NRC Generic Letter 1989-04

NRC Generic Letter 1989-004: Guidance on Developing Acceptable Inservice Testing Programs

ML031150259
Person / Time
Site:	Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Mcguire, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, 05000000, Zimmer, Fort Saint Vrain, Washington Public Power Supply System, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant, Clinch River, Crane
Issue date:	04/03/1989
From:	Varga S A Office of Nuclear Reactor Regulation
To:
References
GL-89-004, NUDOCS 8903300105
Download: ML031150259 (16)

UNITED STATES b Aclc NUCLEAR REGULATORY COMMISSIONWASHINGTON, D. C. 20555April 3, 1989TO: ALL HOLDERS OF LIGHT WATER REACTOR OPERATING LICENSES ANDCONSTRUCTION PERMITSSUBJECT: GUIDANCE ON DEVELOPING ACCEPTABLE INSERVICE TESTING PROGRAMS(GENERIC LETTER NO. 8904)

BACKGROUND

Paragraph 50.55a(g) of 10 CFR Part 50, "Domestic Licensing of Production andUtilization Facilities," requires that certain ASME Code Class 1, 2, and 3pumps and valves be designed to enable inservice testing and that testing beperformed to assess operational readiness in accordance with the Section XIrequirements ot the ASME Boiler and Pressure Vessel Code. The inservicetesting of ASME Code Class 1, 2, and 3 pumps and valves should be viewed asone part of a broad effort to ensure operational readiness of equipment ratherthan viewed in the narrow sense as compliance with 10 CFR 50.55a(g). The intentof the testing is to detect degradation affecting operation and assess whetheradequate margins are maintained. While this letter has been written to provideguidance relative to meeting the requirements of 10 CFR 50.55a(g), it is only onepart of other ongoing industry and regulatory activities. Recent efforts havebeen undertaken by the nuclear industry and NRC sponsored research to provideinformation and techniques for enhanced assurance of equipment operability. NRCstaff concerns regarding equipment operability led to the issuance of Bulletin85-03, dated Novemiber 15, 1985, and Bulletin 85-03, Supplement 1, dated April 27,i988. An expansion of the requirements of this bulletin in the form of a genericletter is being considered by NRC. In addition, NRC is considering rulemakino onIST to develop requirements to address the inadequacies in the current scope andmethods of testing per 10 CFR 50.55a(g).Light Water Reactor (LIR) licensees have submitted to the NRC inservice testing(IST) programs for pumps and valves pursuant to 10 CFR 50.55a(g). The editionsand addenda applicable to IST program intervals are outhlned in 10 CFR 50.55a(g)(4).If the licensee believes thdt conformance with certain code requirements isimpractical, that conformance to the Code would cause unreasonable hardshipwithout a compensating increase in safety or that a proposed alternative providesan acceptable level of quality and safety, 10 CFR 50.55a allows the licensee torequest relief from the Code by notifying the Commission and submitting infor-nation to support this determination. Following the evaluation of this infor-mation, the Conmiassion may grant relief and may impose alternative requirements.All IST programs contain requests for relief from various Coae requirements. Inaddition, the surveillance requirements of technical specification (T.S.) 4.0.5for most plants state that this testing of pumps and valves must be performedin accordance s:ith ASME Section XI except where specific written relief hasbeen granted by the Coruviissiori. Because of the general nature of the :5Tsections of the ASNE Code which does not consider plant specific designs andthe resulting cifliculty in complying with all the ASME Code requirements,utilities frequently revise their programs as more experience with IST isacquirca. Progrcrms at most plants are revised several times during the*29033nt5- / )

