NUREG-1482

Guidelines forInservice Testing atNuclear Power Plants

U.S. Nuclear Regulatory Commission

Office of Nuclear Reactor Regulation

P. Campbell

NUREG-1482

Guidelines forInservice Testing atNuclear Power Plants

Manuscript Completed: April 1995Date Published: April 1995

P. Campbell

Division of EngineeringOffice of Nuclear Reactor RegulationU.S. Nuclear Regulatory CommissionWashington, DC 20555-0001

NUREG-1482iii

ABSTRACT

The staff of the U.S. Nuclear Regulatory Commission (NRC) gives licensees guidelines andrecommendations for developing and implementing programs for the inservice testing of pumpsand valves at commercial nuclear power plants. The staff discusses the regulations; thecomponents to be included in an inservice testing program; and the preparation and content ofcold shutdown justifications, refueling outage justifications, and requests for relief from theAmerican Society of Mechanical Engineers Code requirements. The staff also gives specificguidance on relief acceptable to the NRC and advises licensees in the use of this information attheir facilities. The staff discusses the revised standard technical specifications for the inservicetesting program requirements and gives guidance on the process a licensee may follow uponfinding an instance of noncompliance with the Code.

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CONTENTS

ABSTRACT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iii

ABBREVIATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ix

EXECUTIVE SUMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xi

PREFACE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xiii

1 INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-11.1 Regulatory Basis. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-11.2 Regulatory History. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-21.3 NRC Recommendations and New Guidance. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-31.4 Other Information. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-41.5 Synopsis of Report. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-4

2 DEVELOPING AND IMPLEMENTING AN INSERVICE TESTING PROGRAM. . . . 2-12.1 Compliance Considerations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-12.2 Criteria for Selecting Pumps and Valves for the IST Program. . . . . . . . . . . . . . . . . 2-42.3 Code Class Systems Containing Safety-Related Pumps and Valves. . . . . . . . . . . . . 2-72.4 IST Program Document . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-7

2.4.1 Pumps. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-72.4.2 Valves. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-82.4.3 Piping and Instrument Diagrams . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2-102.4.4 Bases Document. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2-102.4.5 Deferring Valve Testing to Cold Shutdown or Refueling Outages. . . . . . . . . 2-11

2.5 Relief Requests and Proposed Alternatives. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2-112.5.1 Justifications for Relief . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2-112.5.2 Categories of Relief Requests. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2-132.5.3 Content and Format of Relief Requests. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2-13

3 GENERAL SUPPLEMENTAL GUIDANCE ON INSERVICE TESTING. . . . . . . . . . . . 3-13.1 Inservice Test Frequencies and Extensions for Valve Testing. . . . . . . . . . . . . . . . . 3-1

3.1.1 Deferring Valve Testing to Each Cold Shutdown or Refueling Outage. . . . . . . 3-13.1.2 Entry into a Limiting Condition for Operation to Perform Testing. . . . . . . . . . 3-63.1.3 Scheduling of Inservice Tests. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-8

3.2 Start of the Time Period in Technical Specification Action Statements. . . . . . . . . . 3-93.3 120-Month Updates Required by 10 CFR 50.55a(f)(4)(ii) . . . . . . . . . . . . . . . . . . .3-11

3.3.1 Extension of Interval. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3-123.3.2 Concurrent Intervals. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3-133.3.3 Implementation of Updated Programs. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3-143.3.4 General Comments on Inservice Testing Intervals. . . . . . . . . . . . . . . . . . . . .3-16

3.4 Skid-Mounted Components and Component Subassemblies. . . . . . . . . . . . . . . . .3-173.5 Testing in the As-Found Condition. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3-18

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4 SUPPLEMENTAL GUIDANCE ON INSERVICE TESTING OF VALVES. . . . . . . . . . 4-14.1 Check Valves . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-1

4.1.1 Closure Verification for Series Check Valves without Intermediate TestConnections . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-2

4.1.2 Exercising Check Valves with Flow and Nonintrusive Techniques. . . . . . . . . . 4-34.1.4 Extension of Test Interval to Refueling Outage for Check Valves Verified

Closed by Leak Testing. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-74.2 Power-Operated Valves. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-8

4.2.1 Increased Frequency of Testing for Valves That Can Be Tested Only During Cold Shutdown Outages . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-9

4.2.2 Stroke Time Measurements for Rapid-Acting Valves. . . . . . . . . . . . . . . . . . .4-104.2.3 Measurement of Valve Stroke Time . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4-114.2.4 Main Steam Isolation Valves. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4-124.2.5 Verification of Remote Position Indication for Valves by Methods Other

Than Direct Observation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4-134.2.6 Requirements for Verifying Position Indication . . . . . . . . . . . . . . . . . . . . . . .4-134.2.7 Stroke Time Measurements Using Reference Values. . . . . . . . . . . . . . . . . . .4-144.2.8 Solenoid-Operated Valves. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4-154.2.9 Control Valves with a Safety Function. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4-15

4.3 Safety and Relief Valves . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4-164.3.1 Scope . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4-164.3.2 OM-10 Reference to OM-1. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4-184.3.3 Test Supervisor Qualifications. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4-184.3.4 Frequency and Method of Testing Automatic Depressurization Valves in

Boiling-Water Reactors. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4-194.3.5 Jack-and-Lap Process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4-214.3.6 Safety/Relief Valve Setpoint Adjustments . . . . . . . . . . . . . . . . . . . . . . . . . . .4-214.3.7 Setpoint As-Found Value . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4-224.3.8 Vacuum Relief Valves . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4-234.3.9 Clarifications in OM-1, OMc-1994 Addenda to the 1990 Edition of the

OM Code . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4-244.3.10 Valve Groups and Number of Valves to be Tested. . . . . . . . . . . . . . . . . . . . .4-25

4.4 Miscellaneous Valves . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4-264.4.1 Pressurizer Power-Operated Relief Valve Inservice Testing. . . . . . . . . . . . . .4-264.4.2 Post-Accident Sampling System Valves . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4-274.4.3 Multiple Containment Isolation Valve Leak-Rate Testing. . . . . . . . . . . . . . .4-274.4.4 Post-Maintenance Testing After Stem Packing Adjustments and Backseating

of Valves to Prevent Packing Leakage. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4-294.4.5 Leak-Rate Testing Using OM-10 Requirements. . . . . . . . . . . . . . . . . . . . . . .4-314.4.6 Manual Valves. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4-314.4.7 Pressure Isolation Valves. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4-324.4.8 Containment Isolation Valves Which Have Other Leak-Tight Safety

Function(s). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4-33

5 SUPPLEMENTAL GUIDANCE ON INSERVICE TESTING OF PUMPS. . . . . . . . . . . 5-1

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5.1 General Pump Inservice Testing Issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-15.1.1 Frequency of Inservice Tests — Comparison of the American Society of

Mechanical Engineers Code to Technical Specifications . . . . . . . . . . . . . . . . . 5-15.1.2 Continued Measurement of Parameters Deleted from OM-6 . . . . . . . . . . . . . . 5-2

5.2 Use of Variable Reference Values for Flow Rate and Differential Pressure DuringPump Testing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-3

5.3 Allowable Variance from Reference Points and Fixed-Resistance Systems. . . . . . . 5-55.4 Monitoring Pump Vibration in Accord with OM-6 . . . . . . . . . . . . . . . . . . . . . . . . . 5-65.5 Pump Flow Rate and Differential Pressure Instruments. . . . . . . . . . . . . . . . . . . . . . 5-8

5.5.1 Range and Accuracy of Analog Instruments. . . . . . . . . . . . . . . . . . . . . . . . . . . 5-95.5.2 Range and Accuracy of Digital Instruments . . . . . . . . . . . . . . . . . . . . . . . . .5-105.5.3 Use of Tank or Bay Level to Calculate Differential Pressure . . . . . . . . . . . .5-105.5.4 Accuracy of the Flow Rate Instrument Loop. . . . . . . . . . . . . . . . . . . . . . . . .5-11

5.6 Operability Limits of Pumps. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .5-115.7 Use of OM-6 Table 3b Ranges for Hydraulic Parameters. . . . . . . . . . . . . . . . . . . .5-125.8 Duration of Tests . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .5-135.9 Vertical Line Shaft Pumps . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .5-135.10 Adjustments for Instrument Inaccuracies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .5-14

6 REVISED STANDARD TECHNICAL SPECIFICATIONS. . . . . . . . . . . . . . . . . . . . . . . 6-16.1 Introduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-16.2 History . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-16.3 Discussion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-4

7 IDENTIFICATION OF CODE NONCOMPLIANCE. . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-17.1 Nonconformance Conditions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-17.2 Design Basis Reviews . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-1

8 REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-2

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APPENDICES

A Positions, Questions, Responses, and Current Considerations Regarding Generic Letter 89-04

B Valve Tables

C Relief Requests

D Safety Evaluation

E Bases Document

F Design Bases Review Process Description for Compliance with Generic Letter 91-18 Guidance

G Comments and Responses on Draft NUREG-1482

H Generic Letter 89-04, Supplement 1

TABLES

2.1 Typical systems and components in an inservice testing program for a pressurized-waterreactor. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2-15

2.2 Typical systems and components in an inservice testing program for a boiling-water reactor. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2-18

2.3 Example data table for pumps . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2-212.4 Useful abbreviations for valve data tables. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2-223.1 ASME Boiler and Pressure Vessel Code terms for inservice testing activities . . . . . . . . . 3-83.2 Required tests and test frequencies for pumps and valves. . . . . . . . . . . . . . . . . . . . . . . .3-194 Sample testing using nonintrusive techniques (NITs) and the flow testing (FT)

procedure. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-4

EXAMPLES

3.1 Cold shutdown justification CSJ-4. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3-203.2 Cold shutdown justification RBC-1 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3-203.3 Refueling outage justification. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3-213.4 Refueling outage justification ROJ/SI-4. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3-22

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ABBREVIATIONS

ADS automatic depressurization systemALARA as low as reasonably achievableANSI American National Standards InstituteASME American Society of Mechanical Engineers

BWR boiling-water reactorBWST borated water storage tank

CFR Code of Federal RegulationsCIV containment isolation valveCSJ cold shutdown justification

ECCS emergency core cooling system

FT flow test

GE General Electric CompanyGL generic letter

HPCI high-pressure coolant injection

IN information noticeIP inspection procedureISI inservice inspectionIST inservice testing

LCO limiting condition for operationLOCA loss-of-coolant accident

MSIV main steam isolation valve

NIT nonintrusive techniquesNRC U.S. Nuclear Regulatory Commission

OM Operations and Maintenance

PASS post-accident sampling systemPD positive displacementP&ID piping and instrument diagramPORV power-operated relief valvePTC Performance Test CodePWR pressurized-water reactor

RCIC reactor core isolation cooling

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RCS reactor coolant systemRG regulatory guideRHR residual heat removal RPM revolutions per minuteRWST refueling water storage tankRWT refueling water tank

SAR safety analysis reportSBLC standby liquid controlSI safety injectionSOV solenoid-operated valveSR surveillance requirement

TI temporary instructionTS technical specifications

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EXECUTIVE SUMMARY

The U.S. Nuclear Regulatory Commission NRC staff participation on the OM(NRC) is issuing this report to assist the committees.industry in eliminating unnecessary requestsfor relief and to give approval of an alternate (4) To indicate the acceptability or the needmethod of inservice testing (IST) if that for caution in applying certainmethod is in accord with the latest edition of ASME/OM interpretations. industry Codes and standards approved by theNRC. These Codes and standards are found (5) To consolidate references to variousin the American Society of Mechanical documents that apply to IST.Engineers (ASME) Boiler and Pressure VesselCode and the ASME/American National (6) To clarify the information to be includedStandards Institute Operations and in an IST program, the format for reliefMaintenance (OM) Standards, Part 6, requests and cold shutdown/refueling"Inservice Testing of Pumps in Light-Water outage justifications, and the scope of ISTReactor Power Plants," (OM-6) and Part 10, programs."Inservice Testing of Valves in Light-WaterReactor Power Plants" (OM-10). If the (7) To clarify certain ASME Code or NRCguidance in this report is used, it will assist the regulatory issues.industry in establishing a consistent ISTapproach, but implementation of the new The staff discusses new IST issues andguidance is strictly voluntary. No backfit is associated guidance that it found whileintended or approved in connection with participating in ASME Code committees,issuance of this document. This report lists reviewing and evaluating relief requests orportions of OM-6 and OM-10 that licensees proposed alternatives, reviewing inspectionmay partially implement if the related findings and responses, meeting and discussingrequirements stated in the applicable with licensees and industry groups, and issuingrecommendation are met. other generic correspondence.

NRC is issuing this guidance for the following The voluntary nature of the new guidancepurposes: differs from the previously approved positions

(1) To approve portions of OM-6 and OM-10 Acceptable Inservice Testing Programs,"that the staff has determined are which were not entirely voluntary. The newacceptable to implement pursuant to the guidance includes approval of the use of theCode of Federal Regulations, Title 10, new ASME Operations and MaintenanceParagraph 50.55a(f)(4)(iv). Standards, which have been incorporated into

(2) To give guidance on information that approves the use of portions of theseneeds to be included in relief requests for standards, pursuant to paragraphprompt staff approval. 50.55a(f)(4)(iv), before this regulation would

(3) To clarify issues that have been found in 10-year interval IST programs. This approvalNRC inspections, from licensees' is part of the staff's effort to refocus NRCtelephone calls or meetings, and through attention on inspections and audits. The

in GL 89-04, "Guidance on Developing

the regulations. The new guidance also

take effect for individual licensees for updated

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actions that those licensees who choose to use and is part of the plan for improving ISTthe new guidance must take to satisfy programs first established by GL 89-04. Theparagraph 50.55a(f)(4)(iv) are included herein staff plans to further revise the regulations andand will ensure that the implementation is complete a summary of relief requests whichacceptable. The new guidance will be useful have been submitted since GL 89-04 wasto licensees in developing and implementing issued. the regulations and ASME Code requirements,

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PREFACE

On April 3, 1989, the NRC issued Generic implementation in the "NRCLetter (GL) 89-04, "Guidance on DevelopingAcceptable Inservice Testing Programs,"which gave guidance to correct severalweaknesses the NRC staff found in inservicetesting (IST) programs at nuclear powerplants. The staff issued the generic letter aspart of its effort to improve IST programs sothat the staff could verify a program wasacceptable by doing audits and inspections atthe plant site rather than by reviewing theprogram before it is implemented. GL 89-04addressed frequently encountered issues suchas relief requests, procedural implementation,and technical specification provisions foroperability. The positions in GL 89-04 werenot for voluntary implementation in all cases,since the staff requested certain licenseesimplement the positions of the generic letter. However, the guidance herein is strictlyvoluntary.

Certain terms in this document havegradations of regulatory significance tolicensees. Where the requirements of NRCregulations or the ASME Code, asincorporated into the regulations, arediscussed, the terms shall, must, requires, orrequirements are used consistently to indicatetheir mandatory nature. The term must is alsoused in another manner in the context ofimplementing guidance (not requirements), asdiscussed below. The word should is used intwo contexts: (1) in reiterating previouslyapproved NRC staff positions or requirementspromulgated by generic letter or otherapproved generic correspondence, and (2) instating staff recommendations for voluntary

Recommendations" sections. The terms NRCrecommendation, staff recommendation,recommends, acceptable to the staff,acceptable, licensee may, and licenseetypically would are used to discuss issues thathave been evaluated in, and reflect NRC stafffindings from, previous plant-specific safetyevaluations related to IST relief requests, NRCinspection reports, meetings (ASME CodeCommittee meetings, meetings with licensees,and NRC/ASME symposia), and other genericcorrespondence. The term must is used withprovisions of the guidance herein intended forvoluntary implementation by licensees toindicate that, if a licensee chooses toimplement the guidance of a section, thelicensee is to follow such provisions in thatsection without deviation in order to receivecredit for satisfactorily meeting the guidanceof that section.

The new guidance herein is similar inappearance to NRC staff positions given in aregulatory guide because of the termsdiscussed above, and because certainrecommendations indicate acceptablealternatives to Code requirements. However,this guidance is not equivalent to staffpositions in a regulatory guide or other genericcorrespondence, because this guidance isintended strictly for voluntary implementationby licensees. Licensees may still need to seekapproval for certain of these recommendationsthrough the process described in 10 CFR 50.55a.

NUREG-1482���

1 INTRODUCTION

1.1 Regulatory Basis

Section 50.55a of Title 10 of the Code ofFederal Regulations (10 CFR 50.55a) definesthe requirements for applying industry codesand standards to boiling or pressurized water-cooled nuclear power facilities. Each of thesefacilities is subject to the conditions inparagraphs (a), (f), and (g) of 10 CFR 50.55afor inservice inspection and inservice testing(IST). By rulemaking effective September 8,1992 (see Federal Register Vol. 57, 34666),the U.S. Nuclear Regulatory Commission(NRC) established paragraph (f) to separatethe IST requirements from the inserviceinspection requirements in paragraph (g).

The American Society of MechanicalEngineers (ASME) Boiler and Pressure VesselCode (the Code), Section XI, SubsectionsIWP and IWV, specify the IST requirementsfor pumps and valves. The 1989 edition ofSection XI was incorporated by reference intoparagraph 50.55a(b) by the rulemakingeffective September 8, 1992. The 1989edition specifies that the rules for the IST ofpumps and valves are stated in theASME/ANSI Operations and Maintenance(OM) Standards, Part 6, "Inservice Testing ofPumps in Light-Water Reactor Power Plants,"and Part 10, "Inservice Testing of Valves inLight-Water Reactor Power Plants." Anexception to OM-10 was taken in theregulation related to leakage testing ofcontainment isolation valves (see10 CFR 50.55a (b)(2)(vii)).

Licensees are required to prepare ISTprograms which specify the componentsincluded in the program, and the testing andtest frequencies for these components, and toimplement the program in accordance with the

Code. The regulations allow that where a testrequirement of the Code is determined to beimpractical for a facility, the licensee maysubmit requests for relief from the Code withinformation to support the determination. Relief requests generally detail the reasons fordeviating from the Code requirements anddescribe proposed alternative testing. TheCommission is authorized to evaluate therelief requests and may grant relief or imposealternative requirements, considering theburden upon the licensee that could result ifthe requirements were imposed on the facility. The Commission may also authorizealternatives to the Code requirements pursuantto 10 CFR 50.55a (a)(3)(i) and (a)(3)(ii) if thealternatives ensure an acceptable level ofquality and safety or the requirements presenta hardship without a compensating increase inthe level of quality and safety.

Paragraph (f)(4)(iv) in 10 CFR 50.55aspecifies that inservice tests of pumps andvalves may meet the requirements insubsequent editions and addenda that areincorporated by reference in paragraph50.55a(b), subject to the limitations andmodifications listed in paragraph 50.55a(b),and subject to Commission approval. Portionsof editions or addenda may be used if allrelated requirements of the respective editionsor addenda are met. The Commissionresolved various issues by approving OM-6and OM-10 as discussed herein. Licenseesmay implement the later Code editions, orportions thereof, pursuant to paragraph50.55a(f)(4)(iv) without relief, based on theapproval as stated in Sections 3, 4, and 5 ofthis document, provided the IST programincludes documentation of implementation ofthe later requirements in accordance with thenew guidance herein.

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1.2 Regulatory History

The NRC previously issued guidance forimplementing IST requirements. Afterpublishing the rule which established therequirements for IST (Federal Register noticeof February 27, 1976), NRC sent letters tonotify operating licensees of the new rules. InNovember 1976, after receiving inquiries fromlicensees regarding acceptable methods forcomplying with the regulation, the NRC issuedletters to licensees which transmitted “NRCStaff Guidance for Complying with CertainProvision of 10 CFR 50.55a(g), ‘InserviceInspection Requirements.’”

To eliminate the backlog of IST programreviews for operating nuclear power plants, onAugust 3, 1989, NRC issued Generic Letter(GL) 89-04, "Guidance on DevelopingAcceptable Inservice Testing Programs,"which included 11 technical positions used bythe staff in reviewing IST program reliefrequests and describing alternatives to theCode requirements acceptable to the staff. InGL 89-04, the staff also approved six of thesepositions (1, 2, 6, 7, 9, and 10) pursuant to10 CFR 50.55a (g)(6)(i) with the provisionthat the licensee perform the alternativetesting delineated in the applicable position. The staff approved these alternatives uponrecognizing the impracticality in performingthe required testing and the burden if therequirements were imposed.

GL 89-04 states that licensees are todocument the use of Positions 1, 2, 6, 7, 9, and10 in the IST program, but does not requirethat the documentation must be a reliefrequest. Provided the provisions of GL 89-04are followed, GL 89-04 granted approval tofollow the alternative testing delineated inPositions 1, 2, 6, 7, 9, and 10, pursuant to10 CFR 50.55a(g) [now (f)]. Most licensees

have documented the use of these positions inrelief requests for convenience; however,documentation in the program is acceptable inanother format as long as it is clear that theprovisions of the referenced positions aredocumented and discussed in adequate detailto indicate conformance with such provisions. Certain licensees may have submitted reliefrequests to ensure that the conformance was adequately documented in the program,though documentation in the program wouldalso be acceptable, as stated in GL 89-04. The eleven positions are given in ApppendixA of this document.

The staff held four public meetings to discussGL 89-04 and stated that GL 89-04 was afirst step toward resolving various problems indeveloping and implementing IST programs atnuclear power plants. The staff found theseproblems while reviewing IST programs,inspecting and auditing IST programs at plantsites, participating on the American Society ofMechanical Engineers (ASME) Codecommittees, and meeting with licensees andindustry groups.

