWA 5240. k.

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IWA 5223-!WA 5245 SECTION XI - DIVISION 1 1983 Edition 9

those pressure retaming components under operating insulation. Eue,tially vertical surfaces of insulation pressures during normal system service. need only be eummined at the lowest elevation where leakage may be detectable. Essentially horizontal (. .

i IWA 5224 System Hydrostatic Test Boundary surfaces of insulation shad be esamined at each insulation yn,nt.

(a) "Ite boundary subject to test pressurization (b) For components whose external insulation sur-during a system hydrostatic test [IWA-5211(d)] shall faces are innece==ible for direct nummmation, only the be defined by the system boundary (or each portion of e===ination of surrounding area (including floor areas the boundary) within which the components have the or equipment surfaces located underneath the compo-same mmimum required classiScation and are de- nents) for evidence ofleakage, or other areas to which signed to the same primary pressure rating as gov- such leakage may be channeled, shall be required.

erned by the system function and the internal fluid (c) Discoloration or residue on surfaces exammed operating conditions, respectively. shad be given particular attention to detect eviden2e of (b) Systems which share safety functions for boric acid accumulations from borated reactor coolant different modes of plant operation, and within which leakage.

the component classifications differ, shall be subject to .

(-.

separate system pressure tests of each portion of the -

system boundary having the same minimum required IWA 5243 Components With renkere Couection component classifications. Systems (c) Systems designed to operate at different pres-Where leakages from con:ponents are normally sures under several modes of plant operation or post-expected and collected (such as valve stems, pump accident conditions shall be subject to a system seals, or vessel Sange gaskets) the visual examination pressure test within the test boundary defmed by the i VT 2 shah be conducted by verifying that the leakage i operating mode with the pigher pressure. collection system is operative.

(d) Where the respective system primary pressure ratings on the suction and discharge sides of system

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a pumps differ, the system ' test boundary shall be IWA 5244 Buried Components divided into two separate boundaries (such as suction (a)In nonredundant systems where the buried side and discharge side test boundanes). In the case of components are isolable by means of valves, the visual positive displacement pumps, the boundary interface examination VT-2 shall consist of a leakage test that shall be considered as the pump. In the case of determmes the rate of pressure loss. Alternatively, the centrifugal pumps, the boundary interface shall be the test may determme the change in flow between the Erst shutoff valve on the discharge side of the pump. - ,

ends of the buried components. The acceptable rate of I q

pressure loss or Sow shall be established by the r -

Owner.

IWA 5240 VISUAL EXAMINATION (b) In redundant systems where the buried compo- I nents are nomsolable, the visual exammation VT 2 IWA 5241 Noninsulated Components shah consist of a test that determmes the change in (a) The visual examination VT-2 shall be conducted Sow between the ends of the buried components. In by examining the accessible external exposed surfaces cases where an annulus surrounds the buried compo-of pressure retaining components for evidence of nents, the amas at each end of the buried components (

leakage. shall be visuaDy erammed for evidence ofleakage in (b) For components whose external surfaces are lieu of a Sow test.

inaccessible for direct visual examination VT-2, only (c) in nonredundant systems where the bun,ed the examination of surrounding area (including floor comp nents are nonisolable, such as return lines to the areas or equipment surfaces located underneath the beat sink, the visual examination VT-2 shall consist k components) for evidence ofleakage shall be not required.)

impaired. only of a veri 6 cation that the Sow durin

, IWA 5242 Insulated Components

1. rf th'e visual examination VT-2 may be conducted I A a EPerum Tests without the removal of insulation by examining the The visual examination of system components ,

accessible and exposed surfaces and joints of the requiring a test temperature above 200*F during the g 32

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i ENGINEERING SERVICES 1

Plant & Equipment Design Engineering j cc: J. Jacobson .

'R.'C 7EMitchellt C.T. Nieh G.B.~Stramback

. RECEIVED 1 August 9, 1988 AUE 3 l

R. C, NUTCHELL T0: G.H. Heinold Valve _ Design

SUBJECT:

REPLY TO YOUR LETTER,

SUBJECT:

PRC 0F TVA RHR SYSTEM RCPB DATED FEBRUARY 1, 1988.

REFERENCE:

J.C. Major letter of February 26, 1988 same subject. -

After exhaustive review of your letter and considerable review and discussion with different knowledgeable personnel. I have concluded that TVA's answer to (CAQR) potential condition adverse to quality report on your concern is correct. This also was concluded by Joe Major (see Reference 2) page 2 the fifth paragraph.

As you are aware the new P&P 70-42 (June 88) on Potentially Reportable Conditions allows you to go directly to Licensing and Consulting Services with your concern. If you disagree with my conclusion, you should pursue it with them.

2 H. Ehsan, anager Valve Design M/C 753, Ext. 51815 attachments

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