ML20127D604

Responds to 841114 Request for Technical Assistance Re Testing of Max Stroke Time as Part of Inservice Testing Program.Procedures Not in Accordance W/Section Xi,Subsection IWV-3417 of ASME Code Requirements

ML20127D604
Person / Time
Site:	Fermi, LaSalle
Issue date:	04/11/1985
From:	Thompson H Office of Nuclear Reactor Regulation
To:	Spessard R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20126D306	List: IR 05000373/1985016 ML20126D303 ML20126J272 ML20126J289 ML20127C200 ML20127D604
References
NUDOCS 8504190012
Download: ML20127D604 (2)

Text

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Docket No.: 50-341 3 -

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MEMORANDUM FOR: Richard L. Spessard, Director Division of Reactor Safety Region III FROM: Hugh L. Thompson, Jr., Director Division of Licensing Office of Nuclear Reactor Regulation

SUBJECT:

RESPONSE TO REQUEST FOR TECHNICAL ASSISTANCE REGARDING MAXIMUM STROKE TIME TESTING FOR IST OF VALVES We have reviewed the infonnation submitted in your request for technical assistance dated November 14, 1984 testing of the maximum stroke time as part of the in-service testing (ISTregarding) program at the Fenni-2 facility.

Our basic position on this request is that the applicant has committed to comply with the requirements of the ASME Code and has not requested specific relief from the applicable portion of the ASME Code. Our response is directed towards the third concern outlined in your letter (i.e., the acceptability of baseline data established for valve testing in accordance with Section XI of the ASME Code) since the first two concerns were previously resolved.

Acceptability of Baseline Data Established for Valve Testing per Section XI With respect to the applicant's procedures for measuring valve stroke times, as described in your letter dated November 14, 1984, the staff agrees that these procedures are not in accordance with the requirements of Section XI, Subsection IWV-3417 of the ASME Code (the Code). The use of such procedures would require prior written relief by the staff from the specific requirements of the Code.

The specific applicable Code requirements are:

IWV-3417 Corrective Action (a) If, for power operated valves, an increase in stroke time of 25% or more from the previous test for valves with full-stroke times greater than 10 sec or 50% or more for valves with full-stroke times less than or equal to 10 sec is observed, test frequency shal? be increased to once each month until corrective action is taken, at which time the original test frequency shall be resumed. In any case, any abnormality or erratic action shall be reported.

(Emphasisadded).

Contact:

M. Lynch, 49?-7050 g 131985

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f R. L. Spessard, Director APRyy ggS (b) If a valve fails to exhibit the required change of valve stem or disk position or exceeds its specified limiting value of full-stroke time by this testing, then corrective action shall be initiated immediately. If the condition is not, or cannot be, corrected within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the valve shall be declared inoperative. When corrective action is required as a result of tests made during cold shutdown, the condition shall be corrected before startup. A retest showing acceptable operation shall be run following any required corrective action before the valve is returned to service.

As cited above, each in-service test valve stroke time is required to be com-pared to the previous in-service test valve stroke time and is not related in any way to the design or purchase specification for a valve. Additionally, the staff does not interpret a corrective action to be the acceptance of the new stroke time measured on the first monthly test. When a valve has exceeded this criterion on one in-service test, the monthly frequency must be maintained until maintenance is performed on the valve so that it will not become inoperable.

It appears that the applicant's practice for establishing maximum limitino stroke times for valves is also inconsistent with the staff's interpretation of the Code. Subsection IWV is specifically a " component" test code and, therefore, requires that the owner specify the maximum limiting stroke times for each power operated valve (IWV-3413). It is the staff's position that these limiting values of full stroke time are required to be based on reason-able engineering judgement of component (valve) operability, not minimum system

, requirements. System (or component) response time limitations, as stated in the applicant's FSAR or in the plant Technical Specifications, are also time limitations placed on each subcomponent of that system (or compnnent). How-ever, the staff's position is that these response time limitations should 1

rarely take precedence over a component-oriented limiting valve stroke time.

l Inasmuch as the IST program requirements become applicable when Detroit Edison declares that the Fermi-2 facility has gone " commercial," you should bring this matter to its attention so that it can be properly resolved.

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Hugh L. Thompson, Jr., Director

[LL Office Division of Licensing of Nuclear Reactor Regulation

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APR 18.1985 Docket No.: STN 50-483 MEMORANDUM F 'OR: Richard L. Spessard, Director Division of Reactor Safety Region III .

FROM: Hugh L. Thompson, Jr., Director Division of Licensing Office of Nuclear Reactor Regulation -

SUBJECT:

CLOSURE VERIFICATION OF NORMALLY CLOSED CHECK VALVES DURING PREOPERATION TESTING AT CALLAWAY (TIA 83-117)

REFERENCE:

Letter from R. L. Spessard to D. G. Eisenhut on the above subject, dated November 8, 1983.

The referenced letter requested the staff position regarding testing of normally closed check vgives for closure capability during preoperational testing and during plant life. The staff position is that normally closed check valves, that have a safety function in the closed position, should have the closure function verified both during preoperational testing and periodically throughout the plant life. In addition, the staff verifies that closure verification testing is specified in their normal review of the IST program, and if not, measures are taken to see that the program is revised.