The staff summarized the questions andanswers from these meetings in a letter ofOctober 25, 1989, "Minutes of the PublicMeetings on Generic Letter 89-04," October25, 1989. This letter contained informationuseful in applying the guidance in GL 89-04and included discussion of issues of interest tolicensees who attended the public workshops. In a letter of September 16, 1991, the staffissued "Supplement to Minutes of the PublicMeetings on Generic Letter 89-04" to addressa question on stop-check valve testing. Thequestions and answers are consolidated withthe applicable position in Appendix A to thisdocument.

Since issuing GL 89-04, the NRC hasincorporated the 1989 edition of the Code in

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10 CFR 50.55a(b). The 1989 edition of the herein in future safety evaluations and grantCode incorporated OM-6 and OM-10, which relief or authorize the alternative if theinclude rules for IST that were written with licensee has addressed all of the aspectsthe recognition of the maturity of the nuclear included in the applicable section, whereindustry. Certain tests and measurements applicable. required by previous editions of the Codewere eliminated or changed in these standards. The document also discusses OM-6 and OM-

After issuing the generic letter, NRC improved pursuant to 10 CFR 50.55a (f)(4)(iv). ThisIST by revising 10 CFR 50.55a to endorse the document gives the requisite approval forASME Operations and Maintenance Standards 10 CFR 50.55a (f)(4)(iv) for updating an ISTon IST of pumps and valves, separating the program to the requirements of OM-6 andIST and inservice inspection programs in OM-10 (and OM-1 through reference in OM-Paragraph (f) of Section 50.55a, issuing 10). Portions of OM-6 and OM-10 are alsoadditional guidance, and coordinating with approved per (f)(4)(iv), as discussed in theASME for regular symposia on testing pumps following sections. and valves. NRC has also held threesymposia, and will schedule others biennially, 3.1.1 Deferring Valve Testing to Coldwith the fourth planned for July 1996. Shutdown or Refueling Outage

1.3 NRC Recommendations andNew Guidance

The recommendations herein supplement theguidance and positions in GL 89-04. Appendix A is a compilation of the 11positions in GL 89-04, Attachment 1, withquestions and answers from the meetingminutes, and a discussion of the currentapplicability of each position and theapplication of GL 89-04 to OM-6 and OM-10. The document is written for the latest editionincorporated into Paragraph (b) of10 CFR 50.55a. To the extent practical, thedocument reflects the applicable section,subsection, or paragraph of the appropriatedocuments (subsections of Section XI andparagraphs of OM-6, OM-10).

The guidance in many sections herein may beused for requesting relief. However, licenseesmay also request relief that is not inconformance with the guidance. In evaluatingsuch requested relief, the NRC will use therecommendations herein, where applicable. The NRC may reference a recommendation

10, which may be implemented by licensees

3.3.2 Concurrent Intervals (in part)

4.1.4 Extension of Test Interval toRefueling Outage for Check ValvesVerified Closed by Leak Testing

4.2.5 Verification of Remote PositionIndication for Valves by MethodsOther Than Direct Observation

4.2.7 Stroke Time Measurements UsingReference Values

4.3.3 Test Supervisor Qualifications

4.3.4 Frequency and Method of TestingAutomatic Depressurization Valvesin Boiling Water Reactors

4.4.3 Multiple Containment IsolationValve Leak-Rate Testing

4.4.5Leak-Rate Testing Using OM-10Requirements

5.1.2 Continued Measurement ofParameters Deleted from OM-6

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5.3 Allowable Variance from Reference(for fixed resistance systems)

5.4 Monitoring Pump Vibration PerOM-6

5.7 Use of OM-6 Table 3b Ranges forHydraulic Parameters

5.8 Duration of Tests

If a licensee chooses to implement thisguidance for these issues approved under10 CFR 50.55a (f)(4)(iv), deviations from theguidance require a relief request. If a licenseeimplements any or all of theserecommendations, the use of eachrecommendation must be discussed (e.g.,noted, listed, or detailed) in the IST programdocument. If a licensee updates to therequirements of OM-6 for pump inservicetesting and OM-10 for valve testing in theirentirety, it is recommended that the ISTprogram so state in the introductory section,and need not state the use of the sectionslisted above.

1.4 Other Information

Other information on IST can be found in updates the information from GL 89-04 andNRC inspection procedures (IPs) and other sources related to IST programs, andtemporary instructions (TIs) as follows: includes examples of relief requests that have

IP 73756, "Inservice Testing of Pumps andValves," March 16, 1987 Throughout Sections 3, 4, and 5, the staff

TI 2515/110, "Performance of Safety-Related requested relief and gives guidance on theCheck Valves,” November 19, 1991 type of information that would typically (or in

TI 2515/114, "Inspection Requirements for for these issues. It also discusses Code andGeneric Letter 89-04, `Acceptable Inservice regulatory issues and gives recommendations. Testing Programs,'" January 15, 1992 The discussions of issues and

1.5 Synopsis of Report

Section 2 describes existing requirements onIST, discusses the scope of the IST program,and describes guidance for presentinginformation in IST programs, including coldshutdown justifications, refueling outagejustifications, and relief requests. The sectionincludes a sample list of plant systems forboiling-water reactors (BWRs) andpressurized-water reactors (PWRs) thattypically (but not necessarily) contain Codepumps or valves that do a safety function. The section also includes information neededfor licensees to establish the tests and testfrequencies proposed for pumps and valves inan IST program.

Section 3 describes NRC recommendationsand their bases for several general aspects ofIST. Section 4 describes recommendations onvalve issues. Section 5 describesrecommendations on pump issues. Section 6discusses the revised standard technicalspecifications. Section 7 discusses the processfor licensees to follow when a Codenonconformance is found.

In the appendices, the staff consolidates and

been submitted for evaluation and review.

discusses issues for which plants have

some cases must) be included in relief requests

recommendations do not imply additionalrequirements beyond the Code or the

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regulations and do not represent backfits; evaluations related to IST relief requests, NRChowever, some of these discussions address inspection reports, meetings (ASME Codeexisting requirements of the Code or the Committee meetings, meetings with licensees,regulations and are intended to be clarifying. and NRC/ASME symposia), and other generic

Certain terms in this document havegradations of regulatory significance tolicensees. Where the requirements of NRCregulations or the ASME Code, asincorporated into the regulations, arediscussed, the terms shall, must, requires, or section without deviation in order to receiverequirements are used consistently to indicatetheir mandatory nature. The term must is alsoused in another manner in the context ofimplementing guidance (not requirements), asdiscussed below. The word should is used intwo contexts: (1) in reiterating previouslyapproved NRC staff positions or requirementspromulgated by generic letter or otherapproved generic correspondence, and (2) instating staff recommendations for voluntaryimplementation in the "NRCRecommendations" sections. The terms NRCrecommendation, staff recommendation,recommends, acceptable to the staff,acceptable, licensee may, and licenseetypically would are used to discuss issues thathave been evaluated in, and reflect NRC stafffindings from, previous plant-specific safety

correspondence. The term must is used withprovisions of the guidance herein intended forvoluntary implementation by licensees toindicate that, if a licensee chooses toimplement the guidance of a section, thelicensee is to follow such provisions in that

credit for satisfactorily meeting the guidanceof that section.

The new guidance in this document is similarin appearance to NRC staff positions given ina regulatory guide because of the termsdiscussed above, and because certainrecommendations indicate acceptablealternatives to Code requirements. However,this guidance is not equivalent to staffpositions in a regulatory guide or other genericcorrespondence, because this guidance isintended strictly for voluntary implementationby licensees. Licensees may still need to seekapproval for certain of these recommendationsthrough the process described in 10 CFR 50.55a.

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2 DEVELOPING AND IMPLEMENTING ANINSERVICE TESTING PROGRAM

Licensees may use the following guidance for implement the 1989 Edition of the ASMEdeveloping and implementing inservice testing Code, Section XI, in its entirety or for certain(IST) programs. This guidance supplements portions, for IST programs.existing requirements and previously approvedguidance on IST. The regulations specify the upper tier

2.1 Compliance Considerations

Code of Federal Regulations, Title 10, Section50.55a (10 CFR 50.55a), "Codes andStandards," states requirements for IST ofcertain safety-related pumps and valves. These components are to be tested accordingto the requirements of Section XI of theAmerican Society of Mechanical Engineers(ASME) Boiler and Pressure Vessel Code (theCode), Subsections IWP for pumps and IWVfor valves. The testing is intended to assessoperational readiness of components. Thetests conducted during the initial andsuccessive 120-month intervals are to bebased on the requirements in the applicableedition and addenda of the Code, to the extentpractical, within the limitations of design,geometry, and materials of construction, asdescribed in 10 CFR 50.55a(f)(4).

Paragraph 50.55a (f)(4)(ii) requires that IST ineach 120-month interval following the initialinterval be conducted in compliance with therequirements of the latest edition and addendaof the Code incorporated by reference in10 CFR 50.55a(b), in effect 12 months beforethe start of the interval. Pursuant to10 CFR 50.55a(f)(4)(iv), IST may meet therequirements of subsequent editions andaddenda incorporated by paragraph (b) orportions of a revised edition of Section XI. When portions of a revised edition are used,all related requirements of the respectiveeditions or addenda must be met. Thisdocument gives approval for licensees to

requirements for IST. The requirements of theASME Code, as incorporated by referenceinto the regulation, have the force of law. Thetechnical specifications include general andspecific requirements for IST and othersurveillance testing of pumps and valves. Theplant safety analyses include information onthe design limitations and functionalrequirements for the performance of pumpsand valves for a facility. The IST program,including relief requests and data analysismethods, describes the means forimplementing the various requirements for thespecific plant. The implementing proceduresinclude the lowest tier of IST elements. Otherinformation such as bases documents, vendormanuals, trend data, and graphs is often usedby IST engineers in developing, maintaining,and implementing the IST program. The regulations are the authority governingthe implementation of the various ISTrequirements. Therefore, the regulations mustbe met when a licensee finds a conflictbetween the regulations and any of the lowertier requirements (program or procedures). The staff's response to Question 69 (seeAppendix A) gives guidance on cases wherethe licensee modifies its plant in a way thataffects the basis for a relief that has previouslybeen granted. Similarly, if a licensee hasobtained approval of an alternative pursuantto 10 CFR 50.55a (a)(3)(i) or (ii), the licenseeneed not use the alternative if it determinesthat continued compliance with the Coderequirements is warranted or necessary forparticular circumstances that may preclude

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implementation of the alternative method. & Section 50.55a (a)(3)(i) allows the NRCWhen an implementing procedure is revised, to authorize alternatives if "the proposedthe licensee typically ensures that the IST alternatives would provide an acceptableprogram reflects the required testing. level of quality and safety." The NRC

When a system, subsystem, or component is pursuant to this provision only if themodified according to 10 CFR 50.59, or when licensee proposes a method of testing thatan operating or test procedure or valve is an equivalent method, or analignment is changed under Section 50.59, the improvement, to the Code method, or iflicensee typically reviews the IST the testing will comply or is consistentrequirements to determine whether it must with later Code editions approved bychange the program for affected components. NRC in Section 50.55a(b).

Standard Technical Specification 4.0.5 and the & Section 50.55a (a)(3)(ii) allows the NRCcorresponding technical specification for each to authorize an alternative if "complianceplant, state that IST of ASME Code Class 1, 2, [with the Code requirement] would resultand 3 pumps and valves shall be performed in in hardship or unusual difficulty without aaccordance with Section XI of the Code and compensating increase in the level ofapplicable addenda as required by quality and safety." The NRC may10 CFR 50.55a. According to the regulation, approve an alternative pursuant to thisif a revised IST program conflicts with the provision if, although the proposedtechnical specifications for the facility, the alternative testing does not comply withlicensee shall apply to the U.S. Nuclear the Code, the increase in overall qualityRegulatory Commission (NRC) to amend the and safety at the plant would nottechnical specifications to conform with the compensate for the difficulty ofrevised program, or otherwise meet the compliance.requirements of the technical specificationsand 10 CFR 50.55a (see 10 CFR 50.55a & Section 50.55a(f)(6)(i) states:(f)(5)(ii)). This provision in the rule specifiesactions to be taken by a licensee when a The Commission will evaluaterevised inservice inspection (testing) program determinations . . . that Codefor a facility conflicts with the technical requirements are impractical. Thespecifications (see 41 Federal Register 6256, Commission may grant such relief"Statements of Consideration," February 12, and may impose such alternative1976). requirements as it determines is

The NRC may authorize alternatives to Code consideration to the burden upontesting requirements submitted as relief the licensee if the requirementsrequests, or submitted in a similar format that were imposed on the facility. includes a description of the requirements, adescription of the proposed alternative, and The NRC may grant relief pursuant to thisthe justification for approval of the alternative. provision and may impose alternatives if theSection 50.55a includes the following licensee demonstrates that the design orprovisions for accepting alternatives or access limitations make the Code requirementgranting relief: impractical. The burden created by imposing

will normally approve an alternative

authorized by law . . . giving due

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the Code requirements on the licensee is 10, July 1993).considered in the staff's evaluation.

The NRC periodically issues revisions to Testing," which incorrectly references theRegulatory Guide (RG) 1.147, "Inservice 1987 Addendum of OM-6. The correctInspection Code Case Acceptability ASME reference is OMa-1988, Part 6, since noSection XI Division 1," which lists the ASME 1987 Addenda were issued. N-465Code cases suitable for use (see footnote 6 to allows that Part 6 may be used as10 CFR 50.55a). Without obtaining further alternative rules for pump testing in lieuNRC review, the licensee may implement the of Subsection IWP of Section XI.Code cases listed in RG 1.147 for ISTprograms, if the Code cases are used in their N-472, "Use of Digital Readout andentirety, with any supplemental conditions Digital Measurement Devices forspecified in the regulatory guide. The Performing Pump Vibration Testing,"following Code cases are listed in Revision 11 which lists the provision for using digitalof RG 1.147: vibration measuring instruments under

N-415, "Alternative Rules for TestingPressure Relief Devices," which allows N-473, “Alternative Rules for Valveuse of OM-1-1981 as alternative rules to Testing.” The correct reference is OMa-Subsection IWV of Section XI for testing 1988, Part 10, since no 1987 Addendasafety and relief valves. were issued. This code case allows that

N-427, "Code Cases in Inspection Plans," lieu of Subsection IWV of Section XI. which describes how an owner may use a The modification in paragraph (b)(2)(vii)Code Case in an inspection or testing of 10 CFR 50.55a regarding containmentprogram. This case is acceptable if isolation valves continues to apply.paragraph (b)(1) is replaced with thefollowing: "Code Cases that were In the 1988 Addenda and the 1989 Edition ofsuperseded with revised Code Cases and Section XI, Subsections IWP and IWV werehad been approved for use in accordance revised to simply reference Parts 6 and 10 ofwith (a) may continue to be used." the ASME Operation and Maintenance (OM)

N-444, "Preparation of Inspection Plans," Nuclear Power Plants, ASME/ANSIwhich gives guidance for preparing [American National Standards Institute]inspection plans, identifying the contents OM-1987" (1988a addenda of OM-6 and OM-recommended for pump and valve tables. 10), respectively. The OM Standards wereIt also includes justification for rewritten, though no significant technicalsubstututing alternative examinations or changes were made, and were approved bytests. RG 1.147 notes that valve stroke the Board on Nuclear Codes and Standards intimes may be documented outside of the 1990 as the "Code for Operation andIST progam, but that if the stroke times Maintenance of Nuclear Power Plants, ASMEare included and a maximum stroke time OM Code-1990." The OM Code includesis revised, it is not necessary to submit a pump, valve, and snubber IST and snubberrevised IST program to the NRC solely to examination requirements. While OM-6 anddocoument a revision in valve stroke time OM-10 have been incorporated into the(see Footnote 9 of RG 1.147, Revision regulation through the 1989 edition of ASME

N-465, "Alternative Rules for Pump

IWP-4000.

Part 10 may be used for valve testing in

Standard, "Operation and Maintenance of

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Section XI, the NRC has not yet incorporated used to meet this capability would be subjectthe OM Code into 10 CFR 50.55a. The staff to IST.)is considering incorporating the OM Code in aproposed rule expected to be published in the The 1986 Edition (through the Winter 1985Federal Register in 1995. Addenda to the 1983 Edition) of Section XI

An IST program, including implementing valves which give overpressure protection toprocedures, is subject to the requirements of Code class systems or subsystems which10 CFR Part 50, Appendix B, "Quality perform a required function in shutting down aAssurance Criteria for Nuclear Power Plants reactor, in maintaining shutdown conditions,and Fuel Reprocessing Plants." Changes to or in mitigating the consequences of anthe scope, test methods, or acceptance criteria accident. "Accident" refers to the accidentare subject to the requirements of Section analyses in the safety analysis reports and a50.59, "Changes, Tests, and Experiments." broad range of possible adverse events that

The technical specifications for most plants the response to Question Group 104 ofinclude IST requirements more restrictive than Appendix A). Parts 6 and 10 of the 1988the regulations. Section 6 describes how Addendum (OMa-1988) to the ASME/ANSIlicensees may amend their technical OM-1987 Standard, "Operation andspecifications requirements for IST to better Maintenance of Nuclear Power Plants," andaddress the regulations as the governing Subsections ISTB 1.1 and ISTC 1.1 in therequirements. ASME OM Code, also define the scope of the

2.2 Criteria for Selecting Pumps andValves for the IST Program

Subsections IWP-1100 and IWV-1100 ofSection XI, before the 1988 Addenda, definethe scope of the IST program for pumps andvalves with exceptions defined in IWP-1200and IWV-1200. Both Section XI and10 CFR 50.55a(f) state that the IST programincludes certain pumps and valves classified asASME Code Class 1, 2, or 3 and required toperform a specific function in shutting down areactor, maintaining the shutdown condition,or mitigating the consequences of an accident. (NOTE: The length of time assumed formaintaining the safe shutdown conditionwould typically be stated in a plant's safetyanalysis. For example, if the safety analysis isbased on the capability to maintain cold (safe)shutdown for 30 days, the pumps and valveswithin the scope of 10 CFR 50.55a that are

expands the scope of IWV to include certain

could occur at a nuclear power plant (refer to

IST program for certain pumps and valves. However, the scopes of the OM Standards andCode have been expanded to require thatcertain pumps and valves, whether ASMECode Class 1, 2, or 3, or not be included in theIST program. Until the scope of10 CFR 50.55a is changed, the scope of theIST program will continue to include thosecomponents classified by the licensee asASME Code Class 1, 2, or 3, generally asdefined by the plant's safety analysis report.

Members of the OM Committee whoparticipated at the time the scope statementwas developed stated that they did not wish toincrease the scope of OM-6 and OM-10beyond the scope of the 1986 Edition ofSection XI (other than safety and reliefvalves). Originally, the scope statement waswritten to apply to ASME Code Class 1, 2,and 3 components. The scope statements ofOM-6 and OM-10 include Code Class 2 and 3components because many plants were

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licensed before these components were stipulate that the plant was not designed andincluded in the construction code and because licensed for a safe shutdown condition of coldincluding these components is consistent with shutdown. In discussions with ASME Code10 CFR 50.55a. Therefore, it may be committee members, the NRC informed theinappropriate to assume that the scope of OM- committee members that many early plants6 and OM-10 is broader than 10 CFR 50.55a, were licensed to operate with a "safe"even though the scope statement appears shutdown condition of hot standby or hotbroader. Components outside the scope of shutdown, and were not required to achieve10 CFR 50.55a may be included in the scope cold shutdown after a design basis accident. of 10 CFR 50.65, "Requirements for Components and systems necessary to achieveMonitoring the Effectiveness of Maintenance cold shutdown at such a plant may not,at Nuclear Power Plants" (the "Maintenance therefore, be safety-related or subject toRule"). If codes and standards are developed quality assurance requirements. Thesefor components other than ASME Code Class components are not credited to achieve "safe"1, 2, and 3, the NRC would determine if shutdown in plant safety analyses. changes to the regulation would be needed. Recognizing the discrepancy between theAny such changes would be subject to the Code requirements and the licensing basis forprovisions of 10 CFR 50.109, "Backfitting." such plants, the ASME Code committeeHowever, if licensees elect to consolidate recently revised the scope to "safe" shutdowntesting for pumps and valves, designating any rather than "cold" shutdown. Although a reliefnon-Code components as such in the IST request is not required for plants licensed withprogram may be acceptable to meet testing hot shutdown or hot standby as the "safe"requirements for other safety-related pumps shutdown condition, the IST programand valves. document submitted to the NRC must state the

Relief requests for non-Code components may introductory section. be implemented without NRC evaluation andapproval. Although deviations from the Code Refer to Information Notice 91-56, "Potentialfor non-Code components need not be written Radioactive Leakage to Tank Vented toas "relief requests," a notation in the IST Atmosphere," for discussion on potentialprogram would help to identify the deviations leakage pathways that could affect offsiteand indicate that they are related to non-Code dose evaluations. components. If it is not clear that thedeviations relate to non-Code components, it The scope of the IST program is defined inmight be assumed that the requirements of 10 CFR 50.55a, Paragraphs (f)(1), (f)(2), and10 CFR 50.55a are not being met. Some (f)(3). For components that fall within thelicensees use the relief request format to scope defined in these paragraphs, the ISTdocument such deviations, while other program is further narrowed by the scope oflicensees place notes, footnotes, or short the ASME BPVC, Section XI, Subsectionsdescriptions in the program document. IWP and IWV, and, where applicable, OM-6

The current scope defined by the Code scope in IWP/IWV or OM-6/OM-10 in a wayincludes pumps and valves required to achieve that appears to be broader thanand maintain cold shutdown. If the plant was 10 CFR 50.55a, the more narrow scopelicensed for a safe shutdown condition of hot applies. If the FSAR indicates that a systemstandby or hot shutdown rather than cold or component is Code Class 1, 2, or 3, theshutdown, the IST program document will system or component is within the scope of

special condition for the plant in an

and OM-10. If there is a conflict with the

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10 CFR 50.55a. If the FSAR states that a or if it is optional under IWA-1320(b). Thissystem or component is designed, fabricated, requirement was discussed in a letter from W.and maintained as code class at the option of T. Russell, Director of the Office of Nuclearthe Owner as permitted by Paragraph IWA- Reactor Regulation, to R. K. Buckles, NUS1320(e), then the application of the Corporation, September 15, 1994. IWA-requirements in Section XI are also optional. 1320(b) states that optional construction of aIf a licensee has made a commitment to component within a system boundary to ainclude a component in the IST program, the classification higher than the minimum classcomponent is considered within the scope of established in the component designthe program and may be removed only if the specification shall not affect the overallapplicable criteria of 10 CFR 50.55a and system classification by which applicable rules50.59 are met. Also, if the TS require a are determined. IWA-1320(c) states that thecomponent to be tested per the IST program, it rules of IWB, IWC, and IWD may be appliedis considered within the scope. to the higher classification where all

As a result of a design basis document (DBD) isolable portions of the system boundary arereview, many licensees have been reassessing classified to a higher class than required by thetheir IST program scopes and considering group classification criteria,. See ISTA 1.3.2,deleting certain systems from the programs. "Classifications," of the OM Code for similarTo delete entire systems from the IST information on components within the scopeprogram, such as reactor core isolation cooling of the OM Code. If the code classification is(RCIC) or standby liquid control (SLC), a changed pursuant to 10 CFR 50.59, the pumpslicensee would do a review and prepare and valves may remain as augmenteddocumentation under 10 CFR 50.59 (if components (denoted as non-code) in the ISTnecessary). program, as noted in Position 11 of GL 89-04

Plants licensed under the standard review plan determined by the Section 50.59 evaluation). (SRP) may have classified certain systems asCode Class 3 that would not be so classified inearlier plants. The SRP recommends ratherthan requires that these systems be classifiedas Quality Group C (corresponds to CodeClass 3 in RG 1.26). Regulatory Guide 1.26states that it does not cover systems such asinstrument and service air, diesel engine and itgenerators and auxiliary support systems,diesel fuel, emergency and normal ventilation,fuel handling, and radioactive wastemanagement systems, but that these systemsshould be designed, fabricated, erected, andtested to quality standards commensurate withthe safety function to be performed.