I 1-3-Based on the staff's experience the positions contained in Attachment 1 can beimplemented at all plants. However, should licensees be unable to comply withone of these positions because of design considerations or personnel hazard, asopposed to inconvenience, any alternative testing must fulfill the basic testobjective of detecting component degradation. Alternative testing should beindividually evaluated by the licensee and the licensee's plant safety reviewcommittee (or equivalent). When evaluating testing, licensees should addressthe following:1. Maintenance history of the individual (specific) component,2. Maintenance history of related components in a similar environment,3. Component vendor records of degradation at other facilities, and4. Records on degradation of the same or like component from otherutilities.Licensees may utilizE in-plant recoros, the NPRDS and other referenceable sourcesto compile data to address the dbove four areas. A lack of service experienceor test results by itself is not sufficient to justify the alternative test.The alternative test is not considered acceptable unless the above data issufficient to justify its adequacy for detecting degradation and ensuringcontinued operability. Justification for the alternative test should bedocumented and retained in the IST program.For plants not listeo on either Table 1 or 2, currently submitted IST programrelief requests are hereby approved for licensees who have not received an SERprovided that they (1) review their most recently submitted IST programs andimplementation procedures against the positions delineated in Attachment 1and (2) within 6 months of the date of this letter confirm in writing theirconformance with the statec positions. In cases where conformance with thestated positions woula result in equipment modifications, the licensee shouldprovide in his confirmation letter a schedule fcr completing the requiredmodifications. All modifications must be completed within 18 months of thedate of the confirmatory letter or the first scheduled refueling outagefollowing the confirmation letter, whichever occurs later. Changes to the ISTprograms as a result of this generic letter, should be submitted to the NRCalong with the confirmation letter. Approval is granted provided the programsare consistent with the positions taken in Attachment I or, for positions thatnecessitate a plant modification, will be consistent with Attachment I on theschedule noted above. Where a deviation needs to be taken from a specificposition in Attachment 1, the approval is granted provided the adequacy of theproposed alternative testing for detecting degradation is justified as discussedabove.C. Programs With Completed NRC ReviewsFor the plants listed ir Table 2 the staff has completed its review of the ISTprogram arid issued an SEIR. These plants need not respond with the confirimationletter discussed above. The status of the relief requests approved in theSER is not affected by this letter. Tile relief requests that were approved inthe SER may continue to be implemented, and those that were denied should be II-5-the operational readiness of pumps and valves have been or will be the subjectof regulatory actions such as generic letters and rulemaking. Provided theprovisions of this letter are followed, the staff has determined that reliefis granted to follow the alternative testing delineated In positions 1, 2, 6,7, 9, and 10, pursuant to 10 CFR 50.55a(g)(6)(i), is authorized by law, ano willnot endanger life or property or the common defense and security anid is otherwisein the public interest. In making this determination the staff hds consideredthe imprdcticelity of performing the required testing considering the burden ifthe requirements were imposec.This request is covered by Office of Management and Budget Clearance Number3150-0011 which expires December 31, 1989. The estimated average burden hoursis 700 man-hours per owner response, including assessment of the hew recom-mendations, sedrching data sources, gathering and analyzing the data, andpreparing the required letters. These estimated average burden hours pertainwnly to these identified responst-related matters anG do not include the tinefor actual implemnentdtiorn of the requested dctions. Comments on the accuracyof this estlrldte and suggestions to reduce the burden may be directed to theOtfice of Management and Budget, Ruom 3208, New Executive Office Building,Washingtcn, D.C. 20503, dnd the U.S. Nuclear Reguldtory Commission, Recordsand Reports Management Branch, Office of Administration and Resources Manage-wleit, Washington, D.C. 20555.Sincerely,evenR. ,A .gAssociate Director o ProjectsOffice of Nuclear Reactor ReguldtionEnclosures:Tdbles I and 2w/Attachmetit 1 v)TABLE 1PLANTS WITH SERs TO BE ISSUED IN NEAR FUTUREBeaver Valley 1Braidwood 1i&BrunswickCalvert Cliffs 1&2ClintonComanche PeakD.C. Cook 1&2Farley 1&2Ft. CalhounHatch 1&2Hope CreekKewauneeLimerick 1&2McGuire 1&2Millstone 2Nine Mile Point 1hine Mile Point 2Peach Bottom 2&3Rancho SecoRiver BendRobinson 2Seabrook 1SONGS 2&3St. Lucie 2SummerSurry 1&2Vogtle 1Waterford 3Wolf CreekWNP 2Zion 12