I' In an attempt to have the ASME clarify ambiguities within Section XI of the ASME Code regarding valve categorization and leak testing, the staff submitted an inquiry to the society. The response time from the society (approximately one year) was a major factor in the delay of this response to you. Enclosed is a more detailed staff evaluation of the subject.

l)gt:l2., O L- . i hompsoh', Jr.. Dierector

])[HughL.

Division of Licensing Office of Nuclear Reactor Regulation

Enclosure:

As stated cc: T. Martin P. 8emis R. Denise T. Bishop P. Wohld

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L.JQ. Pelke tle, Resident Inspector

Contact:

T. Alexion. LBil (FTS492-8929) 9 Cst'?d o r y \l d Bpp

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" ENCLOSURE  !

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i STAFF EVALUATION REGARDING TESTING 4

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t j 0F NORMALLY CLOSED CHECK VALVES FOR CLOSURE CAPA8ILITY

Reference:

November 8, 1983 remorandum from R. L. Spessard, Region III, I to Darrell G. Eisenhut, NRR ,

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i The referenced memorandum states that there is no apparent requirement in i

Section XI of the ASME Code to verify closure of normally closed check valves i that are classified Category C in accordance with Subsection IWV of the code.

It correctly points out that there are normally closed check valves, other j

thanContainmentIsolationValves(CIVs)andPressureIsolationValves(PIVs), .

4 that have a safety related function in the closed position. An example of l

- such valves is given for the Callaway plant and stated to be a normally closed

ECCS suction line check valve between the Refueling Water Storage Tank and the

! ECCS pumps. '

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! It is stated that verification of the closure function of normally closed check j - valves is a generic safety concern to the extent that surveillance is never

! done after construction to verify the closure function. Specifically, the I staff position was requested regarding:

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1) Testing of normally closed check valves for closure capability l

during preoperational testing.

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2) Testing of normally closed valves for closure capability during l plant life.

j In response, the staff position is, and has been, that normally closed check valves, that have a safety function in the closed position, other than CIVs

! and PIVs, should have the closure function verified both during preoperational testing and periodically throughout the plant life. In the staff's normal

! review of IST programs whenever a valve of this type is identf(ied, the staff

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verifies that closure verification testing is specified in the IST program, i and if not, the staff either requires that the program be revised to so specify i or the staff specifies in the IST SER that closure testing must be performed.

Even though that is the position that the staff has been implementing, the  !

l staff does believe that there is some ambiguity within ASME Section XI re-l garding closure verification testing of normally closed check valves. Check l

! valve testing is specified in paragraph IWV-3520 of the 1983 Edition of Section

! XI. Paragraph IWV-3522 " Exercising Procedure" requires that check valves be  !

! periodically exercised to the position required to fulfill their function.  !

l Testing intervals required vary from a minimum of every three months to each l ,

Cold Shutdown. (Earlier Section XI editions are essentially the same.)

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'l The' Code ambiguity arises from the fact that paragraph IWV-3522(b) "Normally Closed Valves discusses in detail the performance of tests for periodic verification of the valve opening function but does not specifically mention periodic closure verification' tests.

In an attempt to have ASME clarify the ambiguity in the Code paragraphs, the staff submitted a related inquiry to the society. The response to the inquiry, recently received, unfortunately was inconclusive. The staff inquiry was written in broad terms to cover both check and gate valves used in applications where the valve disk in the closed position was essential to the fullfillment of the valve's safety related function. The inquiry asked whether such valves sh'ould be categorized as A or AC and leak tested in accordance with paragraph IWV-3420.

If the ASME response was "no" to the A or AC categorization and leak tests, it was hoped that the reply would at least confim that the intent of IWV-3522 for check valves and IWV-3412 for gate valves was that some kind of closure verification test was to be performed. Unfortunately the response that was received is concentrated on the categorization aspect of the inquiry andsimplystatesthatcategorizationistheOwner's(licensee's) responsibility.

Nevertheless, the staff personnel that participate in ASME 5ection XI standards writing activities were present at some of the meetings when the inquiry was discussed. The impression received at the meetings was that the intent of the Code for both check valves and gate valves was that periodic verification of closure function is required for valves, whether normally open or closed, if they perform a safety function in the closed position. Verification would also be required during preoperational testing by paragraph IWV-3100 " Pre-service Tests" which recuires that all tests to be performed periodically during plant life per IWV-3000 also be performed after installation and prior to service.

One additional item that supports the requirement for periodic closure verification testing is that the latest draft of ANSI /ASME 0M-10 " Inservice Testirig of Valves" specifically requires that check valves be exercised or examined in a manner which verifies obturator travel to the closed, full open, or partially open position required to fulfill its function. ANSI /ASME 0M-10 is generally expected to be an eventual replacement for subsection IWV of,A$ME 5ection XI.

In summary, the staff position is that normally closed check valves that have a safety related function in the closed position should be tested for closure capability during preoperational testing and periodically during plant life in accordance with the intervals specified in IWV-3520.

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