The licensee is responsible for determining ifthe classification of Code Class 3 is required

components within the system boundary or

(NOTE: NRC approval may be necessary as

2.3 Code Class Systems ContainingSafety-Related Pumps andValves

The plant safety analysis report (SAR),technical specifications (TS), and otherdocuments list the systems and componentsthat must function to support the safeoperation and shutdown of the plant. Tables2.1 and 2.2 list systems and components thathave been included in the IST programs forpressurized-water reactors (PWRs) andboiling-water reactors (BWRs). These tablesare not intended to apply to all plants, and notall of the systems or components listed in thetables are considered safety-related at every

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plant, nor are all classified as Code Class 1, 2, frequency. The tables could note applicableor 3. For information on quality group and NRC positions or recommendations for eachCode classifications, see RG 1.26 and pump or valve.NUREG-0800, Section 3.2.2. The licensee'ssafety analysis generally contains a section It is intended that the IST Program reflectdescribing the Code classification of design modifications and other activitiescomponents. The IST program scope must be performed under 10 CFR 50.59 that relate toconsistent with the safety analysis. pumps and valves within the scope of the IST

2.4 IST Program Document

Section 2.4.1 applies to pumps, and Section2.4.2 applies to valves. These sectionsdescribe the information generally needed toprepare and document the IST program. Section XI of the Code includes the rules forinservice inspection (ISI) and IST of nuclearpower plant components. Subsection IWAincludes general requirements for the inserviceinspection and testing of components. ArticleIWA-6000 of Subsection IWA addressesrecords and reports required for theseinspection programs. IWA-6210(a) states thatthe owner shall prepare plans and schedulesfor inservice examinations and tests to meetthe requirements of Section XI. IWA-6220(a)states that examination, test, replacement, andrepair records shall be prepared in accordancewith the requirements of respective articles ofSection XI. However, Articles IWP-6000 andIWV-6000 include minimal guidance for theinformation that could be included in the ISTprogram for pumps and valves that perform asafety function. Appendix F of Section XI,which was introduced in the 1987 Addenda,gives voluntary guidance for the preparationof inspection and testing plans (also seeASME Section XI Code Case N-444 listed inSection 2.1 above).

Licensees have found that pump and valvetables are a convenient format for theinformation. The tables typically includeenough information to allow NRC inspectorsto determine if the testing complies with theCode requirements for test method and

program. It is recommended that the programplan submitted to the NRC includedocumentation of the use of positionscontained herein, GL 89-04 positions, andCode Cases.

2.4.1 Pumps

In preparing pump tables, it is recommendedthat the licensee consider the followinginformation, which includes headings and adescription of the text that could be includedunder each heading, as depicted in theexample in Table 2.3.

Title: List the applicable plant and unit.

Page number: Include the page number andtotal number of pages in the program orprogram section.

Program revision or revision date: List theprogram or page revision number and date oneach page. List the revision number for eachprogram change submitted.

System and Code Class: List the plant systemand code class and briefly describe the serviceof the pump.

Pump identification: List a unique identifierfor each pump to be used consistently in alldocumentation for the IST program and designinformation such as system piping andinstrument diagrams (P&IDs), test procedures,and relief requests.

Piping and instrument diagram number: Listthe P&ID or figure showing the pump in the

NUREG-1482 ���

system. requests in the pump table.

Drawing coordinates: List the coordinates of 2.4.2 Valvesthe pump on the piping and instrumentdiagrams.

Test parameters: List each of the seveninservice test quantities in Section XI, TableIWP-3100-1, or the five parameters in Table 2of OM Part 6, for each pump. A column or afootnote is typically used to list factorsaffecting testing. List a relief request numberwhere the testing cannot be performed asrequired.

Examples of notes often used with pumptesting tables are as follows:

(a) The pump is directly coupled to aconstant speed synchronous orinduction-type driver, and measurementof rotative speed is exempted accordingto IWP-4400.

(b) The pump bearings are located in themain flow path of the working fluid, andmeasurement of bearing temperature isexempted according to IWP-4300 (notrequired by OM Part 6).

(c) Pump bearings are of the permanentlysealed and lubricated design; therefore,this pump is exempt from the requirementto observe lubricant level or pressure (notrequired by OM Part 6).

The previous notes can be used where Codetesting would otherwise be required. A reliefrequest is not required in these cases becausethe test requirement is exempted by the Codeor because the pump design makes the pumpbearing lubricant level or pressure a parameterwhich cannot be observed.

Relief request(s): List any applicable relief

In preparing valve tables, it is recommendedthat the licensee consider the followinginformation, which includes headings and adescription of the test that could be includedunder each heading.

Title: List the applicable plant and unit.

Page number: Include the page number andtotal number of pages in the program orprogram section.

Program revision or page revision date: Listthe program or page revision number and dateon each page. List the revision number foreach program change submitted.

System and Code Class: List the plant systemand code class and briefly describe the serviceof the valve.

Valve identification: List a unique identifierfor each valve in a consistent manner in allIST and design documents, including systemP&IDs, test procedures, and relief requests. Ifvalves such as excess flow check valves aregrouped together on the valve table, thenumber of valves and the valve number mustbe clearly indicated.

Piping and instrument diagram number: Listthe P&ID or figure showing the valve in thesystem.

Drawing coordinates: Specify the location ofthe valve on the piping and instrumentdiagrams.

Valve type: List the valve type (i.e., gate,globe, check, relief).

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Valve size: Specify the valve size in inches, be exercised to the position(s) required tofractions of an inch, or in metric units. fulfill their safety function(s).

Actuator type: List the type of valve actuator Tests performed: Specify which tests are to be(i.e., motor, solenoid, pneumatic, hydraulic, performed on each valve, including theself) with the type and function of the valves. different frequencies that may result for valves that have safety functions in both theCode category: Specify the Code category (or open and closed positions. categories), as defined in IWV-2100 andparagraph 1.4 of OM-10. This determines the Test frequency: If performing the test at theapplicable subsections of the Code. For frequency specified in the Code is impracticalexample, a motor-operated gate valve could or burdensome, reference cold shutdown orbe in Code category A or B. A self-actuated refueling outage justifications (OM-10), orcheck valve could be in category C or A/C. relief requests for test frequency. List the

Active/Passive: State whether a valve isactive or passive as defined in Section XI Relief requests and cold shutdown/refueling(paragraph IWV-2100 before 1986 edition and outage justifications: List any applicable reliefparagraph IWA-9000 1986 edition and later), request(s) in the valve table. When the testingor OM-10, paragraph 1.3. Requirements vary is deferred to cold shutdowns or refuelingbased on the function of the valve. A valve outages (OM-10), reference the technicalneet not be considered active if it is only justification (cold shutdown justification ortemporarily removed from service or from its refueling outage justification) for the testsafety position for a short period of time, such frequency.as manually opening a sample valve to take asample while maintaining administrative Remarks: Include pertinent information notcontrol over the valve. If the plant is in an stated elsewhere in the table such as notes or aoperating mode that does not require a passive brief functional description of the valve. Listvalve to be maintained in its "passive" (safety) any applicable GL 89-04 positions and noteposition, the position of the valve may be any special conditions. changed without imposing IST requirementson the valve. If a valve is routinely Figures in Appendix B depict excerpts fromrepositioned during power operations (or has valve tables for IST programs that have beenan active safety function), it is an active valve. submitted to NRC. Table 2.4 lists commonIf a valve is repositioned to create a new valve abbreviations used in tables.alignment (e.g., as corrective action for acondition of another valve in the line), an 2.4.3 Piping and Instrument Diagrams evaluation, considering the impact on the ISTprogram, may be required to assureoperational readiness prior to positioning it ina new position, as determined on a case-by-case basis. Safety position: List the safety functionposition(s), specifying both positions forvalves that perform a safety function in eachof the open and closed positions. Valves must

actual test frequency.

The staff recommends that piping andinstrument diagrams (P&IDs) or systemdrawings be included in the program submittalto assist in finding the pumps and valvesincluded in the program, and that the drawingsbe the latest revision at the time the program issubmitted to NRC. This information will assistthe staff in reviewing relief requests orproposed alternatives. Inservice inspection

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boundary system drawings and isometrics, or boundaries for a Code class, the basis forreduced size drawings are suitable to be including the pump or valve in the ISTincluded in the program document. If the program or excluding it there from, and thereduced drawings are not complete P&IDs, basis for the testing applied to eachthe staff may request a set of full-size component. Appendix E contains examplesdrawings for evaluating relief requests. A from actual bases documents. partial submittal of the program containingrelief requests could include applicable Although not required by the NRC, the basesdrawings to support the relief requests or to document will help the licensee ensuresupersede previous IST program drawings. continuity of the IST program when theProgram drawings need not be updated responsibilities of personnel or groups change. regularly, but if drawings change because of A bases document will also enable the plantmodifications, or if relief requests are staff to clearly understand the reasons that theaffected, the staff recommends drawings be components are either in the program or not inrevised and submitted to NRC in the next the program. This document, though not aperiodic submittal of revisions to the program "Licensing Basis Document," is a usefuldocument. The staff also recommends reference for reviews performed underlicensees include applicable drawings with 10 CFR 50.59 when changes are made to arelief requests that are very detailed and are facility. submitted to supplement the IST program. These drawings are needed because neither 2.4.5 Deferring Valve Testing to Coldthe technical staff at the NRC nor thecontractors who perform reviews of reliefrequest maintain a set of SAR's for each plant. The IST reviewers do not receive a copy ofthe inservice inspection program plan whichgenerally contains drawings. Drawings arehelpful in reviewing relief requests, whethersubmitted as part of the program or as anattachment applicable to any relief requests orproposed alternatives.

2.4.4 Bases Document

The staff recommends that each licenseecreate a bases document for the IST program. A paper discussing the creation andmanagement of a bases document is includedin NUREG/CP-0123, Supplement 1,"Proceedings of the Second NRC/ASMESymposium on Pump and Valve Testing." Bases documents typically have included adescription of the methodology used forpreparing the IST program, with a list of eachpump and valve in a system within the

Shutdown or Refueling Outages

Exercising valves on a cold shutdownfrequency is not a deviation from the Code. The Code allows for testing during coldshutdown outages if it is impractical to testquarterly during operation. OM-10 allows fora refueling outage frequency if it is impracticalto conduct testing quarterly while in operationand during cold shutdown. The licensee mustlist these valves in the program and includecold shutdown justifications or refuelingoutage justifications for each valve or group ofvalves affected. It is recommended that thesecold shutdown and refueling outagejustifications be included in the IST programsubmitted to the NRC.

Impractical conditions justifying test deferralsare those that could result in an unnecessaryplant shutdown, cause unnecessary challengesto safety systems, place undue stress oncomponents, cause unnecessary cycling ofequipment, or unnecessarily reduce the life

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expectancy of the plant systems and would result if the requirements werecomponents. Examples of impractical imposed.conditions are (1) limitations of design,geometry, and materials of construction of 2.5.1 Justifications for Reliefcomponents (e.g., no test taps, pumps cannotovercome pressure, no available flow path), (2) radiation exposure and personnel safety incertain plant modes (see Section 2.5.1 belowfor discussion on ALARA), (3) testing thatcould cause a plant trip or require a powerreduction. This issue is discussed further inSections 3 and 4, which give guidance ondeferring testing.

2.5 Relief Requests and ProposedAlternatives

A licensee may submit a request for NRC toreview and approve relief from requirementsof the Code, or for authorization to useproposed alternatives. The staff recommendsthat the basis for relief address whether (1) theproposed alternative gives an acceptable levelof quality and safety, (2) compliance wouldresult in a hardship without a compensatingincrease in safety, or (3) complying with Coderequirements is impractical. The justificationmust include adequate information for thestaff to determine if the alternative can beauthorized or relief can be granted (e.g., asapplicable, damage to equipment, hazards topersonnel, and the possibility of a plant trip inthe details of the proposed alternative). Thelicensee may implement the proposedalternative testing while the NRC is reviewingthe relief request if the request is for relieffrom those requirements that have beendetermined to be clearly impractical (seeSection 6).

The staff performs a detailed review of eachrelief request, authorizes an alternative to therequirements or grants relief from therequirements, and may impose alternativerequirements. When granting relief, the NRCconsiders the burden on the licensee that

The NRC considers the merits of thesubmitted technical information when itdetermines to grant or deny relief from theCode requirements or to authorizealternatives. In requesting relief, the licenseewould typically describe the specific Coderequirement and associated paragraph forwhich relief is requested, describe theproposed alternative(s), describe the basis forrelief or for the alternative, and clarify theburden that would result if the requirementswere imposed. The following are examples ofsituations that warrant granting relief orauthorizing alternatives as determined by thestaff in previous safety evaluations for plant-specific requests:

� In complying with the Code requirements,the licensee would not obtain informationmore useful than the informationcurrently available. For example,installing an analog gauge with a range ofthree times the reference value (or less)to comply with Code requirements maynot yield more accurate reading than theaccuracy of the one presently installed(see Section 5.5.1).

� Compliance with the Code is impracticalbecause of design limitations. Impositionof the Code requirements would requiresignificant system redesign andmodifications. For example, a flow meterdoes not meet the accuracy requirementsof IWP-4110 because the present systemconfiguration does not have a straightsection of pipe of sufficient length inwhich to measure flow accurately (seeSections 5.5.1 and 5.5.2).

� The required measurements orappropriate observations cannot be made

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because of physical constraints. � Failure of a component during testingExamples include a component located in could disable multiple trains of a reactoran area inaccessible during power safety system. For example, a motor-operation or a pump totally immersed in operated suction valve common to bothsystem fluid. trains of high-pressure safety injection

� The need to keep personnel radiation operation because a failure of the valveexposure as low as reasonably achievable results in both trains being out of service(ALARA) may present an adequate (see Section 3.1.2). justification. The licensee includedinformation about the general area Inconvenience or administrative burden areradiation field, local hot spots, plant not, alone, adequate justification for deviatingradiation limits and stay times, the from the Code requirements. Entering a TSamount of exposure personnel would limiting condition of operation (LCO), exceptreceive in doing the testing, and the when entering the LCO would be prohibitedsafety significance of deferring testing or because the total system function would beperforming an alternative method. out of service, is also not, alone, adequateALARA relates to controlling exposure justification for deviating from the Code-during an activity, not specifically to specified frequency (see Section 3.1.2).eliminating activities; however, it may bea basis for relief or for deferring an 2.5.2 Categories of Relief Requestsimpractical test when exposure limits toperform testing (or possibly to access avalve for repair in the event it could failduring a test) are prohibitive. If theexposure limits are prohibitive, defertesting to cold shutdowns or refuelingoutages when the exposure limits are nolonger prohibitive. ALARA is part of anoverall program as required by10 CFR 20.1101, including activities suchas IST. NRC has not extablished ALARA "predetermined acceptablelimits" for deferring an IST activity. ASME Section XI Code Case N-444gives guidance on documenting ALARAas justification for alternativeexaminations and tests.

� Testing as required by the Code couldcause significant equipment damage. Forexample, shutting off cooling flow to anoperating pump by exercising a valve inthe cooling flow path could damage thepump.

could not be tested during power

General: A general relief request isappropriate when the relief being requestedapplies to a broad range of similar componentsin the program, such as all pumps or allcontainment isolation valves.

Specific: A relief request is specific when therelief being requested applies only to a singlecomponent or a specified group of similarcomponents in the program, such as servicewater pump discharge check valves.

2.5.3 Content and Format of ReliefRequests

The staff recommends that each relief requestinclude the following information in the orderstated, as a minimum. Appendix C includesexamples of relief requests that have beensubmitted by licensees.

Title and relief request number: Entitle eachrelief request and specify a unique identifier.

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The identifier remains unique to avoid frequency in the "basis." The relief requestconfusion when later revisions are made. should contain all information needed forExamples follow: (1) Relief Request Number NRC review. Most relief requests for check1, (2) Safety Injection Pumps Relief Request, valves list the test direction(s) for which the(3) Check Valves in Series Relief Request. relief is required.

Page number: List the page number and total Proposed alternate testing: Clearly andnumber of pages in the program or program thoroughly present the proposed alternative. section, such as "Page 15 of 135."

Program revision or page revision date: List introductory statements for this section of thethe program revision number or page revision relief request:date on each page.

System and Code class: List the plant system quarterly by way of the minimum flowand Code class of the system in which the line for the pump. They will also be full-component is located. stroke exercised with flow into the

Valve category: List the ASME category for outages.each valve (i.e., A, A/C, B, C, or D).

Component identification: List the during cold shutdown outages using theidentification number for each component in a power operator on the test arm. They willspecific relief request. Each individual also be full-stroke exercised duringcomponent need not be listed in a general refueling outages by means of the fullrelief request, such as one for all pumps in the accident-required flow injected into theIST program. However, it is recommended reactor coolant system.that the list of program components (pump orvalve table) include the relief request number.� These valves will be part-stroke exercised

Component function: Briefly describe the residual heat removal system. Their full-functions of the components and specify the stroke capability will be verified duringfunction which is the subject of the relief refueling outages. They will berequest. disassembled, the internal components

ASME Code test requirement(s): List and stroked. The guidance in Generic Letterdescribe the Code requirement(s) from which (GL) 89-04, Position 2, will be followedrelief is being requested. for the disassembly and inspection

Basis for relief: Discuss the basis for following reassembly.requesting relief or proposing the use of analternative including the reasons for which Discuss the proposed alternate in sufficientcompliance with the Code requirements is detail to clearly illustrate that it is a reasonableimpractical or the proposed alternative is a alternative to the Code requirement. preferred test. Include justification for eachtest frequency deferred (i.e., quarterly, cold Drawings and/or diagrams: If the reliefshutdown). State and justify the proposed request or alternative testing is complex, or if

The following are acceptable examples of

� These valves will be part-stroke exercised

reactor coolant system during refueling

� These valves will be part-stroke exercised

during cold shutdowns with flow from the

examined, and the valve disk manually

program, including a partial-flow test

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drawings or diagrams are available for further documents (e.g., applicable position of GL 89-clarification, they could be included in the 04). A document referenced in the reliefrelief request or could be referenced and request must be submitted to the NRC on theincluded in the IST program document. plant docket. If a document is not docketed

References: List references to SAR sections, request must include the information rathertechnical specifications, and other pertinent than merely referencing the document.

but contains pertinent information, the relief

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Table 2.1 Typical systems and components in an inservice testing program for a pressurized-water reactor

Typical safety-related, Code class Typical components in an inservice testing programsystems in pressurized-water reactors

Reactor coolant system and flowpaths for Power-operated relief valves and associated block valvesestablishing natural circulation

Reactor high point and head vents

Primary system safety and relief valves (pressurizer Code safety valves)

Valves in any proposed flow path used for long-term corecooling or safe shutdown

Pressure boundary isolation valves

Valves in lines to pressurizer relief/quench tank

Main steam system Main steam isolation valves (MSIVs) Main steam non-return valves (if applicable)Secondary system safety and relief valvesAtmospheric dump valvesAuxiliary feedwater turbine steam supply valvesSteam generator blowdown isolation valves

High-pressure safety injection system High-pressure injection pumps and discharge check valves

Injection valves in injection flowpath

Isolation valves

Valves for the refueling water storage tank (RWST) borated water storage tank (BWST), refueling water tank (RWT), including vacuum breakers

Chemical and volume control or makeup Charging or makeup pumps and suction/discharge check valvessystem

Valves in charging/makeup flowpath

Boric acid transfer pumps and suction/discharge check valves

Valves in emergency boration flow paths

Relief valves

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Table 2.1 Typical systems and components in an inservice testing program for a pressurized-water reactor (continued)

Typical safety-related, Code class Typical components in an inservice testing programsystems in pressurized-water reactors

Low-pressure safety injection system Injection pumps and suction/discharge check valves