4ATTACHMENT 1POTENTIAL GENERIC DEFICIENCIES RELATED TOIST PROGRAMS AND PROCEDUREI. Full Flow Testing of Check Valves.Section XI of the ASME Code requires check valves to be exercised to thepositions in which they perform their safety functions. A check valve'sfuil-stroke to the open position may be verified by passing the maximumrequired accident condition flow through the valve. This is consideredby the staff as an acceptable full-stroke. Any flow rate less than thiswill be considered a partial-stroke exercise. A valid full-stroke exerciseby flow requires thdt the flow through the valve be known. Knowledge of onlythe total flow through multiple parallel lines does not provide verificationof flow rates through the individual valves and is not a valid full-strokeexercise.Full flow testing of a check valve as described above may be impractical toperform for certain valves. It may be possible to qualify other techniquesto confirm that the valve is exercised to the position required to performits safety function. To substantiate the acceptability of any alternativetechnique for fleeting the ASfIE Code requirements, licensees must as aminimum adaress and document the following items in the IST program:1. The imrpracticality of performing a full flow test,2. A description of the alternative technique used and a sumnary ofthe procedures being followed,A description of the method and results of the program to qualifythe alternative technique for meeting the ASME Code,4. A description of the instrumentation used and the maintenance andcalibration of the instrumentation,5. A description of the basis used to verify that the baseline datahas been generated when the valve is known to be in good workingoroer, such as recent inspection and maintenance of the valveinternals, and6. A description of the basis for the acceptance criteria for thealternative testing and a description of corrective actions tobe taken if the acceptance criteria are not fiet.An acceptable alternative to this full-stroke exercising requirement isstated in positior 2 below.

K-'")A different valve of each group is required to be disassembled,inspected, and manually full-stroke exercised at each successiverefueling outage, until the entire group has been tested. If thedisassembled valve is not capable of being full-stroke exercisedor there is binding or failure of valve internals, the remainingvalves in that group must also be disassembled, inspected, andmanually full-stroke exercised during the same outage. Oncethis is completed, the sequence of diassembly must be repeatedunless extension of the interval can be justified.Extending the valve sample disassembly and inspection interval from disas-sembly of one valve in the group every refueling outage or expanding thegroup size would increase the time between testing of any particular valvein the group. With four valves in a group and an 18-month reactor cycle,each valve would be disassembled and inspected every six years. If thefuel cycle is increased to 24 months, each valve in a four-valve samplegroup would be disassembled and inspected only once every 8 years.Extension of the valve disassembly/inspection interval from that allowedby the Code (quarterly or cold shutdown frequency) to longer than onceevery 6 years is a substantial change which may not be justified by thevalve failure rate datd for all valve groupings. When disassembly/inspection data for a valve group show a greater than 25% failure rate,the licensee should determine whether the group size should be decreasedor whether more valves from the group should be disassembled during everyrefueling outage.Extension of the valve disassembly/inspection interval to one valve every otherrefueling outage or expansion of the group size above four valves should onlybe considered in cases of extreme hardship where the extension is supportedby actual in-plant data from previous testing. In order to support extensionof the valve disassembly/inspection intervals to longer than once every 6years, licensees should develop the following information:a. Disassemble and inspect each valve in the valve grouping and documentin detaii the condition of each valve and the valve's capability to befull-stroked.b. A review of industry experience, for example, as documented in NPRDS,regarding the same type of valve used in similar service.c. A review of the installation of each valve addressing the "EPRI Appli-cations Guidelines for Check Valves in Nuclear Power Plants" forproblematic locations.3. Lack Flow Testing of Check Valves.Section XI requires that Category C check valves (valves that are selfactuated in response to a system characteristic) performing a safety func-tion in the closed position to prevent reversed flow be tested in a mannerthat proves that the disk travels to the seat promptly on cessation orreversal of flow. In addition, for category A/C check valves (valves that K>~-5 -On April 20, 1981, the NRC issued an Order to 32 PWRs and 2 BWRs whichrequired that these licensees conduct leak rate testing of their PIYs,based on plant-specific IIRC supplied lists of PIVs, and requiredlicensees to moaify their TS accordingly. These orders are known asthe "Event V Orders" and the valves listed therein are the 'Event VuPIVs. The Event V PIVs are a subset of PIVs.Based upon the results of recent inspections, it has been determinedthat the following implementation problem still exists with respectto testing of PIVs. The staff has determined that in some cases theprocedures are inadequate to assure that these valves are individuallyleak tested and evaluated against the leakage limits specified in theTS; in other cases, the procedures were adequate but were not beingfollowed. Specifically, some check valves were tested in series asopposed to individually and some check valves were not tested whenrequired.Licensees shoula review their testing procedures to ensure the Event VPIYs are individually leak rate tested.5. Limiting Values of Full-Stroke Times for Power Operated ValvesThe Code intent with respect to measuring the full-stroke times of poweroperated valves is to verify operability and to detect valve degradation.Measurement of full stroke times for air operating valves fulfills thisintent. However, reviews of operating experience have identified severalproblems with motor operated valves (MOVs) including limitations withstroke time as a measure of operational readiness of the MOV. As a result,the industry has made extensive efforts to improve the knowledge and under-standing of operational characteristics of motor operated valves. Thiseffort has been conducted by industry groups (NUMARC, INPO, NMAC, EPRI),iniiavidual licensees, equipment vendors, and national standards groups.We believe the information arid knowledge developed by these groups shouldbe reviewed and utilized. Some of the information publicly availableincludes an INPO white paper titled, 'Motor-Operated Valve PerformanceUpdate," issued October 4, 1988. This document identifies MOV problemareas and provides the key elements for a comprehensive MOY program.Another document is the "Technical Repair Guidelines for the LimitorqueModel SMB-OGG Valve Actuator," issued by the Nuclear Maintenance Applica-tion Center (HMAC) in January 1989. This guide addresses several areassuch as setting torque and limit switches, preventive maintenance, actuatorfailure modes, failure analysis to determine root cause and correctiveaction, and preoperational and post-maintenance testing.NRC staff concerns regarding MOV operability led to the issuance of Bulletin85-03 and Bulletin 85-03, Supplement 1. Expansion of this bulletin inthe forrm of a generic letter is being considered by the NRC.

K>~-7-Most plants have many power operated valves that are capable of stroking in 2seconds or less such as small solenoid operated valves. Licensees encounterdifficulty in applying the Code 50' increase of stroke time corrective actionrequirements for these valves. The purpose of this requirement is to detectand evaluate degradation of d valve. For valves with stroke times in thisrange, much of the difference in stroke times from test to test comes frominconsistencies in the operator or timing device used to gather the data.These differences are compounded by rounding the results as allowed bythe Code. Thus, the results may not be representative of actual valvedegradation.The following discussion illustrates the problem that may exist whencomplying with the Code requirements for mdny of these rapid-acting valves:A valve may have a stroke time of 1.49 seconds during one test and astroke time during the following test of 1.51 seconds. If stroke timesare rounded to the nearest second as allowed by the Code, the differencebetween these tests would exceed the 50% criteria and would require anincreased frequency of testing until corrective action is taken. Thiscan result from a stroke time difference of 0.02 seconds, which isusually not indicative of significant valve degradation.Power operated valves with normal stroke times of 2 seconds or less arereferred to by the staff as "rapid-acting valves." Relief may be grantedfrom the requirements of Section Xl, Paragraph IWV-3417(a) for these valvesprovided the licensee assigns a maximum limiting value of full-stroke timeof 2 seconds to these valves and, upon exceeding this limit, declares thevalve inoperable and takes corrective action in accordance with IWV-3417(b).An acceptable alternative to the Code stroke timing requirements is theabove stated rapid-acting valve position. Since this represents a devi-ation from the Code requirements, it should be specifically documented inthe 1ST program.7. Testing Individual Control Rod Scram Valves in Boiling Water Reactors (BWRs)B11Rs are equipped with bottom-entry hydraulically driven control rod drivemechanisms with high-pressure water providing the hydraulic power. Eachcontrol rod is operated by a hydraulic control unit (HCU), which consistsof valves and an accumulator. The HCU is supplied charging and coolingwater from the control rod drive pumps, and the control rod operatingcylinder exhausts to the scram discharge volume. Various valves in thecontrol rod orive system perform an active function in scramming thecontrol rods to rapidly shut down the reactor.The NRC has determines that those ASME Code Class valves that must changeposition to provide the scram function should be included in the ISTprogram and be tested in accordance with the requirements of Section XIexcept where relief has been granted in a previously issued SafetyEvaluation Report or as discussed below.