Valves associated with safety injection accumulators and coreflood tanks

Recirculation flowpath valves, including containment sump isolation valves

Isolation valves (high-low pressure interface)

Relief valves

Shutdown cooling, residual heat removal, or Pumps and suction/discharge check valvesdecay heat removal systems Valves in flowpath

Isolation valves (high-low pressure interface)Relief valves

Containment spray system Containment spray pumps and suction/discharge check valves

Valves in flowpaths to spray header

Isolation valves

Valves in spray additive flowpath

Spray additive tank valves, including vacuum breakers

Main feedwater system Main feedwater isolation valves

Auxiliary feedwater system Auxiliary feedwater pumps and suction/discharge check valves

Valves in flowpath to steam generators

Valves in suction lines

Valves between normal and ultimate heat sink suction sources

Relief valves and isolation valves

Primary containment system Containment isolation valves (various systems)

Containment combustible gas venting valves

Containment atmosphere sampling valves (if within the scope of10 CFR 50.55a)

Table 2.1 Typical systems and components in an inservice testing program for a pressurized-water reactor (continued)

Typical safety-related, Code class Typical components in an inservice testing programsystems in pressurized-water reactors

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Component cooling water system Component cooling water pumps and discharge check valves

Valves in letdown cooling water flowpath

Valves in reactor coolant pump seal injection and cooling water flowpath

Relief valves

Spent fuel pool/pit cooling system Spent fuel cooling pumps and suction/discharge check valvesValves in flowpath from ultimate heat sink source supply

Service water system Service water pumps and suction/discharge check valves

Valves in flowpath to auxiliary feedwater system

Valves in flowpaths to emergency room coolers

Valves in flowpaths to containment emergency coolers

Valves in flowpaths to emergency diesel generator heat exchangers

Isolation and cross-tie valves

Valves in ultimate heat sink source flowpaths

Valves in standby or backup service water, if applicable

Emergency diesel generator system (within Fuel oil storage and transfer pumps and valvesscope of 10 CFR 50.55a) Diesel generator external cooling (service water)

Engine air start check valvesAir receiver relief valves

Ventilation systems Pumps and valves in control room emergency cooling water supply flowpath

Instrument air system (if within the scope of Air supply to containment purge valves10 CFR 50.55a) Air supply to power-operated relief valves (PORVs)

Air supply to MSIVs

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Table 2.2 Typical systems and components in an inservice testing program for a boiling-waterreactor

Typical safety-related, Code class Typical components in an inservice testing programsystems in boiling-water reactors

Nuclear boiler and reactor recirculation Primary system isolation valvessystem Excess flow check valves

Main steam system MSIVs and actuator valves (pilot valves, accumulator checkvalves)

Main steam safety and relief valves

Main steam safety valve discharge rupture diaphragm valve

MSIV leakage valves

High-pressure core coolant injection (HPCI) Pump and suction/discharge check valvesystem

Valves in injection flowpath

Isolation valves, including valves in test lines

Excess flow check valves

HPCI pump turbine valves, including turbine exhaustvacuum breakers (unless considered skid-mounted)

High-pressure core spray system Pumps and suction/discharge check valvesValves in injection flowpathIsolation valves, including valves in test lines

Reactor core isolation cooling (RCIC) system Pump and suction/discharge check valve(if safety-related) RCIC pump turbine valves

Excess flow check valvesIsolation valves

Reactor water cleanup system Containment isolation valves

Residual heat removal (RHR) system RHR pumps and suction/discharge check valves Isolation and cross-tie valvesPump suction relief valvesRHR heat exchanger thermal relief valvesValves in injection flowpathFlow control valves

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Table 2.2 Typical systems and components in an inservice testing program for a boiling-waterreactor (continued)

Typical safety-related, Code class Typical components in an inservice testing programsystems in boiling-water reactors

Spent fuel pool cooling system Fuel pool pumps and suction/discharge check valves Ultimate heat sink supply valve

Feedwater coolant injection and isolation Reactor feedwater pumps and suction/discharge check valvescondenser system (if applicable)

Condensate pumps and suction/discharge check valves

Condensate booster pumps and suction/discharge check valves

Emergency condensate transfer pump and suction/dischargecheck and isolation valve

Isolation and bypass valves

Vent valves

Makeup to condenser shell check valves

Standby liquid control (SBLC) system SBLC pumps and suction/discharge check valvesRelief valvesInjection line valvesExplosively-actuated squib valves

Main feedwater system Isolation valves

Primary containment system Containment isolation valves including excess flow check valves (various systems)

Containment atmosphere monitoring system valves

Containment atmosphere dilution system valves

Containment pressure suppression and vents

Closed cooling or component cooling water Pumps and suction/discharge check valvessystem Valves in flowpaths to safety-related coolers

Service water system Pumps and suction/discharge check valvesIsolation and cross-tie valvesValves in flowpaths to safety-related coolersValves in flowpaths to diesel generator coolersValves in standby or backup service waterValves in flowpath from ultimate heat sink sourceValves in residual heat removal service water flowpath

Control rod drive system (portions within the Scram dump valvesscope of 10 CFR 50.55a) Scram discharge volume vent valves

Scram discharge volume drain valvesAccumulator rupture disksHydraulic control unit control valvesDrive water backflow prevention valves

Table 2.2 Typical systems and components in an inservice testing program for a boiling-waterreactor (continued)

Typical safety-related, Code class Typical components in an inservice testing programsystems in boiling-water reactors

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Emergency diesel generator systems (if within Fuel oil storage and transfer pumps and valvesthe scope of 10 CFR 50.55a) Diesel generator external cooling (service water)

Engine air start check valvesAir receiver relief valves

Ventilation systems Pumps and valves in control room emergency cooling water supply flowpath

Instrument air system (if within the scope of MSIV accumulator check valves10 CFR 50.55a)

MSIV pilot valves

Automatic depressurization system (ADS) valve accumulatorcheck valves

ADS pilot valves

Traversing incore probe system (if within the Containment isolation valvesscope of 10 CFR 50.55a)

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Table 2.3 Example data table for pumps

PLANT NAME/UNIT

PUMP TESTING PLAN

Revision: 3Date: 1-15-92Page: 1 of 3

Pump List Parameters

SYSTEM PUMP I.D. P&ID NO. COORD. S P dP (PR-1) T L Flow V

i b

Residual Heat RHR-01 M-402 Sh. 1 D-4 (1) Q Q Q Q Y QRemoval RHR-02 M-402 Sh. 2 G-4 (1) Q Q Q Q Y Q

RHR-03 M-402 Sh. 2 F-5 (1) Q Q Q Q Y Q

Auxiliary AFW-01 M-408 Sh. 1 B-5 (1) Q Q Q Q PR-4 QFeedwater AFW-02 M-408 Sh. 1 B-8 (1) Q Q Q Q PR-4 Q

AFW-03 M-408 Sh. 1 B-11 Q Q Q Q Q PR-4 Q

Service Water SWS-01 M-335 Sh. 1 F-9 (1) PR-7 Q PR-3 PR-2 (2) (4)SWS-02 M-335 Sh. 2 D-4 (1) PR-7 Q PR-3 PR-2 (2) (4)SWS-03 M-335 Sh. 3 E-8 (1) PR-7 Q PR-3 PR-2 (2) (4)SWS-04 M-335 Sh. 4 C-4 (1) PR-7 Q PR-3 PR-2 (2) (4)

Standby Liquid SLC-01 M-367 Sh. 1 D-9 (1) PR-7 PR-5 PR-6 Q PR-4 (3)Control SLC-02 M-367 Sh. 1 D-4 (1) PR-7 PR-5 PR-6 Q PR-4 (3)

Note (1): Pump is directly coupled to a constant speed synchronous or induction type driver.

Note (2): Pump bearings are located in the main flow path of the working fluid.

Note (3): Pump bearings are of the permanently sealed and lubricated design.

Note (4): The pump bearings are located in the main flow path of the working fluid and are cooled and lubricated by the process fluid.

Legend:

S Speed T Temperature, bearingsb

P Pressure, inlet L Lubricationi

dP Differential Pressure PR Pump Relief RequestQ Quarterly V Vibration

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Table 2.4 Useful abbreviations for valve data tables

Parameter Abbrevation Description

Valve Type GT Gate valveGB Globe valveCK Check valveRV Relief valveSC Stop checkBF Butterfly valveDI Diaphragm valveEX Explosive valveBA Ball valve

Actuator Type MO Motor operatedSO Solenoid operatedAO Air operatedHO Hydraulic operatedSA Self actuatedMA ManualPA Pilot Actuated

Safety Position(s) O OpenC Closed

O/C Both open and closedT Throttled

Test(s) Performed FS Full-stroke exercise valve to safety position(s)PS Part-stroke exercise valveLT Leak-rate test valve to Section XI requirementsLJ Leak-rate test valve to Appendix J requirementsST Measure the full-stroke times of the valveFT Observe the fail-safe operation of the valvePI Verify the valve remote position indication RV Safety and relief valve testEX Explosive valve test

Test Frequency Q Test performed once every 92 days

CS Test performed during cold shutdowns but not

RF Test performed each reactor refueling outage

2Y Test performed once every two years

RV Test relief valve at IWV or OM-1 schedule

SD Disassemble, inspect, and manually exercise one

more frequently than once every 92 days

valve from specified group each reactor refuelingoutage

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3 GENERAL SUPPLEMENTAL GUIDANCE ONINSERVICE TESTING

3.1 Inservice Test Frequencies andExtensions for Valve Testing

The American Society of MechanicalEngineers (ASME) Boiler and Pressure VesselCode (the Code) generally requires quarterlytesting of pumps and valves. Subsection IWVof Section XI of the Code allows for deferringvalve exercising to cold shutdown outages ifexercising is not practical during plantoperation. Part 10 of the ASME Operationsand Maintenance Standard (OM-10) hasadditional allowances discussed below. TheU.S. Nuclear Regulatory Commission (NRC)staff may approve relief for extending a testinterval for extenuating circumstances inwhich (1) compliance would result in hardshipor unusual difficult without a compensatingincrease in the level of quality and safety or(2) the system design makes complianceimpractical. Any requested relief wouldtypically include a technical justification forthe deferment. Table 3.1 lists the tests andtest frequencies required by the Code.

3.1.1 Deferring Valve Testing to EachCold Shutdown or Refueling Outage

Exercising valves at each cold shutdownoutage is not a deviation from the Code anddoes not require a relief request. Testing ateach refueling outage is a deviation fromrequirements in Subsection IWV of SectionXI, but is an allowable deferral of the testingrequired by OM-10. The Code specifiestesting at cold shutdowns if it is impractical totest quarterly during operation. OM-10specifies full-stroke exercising at eachrefueling outage if testing is impractical bothquarterly while in operation and during coldshutdown outages. The Code (IWV-3412,

IWV-3522, and OM-10, paragraph 6.2)requires the valves for which testing isdeferred be identified and the basis fordetermining impracticality be documented inthe inservice testing (IST) program. Thelicensee may implement the portions of OM-10 which allow deferral of the testing inaccordance with 10 CFR 50.55a(f)(4)(iv) ifthe following related requirements are met:

Category A and B Valves: OM-10,Paragraph 4.2.1, including a partial-stroke exercise quarterly or duringcold shutdown outages, if practical.

Category C Valves: OM-10,Paragraph 4.3.2, including a partial-stroke exercise quarterly or duringcold shutdown outages, if practical.

Test Plans: OM-10, Paragraph 6.2, fordocumenting the basis of the deferral.

Therefore, although relief is not required, thissection must be referenced in the ISTprogram. Examples 3-1 and 3-2 depictacceptable cold shutdown justifications(CSJs). Examples 3-3 and 3-4 depict refuelingoutage justifications acceptable in accord withOM-10.

NRC issued guidance in letters to licensees in1976 which included examples of valves to bespecifically excluded from exercising (cycling)tests during plant operations. This guidancemay not apply in all cases (e.g., HPCI turbinesteam supply and pump discharge valves maybe tested quarterly during pump testing). Examples of the excluded valves follow:

(1) All valves whose failure in a non-conservative position during the cycling

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test would cause a loss of system service, the possible safety consequences offunction. Valves in this category would performing the test have been weighed againsttypically include all non-redundant valves the benefits of testing. The guidance hereinin lines such as a single discharge line and in the 1976 letters does not supersedefrom the refueling water storage tank or technical specification requirements.accumulator discharge lines inpressurized-water reactors (PWRs) and Check valves that can be stroked quarterly,the high-pressure coolant injection but must be monitored by a nonintrusive(HPCI) turbine steam supply and the technique to verify full stroke, may be full-HPCI pump discharge in boiling-water stroke tested during cold shutdowns orreactors (BWRs). Other valves may fall refueling outages if another method ofinto this category under certain system verifying full-stroke exists at these plantconfigurations or plant operating modes. conditions. However, the quarterly partial-For example, when one train of a stroke testing would continue to be required. redundant system such as an emergency Also, the NRC would not require a licensee tocore cooling system (ECCS) is invest in nonintrusive equipment for theinoperable, non-redundant valves in the purpose of testing check valves quarterly inremaining train should not be cycled since lieu of testing during cold shutdowns ortheir failure would cause a loss of total refueling outages, though the use ofsystem function. nonintrusive techniques is recommended

(2) All valves whose failure to close during acycling test would result in a loss of When considering deferring valve testing tocontainment integrity. Valves in this cold shutdowns or refueling outages, somecategory would typically include all valves could be tested quarterly, but thevalves in containment penetrations where testing involves a hardship; i.e., a limitingthe redundant valve is open and condition for operation of 3 to 4 hours ininoperable. length, the repositioning of a breaker from

(3) All valves, which when cycled, could operator actions to restore the system if ansubject a system to pressures in excess of accident occurred while the test is in progress. their design pressures. It is assumed for The risk of performing a test quarterly forthe purpose of a cycling test that one or such situations may outweigh the benefitmore of the upstream check valves has achieved with a quarterly test. Section 3.1.2failed unless positive methods are gives guidance on these situations. Otherwise,available for determining the pressure or it would be appropriate to weigh the safetylack thereof on the high-pressure side of impact against the benefits of testing as a basisthe valve to be cycled. Valves in this for deferring testing from quarterly to coldcategory would typically include the shutdowns or refueling outages. A method isisolation valves of the residual heat described in NUREG/CR-5775, "Quantitativeremoval/shutdown cooling system and, in Evaluation of Surveillance Test Intervalssome case, certain ECCS valves. Including Test-Caused Risks."

If a technical specification surveillance The following sections discuss issues related torequires a test, even when one train is out of valve testing deferrals. These sections do not

where practical.

"off" to "on," and necessity of manual

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apply to testing required after maintenance or required to maintain the IST schedule.repair. Although OM-10 does not include schedules

3.1.1.1 IST Cold Shutdown Testing method is for the valves tested in the

Subsection IWV does not include provisionsfor plant startup from cold shutdown when allIST of valves tested at a cold shutdownfrequency has not been completed. However,OM-10 allows that plant startup need not bedelayed to complete IST. Valves tested on acold shutdown frequency may be tested ateach cold shutdown (e.g., based on a licenseecommitment) or may be tested sequentiallyduring cold shutdown outages. Valves testedwithin 92 days before changing modes fromcold shutdown need not be tested. Valvestested at a cold shutdown frequency mayinclude valves tested while decreasing powerto cold shutdown or while increasing power tosteady state power operation.

NRC Recommendation

In accordance with OM-10, paragraphs4.2.1.2(g) and 4.3.2.2(g), valve exercisingshall commence within 48 hours of achievingcold shutdown, and continue until all testing iscomplete or the plant is ready to return topower. For extended outages, testing need notbegin in 48 hours provided all valves requiredto be tested during cold shutdown will beretested before plant startup. However, thelicensee need not keep the plant in coldshutdown solely to complete cold shutdowntesting. All valves tested during coldshutdown outages shall also be tested beforestartup from refueling outages, unless testinghas been completed within the previous 92days. If an outage lasts beyond 92 days, allcold shutdown testing shall be completedwithin the last 92 days of the shutdown. Alicensee should make a "good faith"reasonable effort to test valves during a coldshutdown; however, the Code does not requiredocumentation for valves not tested during acold shutdown outage other than as would be

for cold shutdown testing, an acceptable

preceding cold shutdown to be the last valveson the schedule for the next cold shutdown,except for valves tested each cold shutdown. The following is a sample schedule for 15 coldshutdown tests:

First cold shutdown: Tests 1, 2, 3, 4,5, and 6 completed.

Second cold shutdown: Tests 7, 8, 9,and 10 completed.

Third cold shutdown: Tests 11, 12,13, 14, 15, 1, 2, and 3 completed.

Fourth cold shutdown: Tests 4, 5, 6,and 7 completed.

The staff has determined that paragraphs4.2.1.2(g) and 4.3.2.2(g) of OM-10 areacceptable for all licensees to implementpursuant to Section 50.55a (f)(4)(iv) of Title10 of the Code of Federal Regulations(10 CFR 50.55a(f)(4)(iv)). If a licenseechooses to implement this guidance, thissection must be referenced in the ISTprogram.

Basis for Recommendation

The NRC recommendation is consistent withOM-10, which states the most recentrequirements for IST of valves approved byNRC in 10 CFR 50.55a and may be applied toplants continuing to use the requirements inSubsection IWV of Section XI. The technicalspecifications (TS) govern the restart of theplant. The staff has determined that startupneed not depend on the completion of SectionXI testing because, if the licensee wererequired to complete all cold shutdown testingbefore restarting the plant, it may have theunneeded burden of extending cold shutdown

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outages solely to complete surveillance NRC Recommendationtesting. However, a licensee should makereasonable efforts in scheduling andperforming the tests.

3.1.1.2 Testing at a Refueling OutageFrequency for Valves Tested During must be tested during power ascension forPower Ascension

OM-10 requires that valves tested on arefueling outage frequency be tested prior toreturning the plant to operation. Severallicensees have indicated that certain valvescannot be tested until power ascension begins. This section was included to give guidance forsuch valves and to indicate that the operabilityof technical specifications would control thetime for testing such valves. It is intended thatsuch valves will be indicated in the ISTprogram as tested on a refueling outagefrequency, even though the plant may returnto "operation" before the testing is completed. A similar intent applies to valves tested duringpower ascension from cold shutdowns whichare not refueling outages; however, thelanguage in OM-10 is different for valvestested on a cold shutdown frequency.

Before beginning power ascension from arefueling outage, the licensee normallycompletes the tests of those valves tested at Water Reactors to Allow Coldeach refueling outage. However, to test anyvalves that can only be tested during powerascension, the licensee may begin raising thepower level and changing modes inaccordance with TS requirements and test theapplicable valves when plant conditions allowtesting. If maintenance has been performedon a valve during the outage, the licensee isrequired to consider the valve inoperable untilcompleting post-maintenance testing in accordwith the operability requirements in the TS. This situation could also apply to valves testedduring power ascension from a cold shutdownoutage.

OM-10 requires that all valve testingschedules for performance during a refuelingoutage shall be completed before returning theplant to operation; however, for valves which

which technical specification requirements forthe valves or the system determine when thevalves are required to be operable, the testingfor these valves may be scheduled forrefueling outages (or cold shutdown outages). The NRC has determined that paragraphs4.2.1.2(h) and 4.3.2.2(h) of OM-10 areacceptable for all licensees to implementpursuant to 10 CFR 50.55a (f)(4)(iv). Therefore, relief is not required provided thelicensee meets all requirements of theseparagraphs and references this section in theIST program (also see Section 3.1.1.1 above).

Basis for Recommendation

The staff has determined that the guidance ofthis section is consistent with Paragraphs4.2.1.2(h) and 4.3.2.2(h) of OM-10 and the TSrequirements and is acceptable for meetingthose provisions.

3.1.1.3 De-inerting Containment of Boiling

Shutdown Testing

According to 10 CFR 50.44, "Standards forCombustible Gas Control System in Light-Water-Cooled Power Reactors," each BWRequipped with a Mark I or Mark IIcontainment must have provisions for aninerted containment atmosphere during poweroperation to protect against a burn orexplosion of hydrogen gas generated by thecore metal-water reaction after a loss-of-coolant accident (LOCA).

Oxygen content in the containment

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atmosphere is monitored during normal power shutdown and the extent of other outageoperation. Technical specifications specify activities could be factored into a decision. the maximum oxygen concentrations allowed. Also, for extended outages of several months,Since hydrogen generation is not a concern the requirements of Paragraph 4.3.2.5 of OM-during cold shutdown or refueling outages, the 10 or IWV-3416 of Section XI for valves intechnical specifications allow the containment systems out of service may apply (see Sectionatmosphere to be de-inerted. However, 3.1.3). Additionally, guidance on minimizinglicensees do not routinely de-inert the shutdown risk that may impact such a decisioncontainment during cold shutdown outages may be applicable for extended outages.because of the impracticality of the timeneeded to de-inert and re-inert and because Basis for Recommendation the nitrogen used for inerting is lost.

OM-10 and Section XI of the Code allow thelicensee to test certain valves located in theinerted containment during cold shutdownoutages because it is not practical to test themduring power operation. However, access tothe valve may be required to perform thetesting or repair the valve if it failed. The staffhas determined that de-inerting thecontainment at each cold shutdown outagesolely to perform this testing is impractical.