-9 -oefined in the plant TS can be an acceptable alternate method of detectingdegradation of these valves. Also, trending the stroke times of thesevalves may be impractical and unnecessary since they are indirectly stroketimed and no meaningful correlation between the scram time and valvestroke time may be obtained, and furthermore, conservative limits areplaced on the control rod scran insertion times. If the above test isused to verify the operability of scram inlet and outlet valves, it shouldbe specifically documented in the 1ST program.8. Starting Point for Time Period in TS ACTION StatmentsASME Section XI, IWP-3220, states "All test data shall be analyzed within96 hours after completion of a test". IWP-3230(c) states, in part, "Ifthe deviations fall within the 'Required Action Range' of Table IWP-3100-2,the pump shall be declared inoperative,...."In many cases pumps or valves covered by ASME,Section XI, Subsections IWPand TWV, are also in systems covered by TS and, if declared inoperable,woula result in the plant entering an ACTION state-ment. These ACTIONstatements generally have a time period after which, if the equipment-isstill inoperable, the plant is required to undergo some specific actionsuch as commence plant shutdown.The potential exists for a conflict between the aforementioned data analysisinterval versus the TS ACTION statement time period.Section XI, IWP-6000requires the reference values, limits, and acceptance criteria to beincluded in the test plans or records of tests. With this informationavailable, the shift individual(s) responsible for conducting the test(i.e., shift supervisor, reactor operator) should be able to make a timelydetermination as to whether or not the data meets the requirements.When the data is determined to be within the Required Action Range ofTable IWP-3100-2 the pump is inoperable and the TS ACTION statement timestarts. The provisions in IWP-3230(d) to recali-brate the instrumentsinvolved and rerun the test to show the pump is still capable of fulfilling;ts function are an alternative to replacement or repair, not arladditional action that can be taken before declaring the pump inoperable"he above position, which has been stated in terms of pump testing, isequally valid for valve testing.In summary, it is the staff's position that as soon as the data is recog-nized as being within the Required Action Range for pumps or exceeding thelimiting value of full-stroke tine for vlaves, the associated componentmust be declared inoperable and the TS ACTION time must be started.

KJ-11 -1C. Containment Isolation Valve TestingAll containment isolation valves (CIYs) that are included in the Appendix J,program should be included in the IST program as Category A or A/C valves.The staff has determined that the leak test procedures and requirementsfor containment isolation valves specified in 10 CFR 50, Appendix J areequivalent to the requirements of IUV-3421 through 3425. However, thelicensee must comply with the Analysis of Leakage Rates and CorrectiveAction requirements of Paragraph IWV-3426 and 3427(a).1WV-3427(b) specifies additional requirements on increased test frequenciesfor valve sizes of six inches and larger and repairs or replacement over therequirements of IWV-3427(a). Based on input from many utilities and staffreview of testing data at some plants, the usefulness of IWV-3427(b) doesnot justify the burden of complying with this requirement. Since thisposition represents a deviation from the Code requirements, it should bedocumented in the IST program.1i. IST Program ScopeThe 10 CFR 50.55d requires that inservice testing be performed on certainASME Code Class 1, 2, and 3 pumps and valves.Section XI SubsectionsIWP-1100 and IWV-1100 defines the scope of pumps and valves to be testedin terms of plant shutdowns and accident Mitigation. The plant's FSAR (orequivalent) provides definitions of the necessary equipment to meet thesefunctions. The staff has noted during past IST program reviews andinspections that licensees do not always include the necessary equipmentin their IST programs. Licensees should review their IST programs toensure adequate scope. Examples that are frequently erroneously omittedfrom IST prcgrams are:a. bWR scram system valves,b. control room chilled water system pumps and valves,c. accumulator motor operated isolation valves, or accumulatorvent valves,d. auxiliary pressurizer spray system valves,e. boric acid transfer pumps,f. valves in emergency boration flow path,9. control valves that have a required fail-safe position,h. valves in mini-flow lines.It should be recognized that the above examples of pumps and valves do notmeet the IWP/and IWV scope statement requirements for all plants.The intent of 10 CFR 50 Appendix A, GDC-1, and Appendix B, Criterion XI, isthat all components, such as pumps and valves, necessary for safe operationare to be testtd to demonstrate that they will perform satisfactorily inservice. Therefore, %hile 10 CFR 50.55a delineates the testing requirementsfor ASME Code Class 1, 2, and 3 pumps and valves, the testing of pumps andvalves is not to be limited to only those covered by 10 CFR 50.55a.