NRC Recommendation

Valves may be tested during refueling outages using the standard technical specifications areif they would otherwise be tested during cold also restricted in that the proper oxygen levelshutdown outages that require the must be established within 24 hours ofcontainment to be de-inerted for performance exceeding 15-percent thermal power or theof this testing. The NRC staff does not plant must enter an action statement. In eitherconsider that containment de-inerting solely case, the return to power can be greatlyfor the purpose of valve testing is warranted delayed, which results in lost powerand approves the test deferral pursuant to generation. 10 CFR 50.55a (f)(4)(iv) provided the licensee OM-10 allows for valve testing duringmeets all requirements of Paragraphs 4.2.1, refueling outages if such testing is impractical4.3.2, and 6.2 of OM-10 and describes this at quarterly intervals or during cold shutdownsection in the IST program (also see Section outages. The applicable BWR licensees3.1.1.1 above). would face hardship if required to de-inert, or

The staff determined that there are few containment to manipulate valves, solely tooutages that require de-inerting and that perform tests. Because the test interval ismaintaining a separate schedule for valve allowed to be extended to refueling outagestesting was not warranted. When an extended for valves which cannot be tested duringcold shutdown occurs which necessitates de- power operations or cold shutdowns, it isinerting the containment, testing is at the similarly acceptable to extend the test intervaldiscretion of the licensee. The length of the for those valves which cannot be tested unless

Unless the licensee would need to enter thedrywell for other reasons, de-inerting thedrywell during cold shutdown outages toperform testing is impractical because of thetime and effort needed to de-inert, re-inert,and replace lost nitrogen gas which coulddelay the return to power operation. Mostplants with custom TS must reduce theprimary containment oxygen content to lessthan 4 percent within 24 hours of placing thereactor mode switch in the run position. Ifproper oxygen concentration cannot beestablished for any reason, the plant isrequired to return to the startup mode. Plants

to require individuals to enter a de-inerted

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the containment is de-inerted. shutdown outages. The licensee may consider

3.1.1.4 Stopping Reactor Coolant Pumps for extended cold shutdown outages which wouldCold Shutdown Valve Testing

Licensees frequently schedule to test duringcold shutdown outages the valves in supportsystems that perform a function vital to thecontinued operability of the reactor coolantpumps, such as component cooling and thesupply and return of seal water. Exercisingthese valves when the pumps are operating Unless accompanied by other acceptablecould result in pump damage. Stopping the rationale, a required entry into a limitingreactor coolant pumps could extend the cold condition for operation (LCO) to perform ISTshutdown period and would be burdensome to would not justify deferring testing until a coldthe licensee. shutdown or refueling outage. Guidance on

NRC Recommendation and surveillance requirements was issued by

Reactor coolant pumps need not be stoppedfor cold shutdown valve testing. The staffrecommends affected valves be tested duringplant outages when reactor coolant pumps arestopped for a sufficient period of time and ona refueling outage schedule, but not moreoften than once every 92 days. OM-10 allowsthe test interval to be extended to refuelingoutages when the tests cannot be practicallyperformed during power operation or coldshutdown outages. The staff has determined itis acceptable to implement this portion of OM-10 pursuant to 10 CFR 50.55a (f)(4)(iv) asdiscussed in Section 3.1.1.1 above. Thelicensee must reference this section in the ISTprogram.

Basis for Recommendation

The NRC determined that the licensee neednot stop and restart reactor coolant pumps ateach cold shutdown solely to allow for thetesting of certain valves. This requirementwould increase the wear and stress on pumps,increase the number of cycles of plantequipment, and extend length of cold

establishing a schedule to account for

allow for valve testing when the reactorcoolant pumps are stopped for a sufficientlength of time. Valves are to be tested at leasteach refueling outage.

3.1.2 Entry into a Limiting Condition forOperation to Perform Testing

three issues regarding the applicability of LCO

the NRC in Generic Letter (GL) 87-09 asfollows:

(1) unnecessary restrictions on mode changesby TS 3.0.4 and inconsistent applicationof exceptions to it;

(2) unnecessary shutdowns caused by TS4.0.3 when surveillance intervals areinadvertently exceeded; and

(3) two possible conflicts with TS 4.0.3 and4.0.4:

(a) Surveillance requirements thatbecome applicable due toaction requirements.

(b) Surveillance requirements toTS 4.0.4.

The enclosures to GL 87-09 include the basesfor TS 3.0.1 — 3.0.4 which discuss entry intoLCO, stating that

It is not intended that the shutdownACTION requirements be used as an

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operational convenience which service to perform surveillance testing,permits (routine) voluntary removal technical specifications typically require thatof a system(s) or component(s) from the other train is operable. It is recommendedservice in lieu of other alternatives that the out-of-service time of the tested trainthat would not result in redundant be minimized. The probability of a designsystems or components being basis accident occurring during the shortinoperable. The specified time limits period of time a train is out of service isof the ACTION requirements are considered low, while the assurance ofapplicable from the point in time it is component operational readiness throughidentified that a Limiting Condition surveillance testing provides an increasedfor Operation is not met. The time level of safety. However, IST which results inlimits of the ACTION requirements a system being completely removed fromare also applicable when a system or service may not be acceptable for safety. component is removed from service Entry into multiple LCO is to be avoidedfor surveillance testing or (although the safety analysis may not prohibitinvestigation of operational certain situations and plant configurations).problems. Individual specificationsmay include a specified time limit for If a system or subsystem is designed to realignthe completion of a Surveillance automatically during testing and, therefore, isRequirement when equipment is not considered out of service, the licenseeremoved from service. In this case, need not enter an LCO. The NRC hasthe allowable outage time limits of approved relief requests for situations whichthe ACTION requirements are would have required operators to manuallyapplicable when this limit expires if manipulate one or more valves to restore athe surveillance has not been system to an operable status if the systemcompleted. function became required during IST.

In GL 87-09, the NRC stated its position that Therefore, if the licensee chooses the deferralthe structure of the referenced TS accounts for of testing from quarterly to cold shutdown, orentry into an LCO to perform surveillance to refueling outages, other justification musttesting. If the time allowed for equipment to be included in addition to entry into an LCO. be out of service is not sufficient to perform a If the deferral is not justified by additionalsurveillance test, a TS change requesting basis, the licensee must perform testsadditional out-of-service time to allow for quarterly, or during cold shutdown (assurveillance if safety is not compromised by justified), with entry into the LCO for IST tothe increased out-of-service time is be completed within the out-of-service timeappropriate. The NRC issued guidance on the allowed by TS.entry into LCO as documented in NRCInspection Manual Part 9900, "Technical NRC RecommendationGuidance - Maintenance - Voluntary Entryinto Limiting Conditions for Operation ActionStatements to Perform PreventiveMaintenance," which generally discouragesthe voluntarily entry into an LCO to performmaintenance.

When the licensee removes a train from

No new guidance or recommendations arecontained in this section. This sectiondiscusses previously issued guidance andexperience.

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3.1.3 Scheduling of Inservice Tests

Most TS define the test frequencies andintervals specified for IST activities in SectionXI of the ASME Code. Any changes to thistest frequency, such as testing a specific pumpevery 184 days (biannually), would require atechnical specification change and a reliefrequest to extend the test interval, unlessotherwise allowed by the Code.

NRC Recommendation

To remove the ambiguity of the periods asstated in the Code, the staff recommends thatthe licensee use these test frequencydefinitions even if the frequencies are notincluded in TS. For example, paragraphIWV-3411 in Section XI requires Category Aand B valves to be "exercised at least onceevery 3 months." This requirement can be metby testing at the beginning of a 3-month periodand the end of the next 3-month period;however, the intent is that the actual timebetween tests be approximately equal. Forquarterly testing, the staff recommends thepump and valve tests be scheduled such that aparticular test is performed at approximatelythe same time within each quarter. Forexample, if a test procedure applies for manyvalves and thus requires 2 to 3 weeks or moreto complete, the licensee would typicallybegin the procedure at approximately thesame time in each quarter and includedirections to perform tests in a specified orderto ensure that specific valves are tested "atleast once per 92 days."

Table 3.1 ASME Boiler and

Pressure Vessel Codeterms for inservicetesting activities

Term Requiredfrequency for ISTactivities (at leastonce every)

Monthly 31 days

Quarterly orevery 3 months

92 days

Yearly orannually

366 days

R f li f li

Each applicable test is required by TS to beperformed within the specified time intervalwith a maximum allowable extension not toexceed 25 percent of the test interval. However, the licensee would not extend thetest intervals for safety and relief valvesdefined in OM-1 and Paragraphs IWV-3510— IWV-3514 and Table IWV-3510-1 ofSection XI, other than to coincide with arefueling outage. If the conjunction and isused in specifying test frequencies such as"once every refueling outage and followingmodifications or maintenance," the test is tobe performed at both specified frequencies. The test is to be performed at either frequencyfor a schedule such as "once every refuelingoutage or once every 2 years." A 25-percentextension may be applied to the 2 years unlessthe TS or relief request stipulate "whichever ismore conservative," or another statement tothis effect. The Code requires performing the teststhroughout extended shutdown periods foroperable equipment. Most equipment must betested before being placed into service afterbeing out of service for an extended period inaccordance with TS requirements (ifapplicable). Code requirements (IWV-3416/OM-10, Paragraph 4.2.1.7, and IWP-3400(a)/OM-6, Paragraph 5.4) specify thattesting be performed after returning an out-of-service component to service if the componentwas not out of service to be repaired orreplaced.

Basis for Recommendation

This recommendation is based on the standardtechnical specifications which have beendeveloped, reviewed, and approved by theNRC staff. These intervals and extensionsapply directly to IST which is a technical

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specification surveillance requirement for be analyzed within 96 hours after thecertain pumps and valves. In interpretation completion of a test. If the deviations fallXI-78-01 for Section XI, the ASME Code within the required action range, the pump isCommittee clarified the intent of the "2-year" to be declared inoperable. Paragraphs IWV-frequency specified in IWV-3300 for position 3417 and IWV-3523 of Section XI stipulateindication verification and IWV-3420 for leak that corrective action is to be implementedrate testing stating that the intent of the Code immediately for valves, and if the condition istest and examination frequency be related to not corrected within 24 hours, the valve shallperiods of time rather than refueling outages. be declared inoperative. The NRC issuedRefueling outages are referenced to preclude guidance in the bases for TS 4.0.5 and in GLthe necessity to shut down the plant for 87-09, "Sections 3.0 and 4.0 of the StandardSection XI intent only. The requirement of Technical Specifications on the Applicabilitythe Code for Paragraph IWV-3300 is that the of Limiting Conditions for Operation andvalve position indicator test may be done each Surveillance Requirements." The NRC statedone to two years without regard to the in the "Bases" for TS 4.0.5: frequency of refueling outages. Therequirement for Paragraph IWV-3420 is that Under the terms of this specification,the valve leak rate test may be done each 1 to the more restrictive requirements of2 years without regard to the frequency of the Technical Specifications takerefueling outages. precedence over the ASME Boiler

The NRC recommendation for extended applicable Addenda. . . . Theshutdown periods is consistent with TS and Technical Specification definition ofCode requirements, whichever are more OPERABLE does not allow a gracerestrictive. Responding to inquiry IN92-025A, period before a component, that isthe ASME Code Committee stated that it is not capable of performing itsthe intent of Paragraphs IWV-3410 and IWV- specified function, is declared3520 of Section XI to require testing of valves inoperable and takes precedenceevery 3 months, including during extended over the ASME Boiler and Pressureshutdown periods, for valves other than those Vessel Code provision which allowsdeclared inoperable in accord with Paragraph a valve to be incapable of performingIWV-3416. The OM Committee made a its specified function for up to 24similar clarification in OM interpretation 93-1, hours before being declaredresponding that it is the intent of paragraphs inoperable. 4.2.1 and 4.3.2 to require testing of valvesevery 3 months, including during extended In Position 8 of GL 89-04, the NRC statedperiods for valves other than those that are that a pump or valve which exhibitsdeclared inoperable or not required to be performance in a required action range mustoperable. be declared inoperable and the TS action

3.2 Start of the Time Period inTechnical Specification ActionStatements

Section XI, IWP-3220, "Time Allowed forAnalysis of Tests," states that all test data shall

and Pressure Vessel Code and

period started as soon as the data is recognizedas being in the required action range (or avalve exceeds a limiting stroke time or fails toexhibit the required change of disk position). Pumps and valves covered by Section XI arefrequently in systems covered by TS. Upondeclaring a component inoperable, thelicensee may be required to place the plant in

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an action statement, which generally allows a have not been capable of performing its safetyspecific time period for continued operation. function. The operability of a redundant trainIf the equipment remains inoperable after the may be determined based on its lasttime period, the licensee may be required to surveillance and the maintenance condition oftake action such as to begin a plant shutdown. the system. Testing may be appropriate, but

NRC Recommendation would be inoperable during testing. The more

The staff recommends that test procedures manner; that is, within a period appropriate toinclude test parameter reference values and the circumstances and level of detail necessryacceptance criteria to enable the licensee to to complete the analysis. Upon completion ofquickly determine the condition of a the detailed analysis, appropriate actionscomponent. Using this information would relative to the operability of the componentallow those responsible for conducting the test would be taken. The licensee's analysis wouldto both determine whether the data meet typically address the condition of therequirements and ensure the pump or valve is component and not be based solely on aoperable. The staff recommends that the system condition, with a determination of thedetermination, at a minimum, be made by the cause of the degrading condition to ensure thatsame duty shift that performed the test unless redundant components would not be degradedthe test results are not available before the end by the same cause. To complete anof the shift, in which case the on-coming duty engineering analysis, the licensee would notshift may have to make the determination. typically exceed the time allowed in a limiting

After declaring a component inoperable anddetermining that an engineering analysis of theBasis for Recommendation condition is appropriate to determine if thecomponent can be returned to service, theanalysis would, typically, be performed withinthe allowable time of the TS action statement. If particular engineering expertise isnecessary, a preliminary analysis may beacceptable for declaring the pump or valveoperable and exiting the action statement, witha more detailed analysis to follow. Thepreliminary analysis would typically containsufficient basis on which to determine that acomponent is operable in the degradedcondition, with the component placed on anincreased test frequency as specified in theCode, if applicable. In performing theanalysis, the licensee would also typicallydetermine that the redundant train or trains areoperable to perform the safety function of theaffected equipment in case this equipment islater determined by more detailed analysis to

cannot be performed if all trains of the system

detailed analysis would follow in a timely

condition for operation.

The limits established for IST are based onCode requirements or the limits in either theTS or the safety analysis, whichever are moreconservative. The plant safety analysesincludes the minimum required performanceparameters for a component to meet the mostlimiting conditions under which it may berequired to operate for various scenarios.

For example, a pump may have three timesthe capacity required to meet the maximumanalyzed capacity for accident conditions. The reference values for the pump and theCode-required action limits may be muchhigher than the required capacity of the pumpsince the Code limits are not based on systemrequirements (see Section 5.6.2 below). However, in exceeding the Code limits, thepump exhibits degraded performance and may

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soon fail. NOTE: If the testing indicates that detailed analysis may result in determininginstruments are erratic, the test may be that the component is incapable of performingdiscontinued and the instruments recalibrated its safety function. By making this assessment(or replaced by a calibrated instrument that in a reasonable time period, the time ameets the code requirements for accuracy, component is considered operable (based onrange, vibration parameters, etc.) without the preliminary analysis) is limited to a shortdeclaring the pump inoperable (see IWP- period of time. In many cases, the preliminary3230(d), paragraph 6.1 of OM-6, and Question analysis will be sufficient for long-term46 of the minutes to GL 89-04 meetings). assessment. In many cases, the more detailed

For example, upon finding the pump in the analysis. It is expected that the situationsCode required action range, technical where a more detailed analysis is necessaryspecifications (if applicable) would require the and results in declaring the componentlicensee to declare it inoperable while inoperable will be few.reviewing the test results and makingcomparisons to previous test results to ensurethat a condition has not developed that willfurther degrade the pump and cause it toexceed the safety analysis limits. If thelicensee finds that the pump is not in danger offurther degradation over an acceptable periodof time, the licensee's engineering analysismay be an acceptable alternative to the repairor replacement of the pump for that perioduntil such time that repairs can be effected, asallowed by the Code. However, if the licenseedetermines that the condition will soon resultin further degradation, the analysis mayindicate that immediate action is required torepair or replace the pump.

If particular expertise is needed but not readilyavailable, this NRC recommendation allowsthe licensee to avoid an unnecessary plantshutdown by scheduling a preliminaryengineering analysis to be performed by anengineer on shift, such as the shift technicaladvisor or shift engineer.

When a preliminary analysis is performed toassess operability, a more detailed analysismay be necessary if additional expertise isneeded to review the condition of acomponent. The more detailed engineeringanalysis is to be performed in a timely mannerfollowing declaring a component operablebased on a preliminary analysis. The more

analysis will reconfirm the preliminary

3.3 120-Month Updates Requiredby 10 CFR 50.55a(f)(4)(ii)

After the initial 120-month interval, thelicensee must, in accord with the regulation,conduct inservice tests during successive 120-month intervals to verify operational readinessof pumps and valves, whose function isrequired for safety. In conducting theseinservice tests, the licensee must comply withthe requirements of the latest edition andaddenda of the Code incorporated byreference in 10 CFR 50.55a(b) 12 monthsbefore the start of the 120-month interval,subject to the limitations and modificationslisted in paragraph (b). Paragraph (f)(5)(iv)specifies that the licensee list the Coderequirements found to be impractical for thenew interval such that "the basis for thisdetermination . . . be demonstrated to thesatisfaction of the Commission not later than12 months" from the start of the interval. Therefore, it is recommended that reliefrequests for new intervals be submittedapproximately 6 months prior to the interval toaccount for a period for NRC review.

3.3.1 Extension of Interval

If an extended outage hinders a licensee fromcomplying with the inservice inspection

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requirements for items such as piping welds, inservice inspections and IST, it is oftenvessel welds, or pressure testing, it may extend desirable for maintaining the same edition ofthe interval in accordance with IWA-2400(c) the Code for all plant activities related to(1983 edition; the reference paragraph may Section XI. Even though 10 CFR 50.55a doesvary among editions), which states: not discuss extending the intervals, the Code is

Each inspection interval may be and therefore, has the same effect as thedecreased or extended (but not regulation. Although the Code does notcumulatively) by as much as one require NRC approval for 1-year extensions ofyear. For power units that are out of the interval, the licensee would avoid anyservice continuously for 6 months or discrepancies in the interval dates bymore, the inspection interval during informing the NRC of the extension andwhich the outage occurred may be documenting it in the IST program. Becauseextended for a period equivalent to the Code does not allow extension beyond onethe outage. year, other than for extended outages, such an

The licensee will typically also extend the Code or exemption in order to comply withinterval for IST to maintain the programs on the regulatory requirements.the same interval for inspection and testing.

NRC Recommendation extended or decreased up to one year

When the date for the new interval isestablished, the next updated program isrequired to be established to the latest editionof the Code incorporated in the regulation 12months before the new date. For example, if alicensee has an extension from December 14,1994, to September 16, 1995, in accordancewith the Code, the licensee's program for thenew interval must meet the edition of theCode incorporated in 10 CFR 50.55a(b) as ofSeptember 16, 1994. The staff recommendsthe licensee inform the NRC of any extensionbefore the date that would have been the endof the current interval. An extension beyond1 year (other than for outages) requiresapproval of an alternative to or exemptionfrom the Code or 10 CFR 50.55a.

Basis for Recommendation Several licensees have established concurrent

Subsection IWA of Section XI applies to bothIST and inservice inspections. While it is notmandatory to maintain identical intervals for

incorporated by reference in the regulation,

extension would require an alternative to the

The ASME Code allows intervals to be

cumulative and also allows intervals to beextended when outages greater than 6 monthsoccur. In response to an inquiry (ASMESection XI File Number IN93-002), the ASMEBoiler and Pressure Vessel Committeeindicated that Section XI, IWA-2430(d),allows the inspection interval to be extendedor decreased for reasons other than to enablean inspection to coincide with a plant outage. This would apply to IST intervals as well. InInterpretation XI-1-86-54, the committeestated that the one year extension need not beapplied only during the last one-third of theinterval and that the extensions may beapplied serially for both out-of-service andplant outage conditions.

3.3.2 Concurrent Intervals

intervals for all units at sites with multipleunits so that each unit is updated to a neweredition of the Code at the same starting date. Because the regulations do not specifically

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allow concurrent intervals, when the interval such that no single unit is tested at anstart dates are to be concurrent, the licensee interval of over 120 months (or no greatermay request a one-time alternative to or than the interval extension allowed byexemption from 10 CFR 50.55a. If the Code). Thus, the licensee must use thelicensee prefers not to request an alternative interval for the first unit that was licensedor exemption, the establishment of concurrent for commercial operation to establish theintervals would require that program updates interval dates and establish the correctbe performed more often than once every 120 Code edition according to the most recentmonths. Paragraph 50.55a (f)(4)(iv) allows required for either unit. that IST of pumps and valves may meet therequirements in subsequent editions of codes� To exceed 120 months, other than asand addenda or portions thereof which are addressed in the Code for an extension,incorporated by reference in the licensee must first obtain approval of10 CFR 50.55a(b), subject to the limitations an alternative to or an exemption fromand modifications listed, and subject to 10 CFR 50.55a; therefore, establishingCommission approval. This regulation allows two units on the same interval requires ana licensee to update programs before the end alternative or exemption unless theof a 120-month interval. licensee intends to repeatedly update both units more often than the required 120NRC Recommendation months. That is, the licensee will test

If a licensee elects to use the same Codeedition for multiple units, the staffrecommends that an alternative to orexemption from the regulation be requested toplace the multiple units on a concurrentinterval for IST. To establish concurrentintervals without an alternative or exemption,the licensee must update the referencededition of the Code more frequently to remainin compliance with Section 50.55a, except inthe case where the interval dates are within 12months, whereby the Code allowance for anextension would result in concurrent intervals. If the licensee elects to use paragraph By obtaining an alternative or an exemption, a(f)(4)(iv) of Section 50.55a to update to later licensee may test multiple units at the sameeditions of the Code, this section gives the interval, which is less confusing thanrequisite approval for the IST program, but not performing more frequent program updates. for inservice inspection, if the following However, the licensee may choose to updateguidelines are used. without requesting an alternative or

� Without obtaining an alternative or an IST program with a more current edition ofexemption, the licensee may perform the the Code. IST program for multiple units using thesame edition of the Code at concurrent The regulations allow for concurrent intervalsintervals if the initial interval for among multiple units if the program is updatedcombining the programs is established each time an interval for either unit is due.

each unit according to the most recentedition of the Code required for eitherunit.