LT RRtLIST OF RECENTLY ISSUED GENERIC L ETT ERSGenericDate oflteean eteueAd oaLetter No. WUDJCct 60,w,,- ------ --89-0389-0289-0188-2088-1988-1888-17OPERATOR LICENSING NATIONALEXAMINATION SCHEDULEACTIONS TO IMPROVE THEDETECTION OF COUNTERFEITAND FRAUDULENTLY MARKETEDPRODUCTSIMPLEMENTATION OFPROGRAMMATIC CONTROLSFOR RADIOLOGICAL EFFLUENTTECHNICAL SPECIFICATIONSIN THE ADMINISTRATIVECONTROLS SECTION OF THETECHNICAL SPECIFICATIONSAND THE RELOCATION OFPROCEDURAL DETAILS OFRETS TO THE OFFSITE DOSECALCULATION MANUAL OR TOTHE PROCESS CONTROL PROGRAM.INDIVIDUAL PLANTEXAMINATION FOR SEVEREACCIDENT VULNERABILITIES -10 CFR 50.54(f)USE OF DEADLY FORCE BYLICENSEE GUARDS TO PREVENTTHEFT OF SPECIAL NUCLEARMATERIALPLANT RECORD STORAGE ONOPTICAL DISKSLOSS OF DECAY HEAT REMOVAL10 CFR 50.54(f)3/24/893/21/891/31/8911/23/8810/28/8810/20/8810/17/88ALL POWER REACTORLICENSEES ANDAPPLICANTS FOR ANOPERATING LICENSEALL HOLDERS OFOPERATING LICENSESAND CONSTRUCTIONPERMITS FOR NUCLEARPOWER REACTORSALL LICENSEES HOLDINGOPERATING LICENSESAND CONSTRUCTIONPERMITS FOR NUCLEARPOWER REACTOR FACILITIES.ALL LICENSEES HOLDINGOPERATING LICENSESAND CONSTRUCTIONPERMITS FOR NUCLEARPOWER REACTOR FACILITIESALL FUEL CYCLE FACILITYLICENSEES WHO POSSESS*USE, IMPORT, EXPORT,OR TRANSPORT FORMULAQUANTITIES OF STRATEGICSPECIAL NUCLEAR MATERIALALL LICENSEES OFOPERATING REACTORSAND HOLDERS OFCONSTRUCTION PERMITSALL HOLDERS OFOPERATING LICENSESOR CONSTRUCTIONPERMITS FORPRESSURIZED WATERREACTORS

ENCLOSURE AGUIDANCE FOR THOSE PLANTS COVEREDBY TABLES 1 AND 2 OF GL 89-04Table 1 Plants1. EMEB provides PM IST SE.2. PM issues IST SE to the licensee.3. No confirmation letter required from the licensee.4. Relief requests approved by SE are unaffected by GL 89-04 and may continueto be implemented.5. Relief requests denied in SE should be resolved in accordance with SE.6. If licensees have modified or plan to modify their IST program beyondthat which was the basis for the SE, follow Enclosure C to this memorandum.Table 2 Plants1. No confirmation letter required.2. Relief requests approved by SE are unaffected by GL 89-04 and may continueto be implemented.3. Relief requests denied in SE should be resolved in accordance with SE.4. If licensees have modified or plan to modify IST program beyond thatwhich was the basis for the SE, follow Enclosure C to this memorandum.