The request for the alternative or exemptionand the IST program document wouldtypically describe the method for selecting theinterval dates, specifying the dates at which itwill begin and end, and comparing the effectof these dates with that of the dates requiredotherwise.

Basis for Recommendation

exemption, perhaps to periodically maintain

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The preferred manner for establishing reestablished to meet Code changes, thisconcurrent intervals is to consider each unit on would typically involve the new baselinethe same 120-month period with updates (reference) values being established during theoccurring at the end of the 120 months first quarterly or cold shutdown outage testthrough an alternative or exemption. While performed in the new interval, if not before. the example presented is acceptable for IST Before performing tests during the firstprograms in which test frequencies for refueling outage, the licensee would typicallycomponents other than safety and relief valves revise implementing procedures for the tests todo not exceed 18 to 24 months, this be performed during that outage toarrangement may not be acceptable for incorporate any new requirements or newinservice inspection intervals for schedules of components. 3-1/3-year and 10-year examinations. Thestaff might change this recommendation if All tests required to be performed during thefuture changes to the regulation or the Code refueling outage must be completed before ordo not allow for the extension of IST intervals. during startup from the refueling outage, as

3.3.3 Implementation of Updated 4.2.1.2(h) and 4.3.2.2(h)). If the licenseePrograms

Updating the IST program to a revised editionand addenda of the Code is an extensive effortthat involves changes to administrative andimplementing procedures. Often, the revisedrequirements will necessitate establishing newreference values, such as by implementing avibration program using velocitymeasurements rather than displacementmeasurements, or by establishing stroke-timereference values for power-operated valves. New reference values would be necessary forparameters not currently measured. New"reference values" for currently monitoredparameters may not be necessary if previousreference values were acceptable. However,the code does not specifically require newreference values to be established simplybecause a later edition is used.

NRC Recommendation

The staff recommends that, before beginningthe first tests during the new interval, theimplementing procedures be revised accordingto the appropriate requirements. When thetesting requires baseline values to be

required by the Code (OM-10, paragraphs

determines that a timely implementation is notpossible, the staff recommends that a schedulebe submitted to NRC (1) before the beginningof the interval, or (2) if the interval beginswhile a plant is shut down for refueling, beforethe startup from the refueling outage.

Therefore, the staff recommends that the reliefrequests be submitted to the NRC before thenew interval begins, and in any case, no laterthan 12 months following the new intervalstart date per 10 CFR 50.55a(f)(5)(iv).

In accord with the regulations, an updatedprogram to the later edition of the ASMECode must be implemented at the beginning ofa 120-month interval. The regulations statethat where a pump or valve test requirementby the code or addenda is determined to beimpractical by the licensee and is not includedin the revised inservice test program, the basisfor the determination must be demonstrated tothe satisfaction of the Commission not laterthan 12 months after each 120-month interval. Therefore, when a licensee updates the ISTprogram and identifies impractical coderequirements, the relief requests must besubmitted within 12 months from the

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beginning of the interval. Section 6 of the programs was 20 months. Early guidanceNUREG discusses a revision to technical given to licensees in 1976 letters recognizedspecifications and the effect on relief requests that relief requests would be submitted forfor impractical code requirements. review and approval and suggested thatExperience has indicated that impractical licensees submit the programs as early asrequirements are also identified throughout the possible prior to the beginning of a newinterval. In such cases, relief is requested as interval. The revised programs were tosoon as the condition is identified. Because comply with the requirements of editions ofthe requirements are impractical, the licensee the code and addenda in effect no more than 6would test the applicable components by the months prior to the start of the 40-months andmethod proposed in the relief request(s) in the 20-periods. However, the ISI intervalsperiod of time from the beginning of the new established for examination schedules ininterval (or from the time of identification) accordance with Section XI were based onuntil the NRC evaluation is complete (e.g., if a120-months. The rule included the provisionlicensee identifies a solenoid valve that is in for demonstrating "to the satisfaction of thethe IST program and stroke-time tested but Commission not later than 12 months after thehas no position indication, the code expiration of the initial 120-month period ofrequirements cannot be met due to design operation from the start of facility commerciallimitations and an alternative method may not operation and each subsequent 120-monthcomply with the code requirements). Relief period of operation during which therequests that do not relate to "impractical" examination or test is determined to berequirements, but propose alternatives to the impractical." code requirements, are not to be implementeduntil the NRC evaluation is complete (e.g., if a When the rule was changed to increase thelicensee proposes to implement a vibration length of the intervals for both ISI and ISTprogram based on using spectral analysis programs to 120-months (November 1979),rather then the code specified method, the the 12-month provision remained as it wascode requirements must continue to be met previously stated. The phrase "to theuntil NRC evaluation is complete). satisfaction of the Commission" seems to

Basis for Recommendation submitted, and at most that the NRC staff has

In updating the IST program to a revisededition and addenda of the Code, the staffrecognizes that changes might be completedover a period of time to allow for adequatereview and approval and recommendscompletion of the procedural revisions in atimely manner. The regulations do not allowthat a licensee continue with a previous Testing Intervalsprogram until the NRC has reviewed the reliefrequests for the next interval.

When the rule was initially established, theinterval (period) for updating inserviceinspection (ISI) programs was 40 months andthe interval for updating inservice testing (IST)

indicate that the relief request would be

reviewed it and is "satisfied" that it isacceptable. Future rule changes may clarifythe appropriate time period for submitting andimplementing relief requests for updatedprograms. Refer to Section 6 and Section 7for more discussion on relief requests.

3.3.4 General Comments on Inservice

The NRC has received requests for ISTprograms and partial submittals that lack thedates of the intervals or the Code edition inuse. At more than one plant, the individualsresponsible for the IST programs were notaware that the Code of Federal Regulations is

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updated throughout the year. Therefore, when licensee wants to use a later edition of thethey revised their programs, they used the code incorporated into 10 CFR 50.55a(b).bound version of 10 CFR Part 50 to determinethe Code edition cited in paragraph 50.55a(b)Basis for Recommendation12 months before the interval start date. However, a more recent edition had beenincorporated by reference in paragraph50.55a(b), which resulted in the program beingdeveloped to an incorrect edition of the Code.

Additionally, several plants have askedquestions concerning phasing-in the updatedprogram. Generally, this is an acceptableapproach for testing that does not involve anyrelief requests from the code requirements.

NRC Recommendation

The staff recommends that the interval dates licenses, or some other unspecified milestone. and Code edition be included in each IST However, if the NRC revised 10 CFR 50.55asubmittal, whether it is for an entire program after the date cited by the licensee and beforeor only a partial submittal containing new or the date of the operating license, and if thisrevised relief requests. The staff must ensure revision incorporated a later edition of thethat the interval dates are correct and that the Code, the regulations may have required useevaluation is performed using the edition of of a more recent edition than was actuallythe Code from which relief is requested. The used. Therefore, it is important that the ISTstaff recommends that the individuals Program state the Code edition and addendaresponsible for developing and maintaining the used to develop the program. IST program be aware of the regulatorychanges made in 10 CFR 50.55a throughoutthe year and review any new or revisedrequirements for any effect on the ISTprogram.

For phasing-in a new edition or addenda of thecode before the interval date (or during aninterval), the NRC recommends that a licenseesubmit a plan and schedule to the staff. Ifthere are no issues that require NRC review,(1) the testing can be phased-in during the 12months prior to the interval start date to theappropriate edition of the code, or (2) duringany time period identified by the licensee upto an interval start date, if the phasing-inbegins in the middle of an interval and a

The NRC has noted incorrect interval datesand Code editions cited in submittals for ISTprograms. The Code stipulates that thelicensee shall calculate the inspection intervalaccording to the number of calendar years thathave passed since the power unit was placedinto commercial service. The NRC lists, forinformation, the licensing and commercialoperation dates for nuclear power plants in theannual "NRC Information Digest"(NUREG 1350). The licensees for severalplants established the initial interval asbeginning on the date of their operating

3.4 Skid-Mounted Components andComponent Subassemblies

The Code class piping systems at a plant mayinclude skid-mounted components orcomponent subassemblies such as valves indiesel air-start subassemblies, diesel skid-mounted fuel oil pump(s) and valves, steamadmission and trip throttle valves for high-pressure coolant injection or auxiliaryfeedwater pump turbine drivers, steam traps,and air supply system check valves andsolenoid-operated valves for main steamisolation valves. If these components areidentified as ASME Code Class 1, 2, or 3, in

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the SAR, they are subject to IST. If these these individual components be included incomponents are not identified as ASME Code the scope of 10 CFR 50.55a, it would need toClass 1, 2, or 3, in the SAR (or the SAR complete a backfit analysis to justify imposingindicates that they are maintained as Code modifications to enable testing. The OMclass, but are not required to be Code class), Committee, including the OM-16 Workingthey are not subject to IST in accordance with Group for diesels, is considering clarifying10 CFR 50.55a. However, as discussed in whether skid-mounted components are withinPosition 11 of GL 89-04, Attachment 1, these the defined scope of the OM Codes andcomponents may be subject to periodic testing Standards, or if additional guidance on testingin accordance with 10 CFR 50, Appendix A these components is needed. Licensees mayand Appendix B. elect to use the IST program for testing these components and state in the IST program thatNRC Recommendation the surveillance tests of these components

Pending endorsement of OM codes andstandards which specifically address skid-mounted components which are subject toIST, the staff has determined that the testingof the major component is an acceptablemeans for verifying the operational readinessof the skid-mounted and componentsubassemblies if the licensee documents thisapproach in the IST Program. This isacceptable for both Code class componentsand non-Code class components tested andtracked by the IST Program.

Basis for Recommendation

Various pumps and valves procured as part oflarger component subassemblies are often notdesigned to meet the requirements forcomponents in ASME code classes 1, 2, and 3. In Regulatory Guide 1.26, "Quality GroupClassifications and Standards for Water-, Steam-, and Radioactive-Waste-ContainingComponents of Nuclear Power Plants," theNRC gives guidance on classifyingcomponents for quality group A (Code Class1), B (Code Class 2), C (Code Class 3), and D(ASME Code Section VIII; American NationalStandards Institute (ANSI) B31.1). Also seeNUREG-0800, Section 3.9.6. When many ofthe components were procured, therequirements for IST did not apply and thusthe components may not have includedfeatures for IST. If the NRC specifies that

adequately test the skid-mounted components. Also refer to Question Group 110 inAppendix A.

In the June 1994 OM Committee meetings,proposals for skid-mounted pumps and valveswere being considered at various committeelevels. It is expected that the publishedposition will be included in the 1995 Addendato the OM Code. The scope addressescomponents actually mounted on the skid andalso includes components that are notmounted on the skid, but that function muchthe same as skid-mounted components (e.g.,check valves in the service water system thatsupply cooling water to a pump) where testingthe major component can be consideredadequate to test the function of the pumps orvalves.

NOTE: For components outside the scope of10 CFR 50.55a, it is not required that the NRCevaluate relief requests. For furtherinformation in this area, refer to staff responseto Question 53 of the public meetings on GL89-04. The NRC discussed its position fortesting components outside the scope of10 CFR 50.55a (see Appendix A).

3.5 Testing in the As-FoundCondition

The Code does not specifically require testing

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to be performed for components in the as- stroking or maintenance. Section XI does notfound condition except for safety and relief require stroke-time testing or check valvevalves, but does not define as-found even in stroking prior to maintenance; however,the context of safety and relief valves. degradation mechanisms may not be identifiedMeasurement of the initial lift of safety relief if no as-found testing is performed. Post-valves is required to determine if additional maintenance testing is required when thevalves are to be tested, by IWV-3513, maintenance could have affected the valve'sparagraphs 1.3.3.1.4/5 and 1.3.4.1.4/5 of OM- performance (e.g., IWV-3200, OM-10/3.4). 1-1981, or paragraphs 1.3.3.1(d/e) and Similarly, as-found testing may apply to1.3.4.1(d/e) of OM-1-1987. OM-1-1981 and pumps as well. Most inservice testing isOM-1-1987 specify that periodic testing of all performed in a manner that generallypressure relief devices is required and that no represents the condition of a standbymaintenance, adjustment, disassembly, or component if it were actuated in the event ofother activity which could affect the as-found an accident (i.e., no pre-conditioning prior toset pressure or seat tightness data is permitted actuation). before testing.

The as-found condition is generally consideredto be the condition of a valve without pre-

NRC Recommendation

This is included for clarification only.

An allowance for demonstration of the leak tight function during the course of operation is treated an an exception to the scope of IWV-3420,1

with certain provisions for record requirements (Paragraph 4.2.2.1 of OM-10), and the test frequency for valves not subject to the exception continues tobe once every 2 years (see IWV-3421 or Paragraph 4.2.2.3(a) of OM-10).

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Table 3.2 Required tests and test frequencies for pumps and valves

Test Frequency

Measure pump parameters Once every 3 months

Exceptions: Pumps in regular use (record parameters) Pumps in systems out of service Pumps lacking required fluid inventory

Exercise Category A and B valves Once every 3 months

Exceptions: Extension because of impracticality Valves in regular use Valves in systems out of service

Measure stroke times of power-operated Category A Once every 3 monthsand B valves Exceptions:

Extension because of impracticality Valves in regular use Valves in systems out of service

Verify remote position indication Once every 2 years

Observe operation of fail-safe actuators for applicable Once every 3 months, except for extension because ofvalves impracticality

Leak-test Category A and A/C valves Once every 2 years. 1

Test safety and relief valves, primary containment Test interval specified by Table IWV-3510-1 or asvacuum relief valves, and non-reclosing pressure relief specified by OM-1. devices

Exercise check valves Once every 3 months

Exceptions: Extension because of impracticality Valves in regular use Valves in systems out of service

Test explosively-actuated valves 20 percent tested once every 2 years. Charges shallnot be older than 10 years.

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Example 3.1 Cold shutdown justification CSJ-4

Applicable Valve: CV-00112C

System: Chemical Volume and Control System

Function:Volume Control Tank Outlet Valve

Basis for Deferring Testing: Closing this valve while operating a charging pump would isolate thevolume control tank from the charging pump suction header, damaging any operating chargingpumps and interrupting the flow of charging water flow to the reactor coolant system. Thisaction could result in a reactor coolant system transient and a plant trip.

Example 3.2 Cold shutdown justification RBC-1

SYSTEM: REACTOR BUILDING CLOSED LOOP COOLING

COMPONENTS: 15RBC-24A,B CATEGORY: AC15RBC-26A,B CATEGORY: A

SAFETY FUNCTION: These valves close for containment isolation.

JUSTIFICATION: Exercising these valves will interrupt the flow of cooling water to one of thetwo operating cooling water trains for the containment vessel (drywell). Since the drywellcooling system has a limited capacity, this interruption during normal operating conditions couldsignificantly increase the temperature in the drywell which could result in a plant trip on "highcontainment pressure."

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Example 3.3 Refueling outage justification

SYSTEM: Safety Injection

VALVE: SI-8958 Code Class: 2

CATEGORY: C P&ID: M-65, D-7

FUNCTION: This check valve opens to supply water from the refueling water storage tank(RWST) to the suction for the residual heat removal (RHR) pumps.

BASIS FOR DEFERRAL OF TESTING TO REFUELING OUTAGES: This check valvecannot be full-stroke exercised open during unit operation because the shutoff head of the pumpsis lower than the reactor coolant system pressure.

The valve cannot be partially stroked during normal operation or during cold shutdown whenrunning or testing the RHR pumps on mini-flow recirculation. Alternative flow paths wereinvestigated and evaluated. The 8-inch [20.32-cm] recirculation line to the RWST with the RHRreturn valve, SI-8735, is not a prudent method to partially-stroke exercise this valve quarterly orduring cold shutdowns. The following are the reasons for this determination:

1. This is the only valve in the line that isolates the RHR system from the RWST. Failure ofthis valve (single failure) to close would render the RHR system inoperable and not able tofulfill its design basis function during an accident.

2. Operators would not have sufficient time to close this valve within 25 to 27 seconds becauseof its large size.

TEST FREQUENCY: Refueling outages.

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Example 3.4 Refueling outage justification ROJ/SI-4

Valves: SI-8815, SI-8900A, B, C, D, SI-8969A High Head Safety Injection Flowpath Check Valves

SI-8819A, B, C, D, SI-8905A, B, C, D SI-8922 A &B, SI-8926, SI-8949A&D and SI-8969B Intermediate Head Safety Injection Flowpath Check Valves

Reason for ROJ:

These valves are full-stroke exercised at refueling outages. These valves cannot be fully or partially opened duringplant operation or during cold shutdown outages because the flowpaths discharge into the reactor coolant system(RCS).

Justification:

The valves for the high head subsystem cannot be full-stroke exercised during plant operation because the high RCSpressure will prevent the maximum required injection flow rate. Part-stroke exercising during plant operation is notpracticable because any flow through the valves results in unnecessary thermal transients on the RCS cold leg nozzlesfor which they are not designed and imposes hydraulic transients on the charging system and on the reactor coolantpump seals which can cause them to cock. The check valves in the high head injection path cannot be full-strokeexercised at cold shutdowns because the high flow rates could challenge the RCS cold overpressure mitigation systemand would impose hydraulic transients on the charging system and on the reactor coolant pump seals which can causethem to cock. Part-stroke exercising at cold shutdowns is not practicable because the high head injection flowpath isnot designed for throttled operation.

The valves in the intermediate head subsystem cannot be fully or partially exercised during plant operation becausethe high-pressure of the RCS will not allow flow forward through these paths. (An exception to this is valve 8926which is in the mini-flow path of the safety injection (SI) pumps and thus is part-stroke exercised open duringquarterly pump tests.) Using the SI test header to part-stroke exercise certain check valves during plant operation isnot practicable because this path yields flow rates too small (approx. 5 gpm [0.315 L/sec]) for assessing theoperational readiness of these valves. The check valves in the intermediate head injection paths cannot be full-strokeexercised at cold shutdown outages because the high flow rates could challenge the RCS cold overpressure mitigationsystem. Part-stroke exercising these valves during cold shutdown outages is not practicable because the flowpaths arenot designed for throttled operation.

Test Frequency:

The subject check valves are full-stroke exercised closed during refueling outages at the same frequency as the full-stroke open exercise for the reasons described above. Close exercising of valve 8926 is not practicable after itsquarterly part-stroke exercise open because that would defeat both trains of the intermediate head subsystem. Therefore, valve 8926 is also full-stroke close exercised at refueling outages coincident with its full-stroke openexercise.

Editorial Note: This ROJ combines various check valves and could be simplified if divided into two or more ROJs.

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4 SUPPLEMENTAL GUIDANCE ON INSERVICETESTING OF VALVES

The following are recommendations of the satisfy the exercising requirements need notU.S. Nuclear Regulatory Commission (NRC) be additionally exercised, provided thestaff for valves that may be a part of an observations otherwise required for testing areinservice testing (IST) program. The types of made and analyzed during such operation, andvalves discussed herein are covered by are recorded in the plant record at intervals noSection XI of the American Society of greater than specified in IWV-3411. Even ifMechanical Engineers (ASME) Boiler and check valves are "exercised" in accordancePressure Vessel Code (the Code) and Part 10 with IWV-3414, they need to be included inof the ASME Operations and Maintenance the valve list in the IST program and the(OM) Standards (OMa-1988 edition). record (e.g., plant log, test procedure) needs to

4.1 Check Valves

The NRC considers check valves, and otherautomatic valves designed to close withoutoperator action after an accident and forwhich flow is not blocked, as "active" valveswhich would be classified as such in the ISTprogram (reference, for example, Section B3.6.3 of the Westinghouse Revised StandardTechnical Specifications). Similar criteriacould be applied to the opening function of acheck valve. The flow through a check valvewould be blocked by any condition precludingflow through the system. For example,installing a flange or closing another valve(other than a check valve) in the line wouldblock flow. A valve that is "positively held inplace" would be one that has an operator orother auxiliary device that maintains the diskin an open or closed position such as a stopcheck valve. SECY-77-439, "Single FailureCriterion," which was referenced in severalplants' licensing basis, discusses the failure ofa check valve to move to its correct positionas a passive failure; however, this does notcorrespond to the issue of "active" versus"passive" for the intent of IST.

IWV-3414 discusses valves in regular use andstates that valves that operate in the course ofplant operation at a frequency which would

indicate that the test requirements are met.

Those check valves (Category C valves)which must also be leak-tight (Category Avalves) would be designated as "CategoryA/C" in the IST program.

For "grouping" of similar check valves, referto the guidance given in Position 2 of GL 89-04 (see Appendix A). For grouping valves inmultiple units of like design and construction(e.g., Point Beach Nuclear Plant), if the unitsare "identical" and the grouped valves havesimilar operational experience and otherwisemeet the grouping criteria, it is acceptable togroup valves from multiple units. Position 2states that if a potentially generic problem isidentified during a disassembly and inspectionduring a refueling outage, all valves in thegroup in that unit must be inspected during therefueling outage. If the other unit is not alsoin a refueling outage, inspection of the valvesin the group which are installed in that unitmay be deferred to the next refueling outage ifthe licensee's evaluation of the problemindicates that it could impact the safety ofcontinued operation. "Grouping" may also beapplied to the use of nonintrusive techniquesas discussed in Section 4.1.2 below, thoughthe focus is slightly different in that all thevalves in the group are tested, while thenonintrusive techniques are applied to only

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one valve of the group; therefore, all valves in as practical. However, this in-situ testingthe group must be in the same unit. demonstrates only that at least one valve of

The NRC issued the following information The only indication of a problem would be thenotices (INs) on IST for check valves: failure of both valves to close.

IN 82-08 "Check Valve Failures on IST of a pair of valves does not enable theDiesel Generator Engine licensee to verify the operational readiness ofCooling System" each component as intended in the Code,

IN 83-03 "Check Valve Failures in Raw if one valve of the pair failed open. However,Water Cooling System of testing the pair of valves would be acceptableDiesel Generators" if the configuration does not require two

IN 83-54 "Common Mode Failure of configuration would credit either of the twoMain Steam Isolation valves. Nonreturn Check Valves"

IN 88-70 "Check Valve Inservice TestingProgram Deficiencies"

4.1.1 Closure Verification for SeriesCheck Valves without Intermediate to determine if both valves are required toTest Connections

Many plants have piping configurations whichinclude two check valves in series with noprovision (such as intermediate test taps) forverifying that each valve can close. Thesevalves may perform a safety function in theclosed position. For example, the valves maybe required to prevent the gross diversion offlow rather than to be leak-tight. The Coderequires valves performing safety functions tobe stroked to the position(s) required for thevalves to perform those functions.

Systems containing these valves may haveprovisions for verifying that at least one of thetwo valves in a pair is closed. The provisionswould enable the licensee to measure orobserve an operational parameter such asleakage, pressure, or flow for the pair ofvalves. The verification may be done eachquarter or during each cold shutdown outage

the pair is capable of reverse flow closure.

because this testing method would not detect

valves. The safety analysis for such a

NRC Recommendation

If the licensee has no practical means forverifying the ability of each valve in a series toclose, it may review the plant safety analysis

function. If only one of the two valves iscredited in the safety analysis (that is, if onevalve could be removed without creating anunreviewed safety question or creating aconflict with regulatory or licenserequirements), then verification that the pairof valves is capable of closing is acceptablefor IST. If relief is requested on this basis,both series check valves must be included inthe IST program and be subject to equivalentquality assurance criteria. Testing (such as theuse of pressure indication to verify the closureof one of the check valves) is required duringeach quarter or at an extended interval inaccord with the Code. No additional testingneed be performed unless the licensee findsindication that the closure capability of thepair of valves is questionable. If so, bothvalves must be declared inoperable andcorrective actions taken for both valves, asnecessary, before being returned to service.

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When testing of the pair of valves in diversion of flow. The Code requires thataccordance with the Code is not practical, the each valve performing a safety function belicensee may demonstrate the capability of stroked to the position required to performboth valves to close by disassembly and that function.inspection (GL 89-04, Position 2), or otherpositive means in combination, during testing. Systems containing these valves may haveIf the series valves are specifically required by provisions for verifying that at least one valvethe plant safety analysis assumptions, the is capable of closing. These provisions enableCode requires verification of the capability of the licensee to measure or observe operationaleach of the pair of valves to function. The parameters such as leakage, pressure, or flowlicensee may follow the guidance in GL 89-04,each quarter, during cold shutdown outages,Position 2, to disassemble and inspect each as or during refueling outages. However, thisan alternative means of verifying that testing provides no assurance that both valvesindividual closing capability, but not for close. The only indication of a problem wouldverifying leak-tightness (Category A valves). be the failure of both valves in the series.

Both valves in a series pair must be verified to Keep-fill valves are a special case in that theyfunction if the plant safety analysis credits or are redundant valves in redundant systems inotherwise requires both valves. For example, which only one valve of a series is actuallythe valves in the reactor coolant pressure necessary to perform a system's intendedboundary are required by Criterion 14 in function. Licensees have proposed to excludeAppendix A to Part 50 of Title 10 of the Code the upstream valve from the IST program. of Federal Regulations (10 CFR Part 50). However, recognizing that neither valve canPressure isolation valves are a special case of be individually demonstrated to shut, the NRCreactor coolant pressure boundary valves previously determined for the alternative testwhich generally are required to be individually method discussed in this section that bothleakage tested at a frequency specified by valves must be included in the IST programtechnical specifications and the Code. and operationally tested as a pair to prevent

To perform testing of the pair of valves as observing leakage, the licensee disassemble,described above, the licensee must obtain inspect, and repair or replace both valves asrelief because the Code requirements for necessary before the return to service.individual valves are not met. The reliefrequests typically include information on the 4.1.2 Exercising Check Valves with Flowsafety analysis, quality assurancerequirements, the acceptance criteria, and thecorrective actions that would be taken ifexcessive leakage is identified.

Basis for Recommendation

Many plants contain piping configurationswith series check valves that have noprovision (such as test taps) for testing theclosure capability of each valve. Some ofthese check valves perform a safety functionin the closed position to prevent the gross

reverse flow. The NRC specified that, upon

and Nonintrusive Techniques

The Code requires check valves to beexercised to the position(s) required to fulfilltheir safety function(s). To verify the diskposition of check valves that do not haveexternal disk position indication, the Codeallows the use of indirect evidence (such aschanges in system pressure, flow, temperature,or level) or other positive means. Instrumentsused to verify flow or pressure measurementsfor check valve full-stroke are not subject tothe range and accuracy requirements for such

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Table 4 Sample testing using nonintrusivetechniques (NITs) and the flow testing (FT)procedure

Cycle of refueling

Train 1Valve

Train 2Valve

Train 3Valve

Train 4Valve

1 FT/NIT FT/NIT FT/NIT FT/NIT

2 FT/NIT FT FT FT

3 FT FT/NIT FT FT

4 FT FT FT/NIT FT

5 FT FT FT FT/NIT

instrumentation used for pump IST; however, valve, the licensee would typically usethere may be testing techniques that nonintrusive techniques to verify that thenecessitate a high degree of instrument system pressures and flow conditions specifiedaccuracy. An acceptable test method must in the test procedures cause the valves to fullydemonstrate that a check valve disk opens to stroke. the position necessary to fulfill its safetyfunction, which may not be "full-open" to the During subsequent testing, if the systembackstop, but which may be verified either by conditions are repeatable, each valve wouldpassing design flow or by another positive typically be fully stroked; however, themeans such as nonintrusive techniques. The nonintrusive verification need be performed"other positive means" must be repeatable to for only one valve of the group on a rotatingmeet the intent of the Code. schedule each time testing is performed.

NRC Recommendation one valve would typically be nonintrusively

In supplementing the guidance from Position 1in Generic Letter (GL) 89-04, the NRCdetermined that the use of nonintrusivetechniques is acceptable to verify the fullstroke of a check valve. The licensee may usenonintrusive techniques to verify thecapability to open, close, and fully stroke inaccord with quality assurance programrequirements. These techniques areconsidered "other positive means" inaccordance with Paragraph IWV-3522of Section XI (Paragraph 4.3.2.4(a) ofOM-10), and relief is not requiredexcept as would be necessary for thetesting frequency if the test intervalextends beyond each refueling outage asallowed by OM-10.

When using nonintrusive testingtechniques in a sampling plan, thelicensee may implement a program suchthat similar valves in the same serviceare grouped for testing purposes, not toexceed four valves in a single group (for valvegroups of greater than four, the grouping andtest schedule must be justified in thedescription of the testing plan). GL 89-04indicates that the valves in the group selectedbe of the same size, model number, andsystem function. During the initial test of each

Under a sampling program for check valves,

tested each time the testing is performed, on arotating schedule, and the balance of thegroup would be flow tested. If problems arefound with the sample valve that aredetermined to affect the operational readinessof the valve, all valves in the group must betested using nonintrusive techniques duringthe same outage (the group may not consist of

valves in more than one unit). The followingtable, which is based on testing during eachrefueling outage, illustrates thisrecommendation.

The staff has determined that nonintrusivetechniques meet the Code requirements forverifying disk movement for the full-strokeexercising — opening and closing — of check

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valves. The nonintrusive reverification allows By performing nonintrusive testing initially onflow testing at repeatable conditions to be all valves in the group, the licenseeperformed on all valves in a group while demonstrates that the full-stroke capabilityrequiring nonintrusive tests of only one of the verification is acceptable. By repeating thegroup on a rotating schedule. Relief is not flow test under the same conditions, withrequired because this test method is nonintrusive verification of only one of theconsidered an acceptable "other positive four valves, the licensee verifies that themeans," even if used on a rotating basis. testing is repeatable. If the licensee finds aHowever, if the recommended alternative problem with one train, it must check all fourmethods of this section are implemented, the trains with the nonintrusive techniques. Whenlicensee must describe the implementation of the system has not been modified and the flowthis section in the IST program document. and pressure conditions are repeated, noThis recommendation is not intended to phenomena would be expected to invalidatemandate the use of nonintrusive techniques. the testing as verified initially that would not

Basis for Recommendation licensee modified the system or performed the

The recommended test method is applicable totests performed with less than accident flowrate. If accident flow rate is passed throughthe check valve being tested, nonintrusivetechniques are not necessary to establish thefunctionality of the valve. The nonintrusivetechniques would be used for verifying thatthe test at reduced flow would indicateadequate disk movement for full-strokeexercising the valve in accordance with theCode. An allowable flow variation would beestablished during the baseline testing usingthe nonintrusive techniques. If the flow rateduring future testing cannot be establishedwithin the range, the test is unacceptable and(1) nonintrusives could be used to verify thateven at different flow conditions, full-strokeexercising is achieved, or (2) correctiveactions to determine the cause of the failure tomeet the acceptance criteria for the test wouldensue. If other valves meet the acceptancecriteria, only the valve that indicates aproblem (if it is not the valve used forreverification by nonintrusive techniques)needs to be addressed for corrective actionunless the cause is determined to be applicableto the other valves as well. The rotation of thenonintrusive techniques over the four outages(in the example) is for reverifying the testmethod and test conditions.

be indicated in one of the four trains. If the

testing with a different valve alignment or testcondition, it must perform "initial"verifications for the new test conditions. Acopy of an NRC safety evaluation for a reliefrequest to adopt this method is included inAppendix D.

If all the valves in the group are flow tested, a"sampling" of one valve each refueling outageto verify that the test method is repeatable isacceptable to the staff for implementingnonintrusive test methods. If the "sampling"indicates problems with repeatability of thetest conditions, or other problems that mightaffect the testing of the other valves, thenonintrusive techniques must be used for theother valves during the same outage to complywith the sampling criteria. Relief is notrequired because the method meets the "otherpositive means" of the Code if each valve inthe group is flow tested at the regularfrequency. When extending the test intervalper OM-10, a test deferral justification may benecessary. If a sampling program is employedthat does not include a flow test of each valveon a regular basis, NRC evaluation of thealternative would be necessary. The OM-22working group on check valves initiated achange to the OM Code to allow a similarsampling program using nonintrusivetechniques for disassembly and inspection as

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discussed in Position 2 of GL 89-04. OM-22 useful if the test is performed in ais also considering a sampling plan with controlled manner with accuratebroader applications referred to as "condition instruments. The tests can also bemonitoring." verified using nonintrusive techniques

General guidance in qualifying a nonintrusive evaluation was issued for the Fortmethod is given in Position 1 of GL 89-04. Calhoun test which included the reportFurther information on qualification is prepared by the ORNL staff on theavailable through the OM working group for results of their review (ORNL/NRC/LTR-check valves and the Nuclear Industry Check 94-04). Both the study and a copy of the(NIC) Valve group. Disassembly and Fort Calhoun safety evaluation wereinspection may be necessary as part of the provided to the NIC Valve group forinitial verification or periodic reverification, distribution to members.depending on the techniques used. Disassembly and inspection would not (2) Licensees have asked about theotherwise be necessary to meet the appropriate corrective actions to takerequirements of IST, but may be used to when nonintrusive techniques cannot beconfirm a nonintrusive conclusion, for verified. The types of corrective actionscorrective actions, or for preventative taken when a test is inconclusive or whenmaintenance as part of an overall check valve the results indicate unacceptableprogram. functioning of the check valve are

]the use of nonintrusive techniques in addition include additional testing. Disassemblyto the issues discussed in Section 4.1.2. and inspection may be one element ofAdditional issues are discussed below: corrective actions, as mentioned in

(1) Several licensee have asked whether functional capability of the valve. GLmeasurement of the C of a check valve 89-04, Position 2, states that a flow testv

in conjunction with the application of for part-stroke exercising of the valvemeaningful flow versus differential should be performed followingpressure criteria would be considered reassembly, if practical."other positive means" in accordancewith IWV-3522 of the Code. The NRC (3) Some of the flow tests used withcontracted with Oak Ridge National nonintrusive techniques impart justLaboratory (ORNL) to perform a review enough energy to the disk to generate aof such a test method used at the Fort marginally audible impact of the diskCalhoun and Beaver Valley plants. The against the backstop. In these cases,review was to determine if the variations in initial conditions couldmeasurements and reduction of the data produce inconclusive nonintrusive testgive adequate assurance of the results. There are several nonintrusivefunctionality of the tested valves which methods available to verify disk positionwere, for both plants, the accumulator without requiring audible disk-backstopdischarge check valves. impact such as radiography, ultrasonics,

The results indicate that the data are must give conclusive results and be

during the initial testing. A safety

determined by the licensee. Actions may

Section 4.1.2 above, to ensure the

and magnetics. The method selected

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repeatable for the application. verified in the closed position quarterly

When using audible techniques, including indication and are generally located insideacoustic probes, the qualification method reactor containment or at other inaccessiblemust address concerns associated with locations. These valves may lack designother potential noise sources that could provisions for system testing to verify closureaffect the sound pattern of the disk capability at any plant condition. The onlystriking the backstop or valve seat. The practical means of verifying valve closure maylicensee is cautioned that this method is be by performing a seat leakage test. Many ofsubjective. For example, the license these valves are Category A/C valves that arewould benefit by using test equipment Type C leak-rate tested during each refuelingthat produses a trace to objectively outage as specified in Appendix J tomeasure the initial qualification of a 10 CFR Part 50.nonintrusive method that yields onlyaudible acoustic results. Potential noise NRC Recommendation sources include noise from a diskseparated from the swing arm, brokenparts in the piping, pump noise, loosestructures.

NRC Recommendation

The discussion provides general information that the setup and performance limitationsregarding nonintrusive testing methods. The may render leak testing impractical duringNRC recommends that the basis for the power operation and cold shutdown outages,qualification and use of nonintrusive the staff has determined that implementationtechniques be well documented. For issues of an extension of the test frequency for suchthat a licensee believes are unclear, a valves is acceptable in accord withproposed alternative could be submitted to the 10 CFR 50.55a(f)(4)(iv). NRC for review and evaluation.

4.1.4 Extension of Test Interval to accordance with the provisions of ParagraphRefueling Outage for Check ValvesVerified Closed by Leak Testing

Section XI requires that check valvesperforming a safety function in the closedposition be exercised to that position. OM-10allows for the licensee to verify the exerciseby visually observing the valve, recording anelectrical signal initiated by a position-indicating device, observing the appropriatepressure indication in the system, performingseat leakage testing, or using other positivemeans. IST programs include check valvesthat perform a safety function in the closedposition. Certain of these valves cannot be

because they do not have remote position

If no other practical means is available, it isacceptable to verify that check valves arecapable of closing by performing leak-ratetesting, such as local leak rate testing inaccord with Appendix J to 10 CFR Part 50, ateach reactor refueling outage. Recognizing

Thus the licensee may perform testing in

4.3.2.2(e) of OM-10. That is, if valveexercising is not practicable during plantoperation or cold shutdowns, it is acceptableto limit testing to full-stroke exercising duringrefueling outages. To use this position, thelicensee must include a refueling outagejustification describing the impracticality ofperforming testing at the Code frequency andreferencing this position in the IST program. If these valves also perform a safety functionin the open position, they would typically beexercised open at the Code-requiredfrequency, or the refueling outage justificationwould typically include the technicaljustification for not testing the valves quarterly

NUREG-1482 ���

or during cold shutdown outages. is not required to be performed at the same

In the justification for the Code cold shutdown outage or refueling outage frequency, the basisfor the impracticality of performing testingduring power operations and, if applicable,during cold shutdown outages, must bedescribed. The NRC has determined that theneed to set up test equipment is adequatejustification to defer backflow testing of acheck valve until a refueling outage. Whentesting at the Code interval is practical, thelicensee would need to obtain relief to test atanother frequency (e.g., once per fuel cycle;once per six months). Entering an LCO is not,alone, sufficient basis for deferring testing, asthe LCOs were established with testing inmind; however, if a test necessitates entry intoan LCO, that may be an element of thejustification for deferring the test (refer toSection 3.1.2.).

Basis for Recommendation

Leak rate testing verifies valve closure andprovides more information about the closedposition than a simple backflow test. However, leak rate testing generallynecessitates that certain systems necessary forplant operation be taken out of service forextended periods. Additionally, containmentaccess may be needed. Therefore, this testingis not practical to perform quarterly asbackflow testing might be on certain othervalves. This testing may not be practical toperform during cold shutdown outagesbecause the installation and removal of testequipment could delay plant startup. OM-10recognizes the limitations of performingtesting during power operations and coldshutdown outages and allows testing to beperformed during refueling outages for thosevalves which cannot be practically exercisedotherwise. Open exercising and verification isrequired at the Code-specified frequency and

time the leak rate testing is performed.

4.2 Power-Operated Valves

Power-operated valves are equipped withactuators that use motive force to change theposition of the valve obturator. The types ofactuators include motor operators, pneumaticactuators, hydraulic actuators, and solenoidactuators. Certain valves, such as main steamisolation valves and valves that have a fail-safe function, may actuate open (or closed) onspring force. The NRC discussed the IST ofseveral types of power-operated valves inNRC IN 86-50, "Inadequate Testing to DetectFailures of Safety-Related PneumaticComponents or Systems," and IN 85-84,"Inadequate Inservice Testing of Main SteamIsolation Valves." The NRC issued GL 89-10,"Safety-Related Motor-Operated ValveTesting and Surveillance," upon finding acommon mode failure with motor-operatedvalves. Testing programs addressing GL 89-10 include condition monitoring capabilitiesbeyond the stroke-time measurementrequirements for IST, but may be analternative method of monitoring the conditionof valves for which conventional stroke timingis not practical.

4.2.1 Increased Frequency of Testing forValves That Can Be Tested OnlyDuring Cold Shutdown Outages

The licensee for one pressurized-water reactor(PWR) plant performed stroke time tests ofthe main steam isolation valves (MSIVs)during power ascension and initially found thestroke times acceptable upon comparing themwith previous values. However, after furtherreview with the plant at 100-percent power,the licensee found that the stroke time for atleast one valve had increased such that the

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corrective action requirements of IWV- IWV-3417 for increased testing apply to3417(a) applied. In accordance with the valves independent of the exercisingCode, this increase necessitated that the test frequency specified in IWV-3412.frequency be increased to monthly until corrective action was taken. To conduct NRC Recommendation monthly full-stroke tests of MSIVs, thelicensee would have had to reduce plantpower and possibly bring the plant to ashutdown mode.

The NRC granted the licensee's request forexigent relief from the requirements of IWV-3417(a) to avoid shutting down the plantbased on an analysis that the valve stroke timeremained well within the plant's safetyanalysis limits and that an increase was notexpected to exceed the limits prior to the nextplanned cold shutdown. The licensee foundthat the need for this exemption resulted froma weakness in the administration andimplementation of its IST program.

There is no advance notice of which valvestested during cold shutdown will be in a rangefor stroke time which requires increasedtesting as specified in IWV-3417(a). Since acold shutdown justification has demonstratedthat the test can only be performed at coldshutdown, it is not practical to prepare a reliefrequest, submit the request to the NRC forevaluation, and obtain approval within 30days, when the next test would be required.

Paragraph 4.2.1.9(c) of OM-10 allows the useof analysis for declaring a valve operable,after testing indicates the stroke time is abovethe limiting value or has increased above thereference value by a specified percentage. This approach may be used to the extent thatit applies. In cases where a valve stroke timeexceeds the limits of the safety analysis, itcould not be declared operable until areanalysis indicates the new (increased) stroketime is acceptable. A relief request would notbe necessary to perform the analysis (orreanalysis). The intent of this section is toinform licensees that the requirements of

If the licensee cannot test safety-relatedpower-operated valves during power operationand must increase the testing frequency as aresult of tests performed during cold shutdownoutages in accordance with IWV-3417(a), thelicensee must take corrective action asspecified in IWV-3417(b) before returning theplant to power operation, or must return theplant to a mode that permits testing the valveseach month.

This requirement does not apply to testingperformed in accordance with OM-10, whichdoes not include this requirement; rather, OM-10 requires corrective action if a limitingstroke time is exceeded and does not specifyan increased test frequency for an increasingstroke time. Therefore, the increased testing isnot required if a licensee is testing againstportions or all of the stroke time requirementsof OM-10 in accord with 10 CFR 50.55a(f)(4)(iv). However, corrective actions arerequired more expeditiously under OM-10.

With test results indicating that somedegradation has occurred, it would not beconservative to allow an extension of thetesting interval from once each month to onceeach cold shutdown outage. To avoid a plantshutdown in one month, the staff recommendsthat these valves be repaired or otherwiseanalyzed and the increase in stroke timedetermined acceptable before the return topower. However, the licensee may elect toperiodically place the plant in a mode thatallows for monthly testing of the valve whichwould meet Code requirements.

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Basis for Recommendation are taken if degrading conditions are

Paragraph IWV-3412(a) of Section XI permitsthe licensee to defer valve testing from aquarterly interval until cold shutdown outages,if it is impractical to perform during poweroperation. However, the Code requires thelicensee to increase the frequency of testing toonce each month until corrective action istaken if the licensee, while conducting coldshutdown testing, finds that a power-operatedvalve fails to exhibit the required change ofposition within the stroke time limits of IWV-3417(a). Although the affected valves may bedegrading, they need not be consideredinoperable if placed on an increased frequencyof testing. Since these valves are technicallyoperable, the technical specifications (TS)may yet permit plant startup. However, thelicensee may have previously determined totest these valves only during cold shutdownoutages because they cannot be practicallytested during power operation.