ENCLOSURE BGUIDANCE FOR THOSE PLANTS NOT LISTED IN EITHERTABLE 1 OR TABLE 2 OF GL 89-041. GL 89-04 constitutes required approval for the implementation of IST programrelief requests provided licensee reviews their IST program and amends it to:(a) conform with the Code requirements explained in Positions 1, 3, 5,and 11 of Attachment 1 of GL 89-04;(b) conform with the Technical Specification (TS) requirements explainedin Positions 4 and 8 of Attachment 1 of GL 89-04;(c) conform with applicable Code requirements or staff approvedalternatives in Positions 1, 2, 6, 7, and 10 of Attachment 1 of GL89-04; and'(d) justify and document, where required, alternative testing as noted initem 2. below. These justifications may be evaluated duringinspections.2. Where a deviation from a Position in Attachment 1 needs to be taken dueto design considerations or personnel hazard, alternative testing(a) must fulfill the basic test objective of detecting componentdegradation;(b) should be individually evaluated by the licensee and licensee's plantsafety review committee addressing:(i) maintenance history of the specific component;(ii) maintenance history of related components in a similarenvironment;

-2-(iii)component vendor records of degradation at other facilities;and(iv) records of degradation of the same or like components fromother utilities.NOTE: In-plant records, NPRDS, and other referenceable sourcesmay be utilized to compile data to address the aboveareas. Lack of service experience or test results byitself is insufficient to justify an alternate test. Datamust be sufficient to justify the alternative test's adequacyfor detecting degradation and ensuring continued operability.(c) should be documented and retained in the IST program. This may bereviewed during plant inspections.3. Licensee is to confirm by letter by 10/3/89:(a) their conformance, as noted above, to the Positions of Attachment 1to GL 89-04;(b) a schedule for equipment modifications required by conformance tothe Positions of Attachment 1 of GL 89-04; andNOTE: All modifications must be made by the latter of:(i) first scheduled refueling outage following theirconfirmatory letter; or(ii) within 18 months following their confirmatoryletter.

a *K;-3-(c) that procedures have been reviewed and amended to address deficienciesrelated to the implementation of Positions in Attachment 1 of GL89-04.4. PMs should review the confirmation letter for consistency with Item 3 above.5. For areas of non-conformance between the confirmation letter and GL, seeCASE 3 of Enclosure C.

yj,ENCLOSURE CGUIDANCE FOR THOSE FACILITIES MODIFYING THEIR IST PROGRAM BEYONDTHE IST PROGRAM SUBMITTAL AS OF 4/3/89 (i.e. PROGRAM UPDATES/REVISIONS)CASE 1: IST Program Changes for Which Specific Acceptable Alternatives AreProvided in Attachment 1 of GL 89-04GL constitutes the required approval, and no plant specific TACis required.CASE 2: IST Program Relief Request for Which Specific Acceptable AlternativesAre Not Provided in Attachment 1 of GL 89-04 (i.e., in Positions 1, 2, 6,7, and 10).1. 10 CFR 50.55(a)g applies.2. Plant specific TAC to be issued by the PM.*CASE 3: IST Program Changes Taking Exception to the GL or Its Attachment.1. This case would constitute non-conformance to the GL.2. For areas of exception, the licensee would not have NRC approvalto implement the change and would be outside the applicableregulation, 10 CFR 50.55a, if they did.3. The licensee is liable to enforcement action under T.S. 4.0.5 untilNRC review is completed and resolution implemented in the licensee'stesting procedures.* This case is not really covered by the GL