In contrast to Section XI, IWV-3417, OM-10includes specific requirements for the limitingstroke times such that, if the test results arenot acceptable, the licensee must consider thevalve degraded and take corrective action. OM-10 does not specify an intermediatecondition that allows continued operation ofthe valve without corrective action, but withincreased testing.

4.2.2 Stroke Time Measurements forRapid-Acting Valves

New technologies and new applications ofexisting technologies enable licensees to timethe strokes of rapid-acting valves withaccuracy measured in milliseconds, though theCode does not require such accuracy. Usingnew technology, the licensee could establishan appropriate limit based on a multiple of areference value to ensure corrective actions

evidenced.

The traditional method of stroke timingpower-operated valves was to use stopwatchesto measure the stroke time from initiation ofthe signal at the handswitch to the change inposition-indicating lights (switch to light). Thetraditional method includes signal processingtime from the switch to the valve actuator. Monitoring stroke times for valves that strokein milliseconds using the diagnostic equipmentthat measures only actual valve travel isacceptable for indicating degrading trends;however, the method does not indicateincreases that could occur in the signal to thevalve, which may be important in meetingsafety analysis limits for certain valves. Typically, the valves that would benefit fromthis monitoring are rapid-acting valves. Thetraditional method would have a set limit of 2seconds which masks any signal processingtime unless a gross change occurs. Ifmeasuring the stroke times locally needs to besupplemented by a periodic test to include thesignal processing times, a periodic 2-secondlimit test could be performed to augment theIST. The code does not specify a particularmethod, so there would be no conflict in usingmore than one method.

NRC Recommendation

Although the licensee is not required to do soby the Code, if a licensee uses new technologyfor stroke-time measurements of rapid-actingvalves, the staff recommends that the licenseedetermine if continued reliance on the 2-second acceptance criterion of Position 6 ofGL 89-04 or paragraph 4.2.1.8(e) of OM-10 isappropriate when actual stroke times aremeasured to within milliseconds.

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Basis for Recommendation and describe the impracticality or hardship of

The NRC and the OM Committee established Code. the 2-second limit for rapid-acting valves forthe conventional method of measuring stroke- The staff has determined that this alternativetimes using a stop watch. Other methods have can ensure an acceptable level of quality andbeen developed as technology has improved. safety if the licensee has an establishedThe latest technology may improve the program of periodic testing. In this context,monitoring of the condition of these valves or the staff has found acceptable the testingserve to verify that a valve actuates within a programs established to GL 89-10 guidance. safety analysis limit which is less than 2 Because this alternative is not in accord withseconds. the Code requirements for test frequency,

4.2.3 Measurement of Valve Stroke Time

The Code requires that the stroke time ofpower-operated valves be measured to at leastthe nearest second (IWV-3413, for valves thatstroke in less than 10 seconds, and OM-10,paragraph 4.2.1.4(b), for all power-operatedvalves). However, many licensees useinstruments that can measure stroke timesaccurately to fractions of a second.

NRC Recommendation

To comply with Code requirements, thelicensee measures stroke times for power-operated valves to at least the nearest second. Similarly to Section 4.2.2 above, if using amore precise technique, it may be desirable,though not required, to establish stroke-timelimits based on a multiple of the referencevalue.

When it is impractical to measure stroke timesby any other method, a program of diagnostic The NRC described an inadequacy in the ISTmethods for valves may be an acceptable of MSIVs in IN 85-84, "Inadequate Inservicealternative test method. One example is a Testing of Main Steam Isolation Valves." Theprogram established in accord with GL 89-10, staff stated that two different licensees were"Safety-Related Motor-Operated Valve testing their MSIVs using the nonsafety-Testing and Surveillance," for monitoring related instrument air to achieve closure. Fail-motor-operated valves. Relief may be safe IST of MSIVs as required by IWV-3415necessary if the test schedule is not consistent and OM-10, paragraph 4.2.1.6, necessitateswith the IST requirements. If a licensee the removal of the instrument air supply andrequests relief, the submittal would typically electric power. Recent concerns related tospecify the details of the proposed alternative MSIVs are described in IN 94-08, "Potential

performing testing in accordance with the

relief is required.

Basis for Recommendation

Basing measurements and reference values onthe nearest second meets the coderequirements. However, valve diagnosticprograms for monitoring valve operatingparameters such as stroke times yieldsignificant information about the valveassembly (the valve and actuator). When ISTrequirements are impractical, the periodicverification performed using valve diagnostictechniques may be an adequate alternativemethod for monitoring these valves fordegrading conditions, including stroke timing. Because the testing addresses much more thanonly timing the valve strokes, the additionalinformation obtained on the condition of thevalves could justify the extension of the testinterval for performing diagnostic testing.

4.2.4 Main Steam Isolation Valves

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for Surveillance Testing to Fail to Detect an containment pressure is considered, a leakInoperable Main Steam Isolation Valve," and tightness test of the MSIV actuator andIN 94-44, "Main Steam Isolation Valve Failure accumulator, and a modification of theto Close on Demand Because of Inadequate applicable licensing basis documents. GEMaintenance and Testing." noted that this would necessitate measurement

NRC Recommendation final 10-percent of stem travel coincides with

The staff recommends that licensee review monitoring position switches alone, the utilitytheir inservice and fail-safe testing to ensure could not determine that the valve is fullycompliance with Code requirements. closed because the switches monitor the valve

Basis for Recommendation percent closed. The issue has not yet been

The practice of performing IST of components the MSIVs would not pass local leak ratewhich are relied on to mitigate the testing after closing on spring force only.consequences of accidents and which arerelied on to do so with sources of power not NOTE: Related to MSIVs, a number of plantsconsidered in the safety analyses is not in perform a partial-stroke exercise quarterlykeeping with the objective of periodic IST for during power operations. The revisedfail-safe testing. In IN 85-84, the NRC standard technical specifications bases forinformed licensees that, with low or no steam MSIV surveillance requirements states thatflow, the MSIV might not close unless "MSIVs should not be tested at power, sinceinstrument air is available to power the even a part-stroke exercise increases the riskactuator. of a valve closure when the unit is generating

In Service Information Letter 477, General Electric (GE) described a related concern for 4.2.5 Verification of Remote Positionboiling-water reactors (BWRs) in whichexcessive tightening of gland flanges in theMSIV can prevent the valve from closing fromspring force alone. During a postulated designbasis accident in which a recirculation linebreaks with the MSIVs open, containmentpressure may increase significantly, exertingan opening force on the valve actuators insidecontainment. Under such circumstances, theMSIV springs alone will not close the MSIVunless the spring force can overcome thecombination of the opening force caused bycontainment pressure and the resistive forcecaused by stem packing friction. GErecommended a review of packing chambermaintenance practices, "springs-only" full-stroke closing tests, a force balance in which

of the actual valve stem travel because the

the weakest spring force. GE stated that, by

only when it is 90-percent open and 90-

resolved. One BWR recently identified that

power."

Indication for Valves by MethodsOther Than Direct Observation

The Code (IWV-3300 and OM-10, paragraph4.1) requires that valves with remote positionindicators be observed at least once every 2years to verify that valve position is accuratelyindicated. Many valves such as sealedsolenoid valves and valves with enclosedstems have no provision for verifying theposition by direct observation. To verify theposition by observation, the licensee candisassemble the valve which could introduceadditional valve failure mechanisms. Othermethods, such as nonintrusive techniques,causing the flow to begin or cease, leaktesting, and pressure testing can yield a

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positive indication of position. closed. Leak-rate testing may yield positive

NRC Recommendation position. An in-line flow rate instrument can

If remote valve position cannot be verified by System pressures or differential pressurelocal observation at the valve, an acceptable across a valve seat may also give a positiveapproach is for the licensee to observe indication of actual valve position.operational parameters such as leakage,pressure, and flow that give positive indication Paragraph 4.1 of OM-10 states that whereof the valve's actual position(s). This is local observation is not possible, otherconsistent with paragraph 4.1 of OM-10. The indications shall be used to verify valvestaff determined that the use of this portion of operation. Such indications are also useful toOM-10 is acceptable pursuant to ensure that a valve disk is connected to the10 CFR 50.55a (f)(4)(iv) and that relief is not stem. required if all requirements of paragraph 4.1of OM-10 are implemented. No other related 4.2.6 Requirements for Verifying Positionrequirements apply.

For certain types of valves that can beobserved locally, but for which valve stemtravel does not assure the stem is attached tothe disk, the local observation must besupplemented by observing an operatingparameter as required by OM-10.

Basis for Recommendation

Paragraph IWV-3300 of Section XI requiresthat "valves with remote position indicatorsshall be observed at least once every twoyears to verify that valve operation isaccurately indicated." Often, licensees cannotverify the accuracy of remote positionindication by local observation of many valvessuch as those with enclosed stems or sealedsolenoid valves, and these valves may nothave position indicators, such as pointers, onthe valve actuators.

Accurate position indication for safety-relatedvalves is important for reactor operationduring all plant conditions. Therefore, theCode requires verification of the accuracy ofthe remote position indication for all valves inthe IST program with remote positionindication. Many positive ways are availableto verify the indication that a valve is open or

indication that the disk is in the closed

indicate system flow or flow stoppage.

Indication

The Code does not restrict the verification ofposition indication to only active valves. OM-10, Table 1, indicates that the licensee mustalso verify the position indication for CategoryB passive valves. Also, the Code does notrequire the licensee to verify the indication atthe remote panels. In Interpretation XI-1-89-10, the ASME Code committee stated that it isthe intent of Section XI, IWV-3300, that forvalves having remote position indicators atmultiple locations (such as in the control roomand also on a remote shutdown panel orsampling panel) that only the remote positionindicator at the location utilized in exercisingthe valve (IWV-3412) and timing the stroke ofthe valve (IWV-3413) be verified foraccurately indicating valve operation.

NRC Recommendation

This is for clarification of existing Coderequirements only.

4.2.7 Stroke Time Measurements UsingReference Values

Position 6 of GL 89-04 states that it isacceptable for the licensee to measurechanges in stroke times from either a

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reference value or the previous test value as values. Guidance included in GL 89-04,required by IWV-3413. In Position 5, the Position 6, did not discuss details of usingNRC gave guidance on establishing limiting reference values and licensees have typicallyvalues, but did not list acceptable percentages made proposals for implementing such anof the reference values. alternative that have been reviewed andNRC Recommendation evaluated by the NRC. Guidance for

OM-10 specifies the allowable changes in was given in GL 89-04, Position 5, andstroke times from reference values. remains acceptable even when using OM-10. Therefore, when a licensee elects to compare Paragraph 4.2.1.4 of OM-10 specifies that themeasured stroke times to reference values, thelimiting value(s) of full-stroke time berequirements of paragraph 4.2.1.8, "Stroke specified by the Owner. The use of referenceTime Acceptance Criteria," of OM-10 and all values, alone, differs from therelated requirements such as testing recommendation to use the multipliersrequirements and corrective action apply. The specified in Paragraph 4.2.1.8 of OM-10. staff has determined that it is acceptable for a Limiting values and reference values are twolicensee to implement this method in accord distinct values, though interrelated inwith 10 CFR 50.55a (f)(4)(iv) for use of establishing the stroke times at whichportions of later editions of the Code approved corrective action is required. Additionally,in 10 CFR 50.55a(b) if all related licensees using reference values establishrequirements are met which include these values in various ways, such asparagraphs 3.3, 3.4, 3.5, 4.2.1, 5, and 6. averaging three stroke times following

Basis for Recommendation OM-10 does not specify a particular method

The licensee can follow the requirements ofOM-10 for establishing reference values of Paragraph 3.5 of OM-10 gives thestroke times because the stroke timing requirements for establishing additionalacceptance criteria for power-operated valves reference values. It appears that differentin IWV were based on a change from the reference values may exist for a single valve ifprevious values. This removes the there is justification. For example, testinconsistencies of applying acceptance criteria conditions could impact the reference strokewhere no previous guidance was available. time depending on pressure or flow in theVariance from these requirements of OM-10 system. It may be necessary to have morewould necessitate relief describing the details than one test condition, such as dynamicof the alternative method of setting versus static, which would necessitateacceptance criteria, establishing appropriate different reference values.multipliers, etc. Appendix C includes asample relief request for the use of stroke time4.2.8 Solenoid-Operated Valvesreference values in accord with OM-10.

The recommendation is intended to allow theuse of OM-10 requirements in lieu of IWV-3413 for power-operated valves. Thediscussion refers to the use of reference

establishing "limiting" values of stroke times

maintenance, or using the first test value.

for establishing reference stroke times.

The NRC has received many relief requests tonot measure the stroke times of enclosedsolenoid-operated valves (SOVs) that do nothave position indication. Most of the requestsproposed no alternative to monitor the valves

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for degradation. recommended that the technique evaluates

NRC Recommendation of the pilot valve or valve stem.

If the licensee cannot time the stroke of an 4.2.9 Control Valves with a SafetySOV by the conventional method usingposition indication, the Code would requirethat it propose a method to time the stroke ofthe valve or otherwise monitor for degradingconditions to give adequate assurance ofoperational readiness. The staff hasdetermined that, while an exercise of thevalves on a quarterly schedule ensures that thevalves actuate properly, this is not adequatefor IST. If the frequency requirements of theCode are met, no relief is required to usemethods such as acoustics or diagnosticsystems for stroke timing. If a method tomonitor for degradation other than bymeasuring stroke time is proposed as analternative, NRC approval is required. Forexample, an enhanced maintenance programor periodic replacement may be acceptablewhen testing methods cannot be usedeffectively.

Basis for Recommendation

In NUREG-1275, Vol. 6, "OperatingExperience Feedback Report - Solenoid-Operated Valve Problems," the NRCdescribed common-mode SOV problems thatcould significantly reduce plant safety. Several methods have been developedrecently to measure stroke time or monitor thecondition of SOVs using parameters such asthe acoustic effects of disk movement, electricresistance, and the temperature of the coil. Such methods and continuing research aredescribed in papers from Session 2A,"Solenoid and Air-Operated ValvePerformance and Testing," published inNUREG/CP-0123, "Proceedings of theSecond NRC/ASME Symposium on Pump andValve Testing." Valve diagnostic systems canbe used to trace the stroke of an SOV and thusindicate the stroke time in milliseconds. It is

actual disk movement and not just movement

Function

Often a safety function is performed bycontrol valves that fail in the safe position,whether that is open or closed. Unless controlvalves have a safety function which mayinclude a "fail-safe" function, as valves thatrespond to system conditions, these valveswould be exempt from IST as discussed inIWV-1200 or Paragraph 1.2 of OM-10;however, the valves are required to be testedin accordance with the requirements for IST ifthey perform a safety or fail-safe function. The staff has received many requests for relieffrom stroke-time measurement requirementsbased on the impracticality of performing themeasurement by the conventional methodusing position indication lights. Typically, thecontrol valves do not have position indication,and testing can only be performed bybypassing control signals. To allow stroketiming by bypassing the control signals ofthose control valves with position indication,the licensee may also have to drain entiresystems which makes testing at the Codefrequency impractical.

NRC Recommendation

Control valves that perform a safety or fail-safe function are required to be tested inaccordance with the Code requirements forIST to monitor the valves for degradingconditions. Simply verifying that the valvesfunction is not an acceptable alternative whenthe stroke time measurement by theconventional method is impractical. Acceptable alternatives exists for monitoringthe valves for degrading conditions.

The staff recommends that the licenseeinvestigate alternatives that include stroke-

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timing with acoustic or other nonintrusive related functional requirements for flowmethods, stroke-timing with local observation shutoff or operation to full open status areor observation of system conditions, enhanced required to be classified as Category A or Bmaintenance with a periodic stroke which may valves. The response was originally that thenot be timed, stroke-timing and fail-safe valves were required to be tested intesting during cold shutdowns or refueling accordance with Subsection IWV, but theoutages that involve bypassing control signals, response was later revised in XI-1-83-59R toand a control system signal calibration to indicate that it is the owner's responsibility toverify the stroke times of the valves. The categorize valves as required by IWV-1400motor-operated valve testing program and in accordance with the criteria of IWV-established in accordance with GL 89-10 and 2200.performed on a periodic schedule is an acceptable alternative, along with a periodicvalve stroke, because it would yield moreinformation on valve condition includingstroke time, although the information wouldbe obtained less frequently. The alternativemethod proposed by the licensee wouldtypically be described in detail in the reliefrequest, if required, in order for the staff todetermine the acceptability of the alternativemethod.

Basis for Recommendation

Many control valves are not exempt from ISTbecause they perform a safety function otherthan "control." The Code requires stroketiming of power-operated valves, but thefeatures that enable testing have often notbeen provided for control valves. Therefore,an alternative test method is acceptable if themethod, possibly in combination with aperiodic valve stroke, provides an indicationof degrading conditions. Although stroketiming by an alternative method is preferredbased on the Code requirements, the licenseecan use other methods if stroke timing isimpractical. However, the licensee mustobtain relief for alternatives that do notcomply with the Code.

In interpretation XI-1-83-59, the ASMESection XI Committee responded to a questionon whether control valves that have safety-

4.3 Safety and Relief Valves

The NRC has received many relief requestsfor the IST of safety and relief valves. 4.3.1 Scope

In Paragraph IWV-1100 of the 1986 edition ofSection XI, the Code committee increased thescope of the valves subject to IST to includethose valves which protect certain Code classsystems that are required to perform a specificfunction in shutting down the reactor,maitaining the safe shutdown condition, or inmitigating an accident, from overpressure. Pressure relief valves which are installed inthe applicable systems to protect againstoverpressure may not, themselves, appear toperform a specific function to shutdown thereactor, maintain it in a safe shutdowncondition, or mitigate the consequences of anaccident (automatic depressurization valves inBWRs are an example of relief valves whichperform both an overpressure protectionfunction and a function to depressurize theprimary system when opened on an automaticsignal or by an operator). However, certain ofthese valves are now required to be includedin the IST program and tested according to theschedules stipulated in OM-1-1981 or OM-1-1987 "Requirements for InservicePerformance Testing of Nuclear Power Plant

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Pressure Relief Devices." OM-1 does clarify necessary safety or overpressure protectionthat it applies only to pressure relief devices function, it may be possible to coordinate withrequired for overpressure protection. The a design engineering group for reanalyses. Ifregulation requires this testing to be included the results of the overpressure protectionin 120-month updated IST programs. "reanalysis" for a particular system indicate

The revised scope in Part 1 of the OM Code, removed from the scope of the IST program. OMc-1994, more clearly indicates that therequirements are applicable to safety and NRC Recommendationrelief valves which are required to protectsystems or portions of systems that perform aspecific function in shutting down a reactor tothe safe shutdown condition, in maintainingthe safe shutdown condition, or in mitigatingthe consequences of an accident. An inquiryon "thermal relief valves" was discussed in theOM-1 working group meetings in Septemberand December 1993 and in the OMsubcommittee on valves meeting in March1994. The inquiry originally asked if "thermalrelief valves" were in the scope of Part 1. Theworking group requested the inquiry berewritten because there is no definition for"thermal relief valves." When rewritten, theinquiry questioned wither it is the intent of theOM Code to require testing of relief valvesthat protect systems or portions of systemsthat perform a specific function in shuttingdown a reactor to the safe shutdowncondition, in maintaining the safe shutdowncondition, or in mitigating the consequences ofan accident, against overpressurization due toa temperature increase. The working grouprecommended to the subcommittee that theresponse be "Yes." Further actions areongoing to give more clarification.

It is important to note that the requirement toperform testing of safey and relief valveswhich protect against overpressure is based onthe requirements of Section III of the ASMECode, or the applicable code of construction. The IST engineer may not have thedocumentation for the system design ordevelopment of the Section III overpressureanalyses. However, if there are safety orrelief valves that do not appear to perform a

that a relief vale is not necessary, it may be

None. This discussion is for clarification ofexisting requirements and discussion ofquestions that have been posed concerning thescope of OM-1.

Basis for Recommendation

The basis for the clarification is the scopestatement of OM-1, as well as the revisedscope statement in Appendix 1 (OM-1) of theOMc-1994 Addenda to the OM Code. Also,in a paper presented by Thomas F. Hoyle,"Introduction to OM-10, TechnicalDifferences Between IWV and OM-10,"NUREG/CP-0111, the expansion of scope isdiscussed. The expanded scope includes onlyASME Code Class 1, 2, and 3 valves and is,therefore, within the scope of 10 CFR 50.55a.

4.3.2 OM-10 Reference to OM-1

The 1989 Edition of Section XI, IWA-1600,references the 1987A Addenda of OM Parts 6and 10, and the 1987 Edition of Part 1. Asdiscussed in 10 CFR 50.55a(b)(2)(vii), whenusing the 1987 Addenda, 1988 Addenda, orthe 1989 Edition of Section XI, the OMa-1988Addenda of Parts 6 and 10 shall be used. Thiswas corrected in the 1990 Addenda of SectionXI, as errata. Part 10 does not reference aspecific edition of Part 1.

NRC Recommendation

None. This discussion is for clarification ofexisting requirements.

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4.3.3 Test Supervisor Qualifications measuring fluid flow.

Performance Test Code (PTC) 25.3-1976 isthe PTC referenced in Section XI, IWV-3512,for setpoint testing of safety valves and reliefvalves. Paragraph 3.02, "Qualification ofPerson Supervising the Test," of the PTC is arequirement for IST. The OM committeerecognized that PTC 25.3-1976 was writtenfor testing at the manufacturer's facility andincludes requirements that are difficult toapply to an operating power plant. Also, itdoes not include all testing for monitoringinservice valves. Therefore, the OMCommittee issued OM-1, "Requirements forInservice Performance Testing of NuclearPower Plant Pressure Relief Devices," forapplication to both preservice and IST. WhenOM-1 was issued for testing safety valves andrelief valves in nuclear power plants, it did notinclude specific requirements for thequalifications of test supervisors. Paragraph1.3.2.1(d) of OM-1, lists "the qualification ofpersonnel who perform testing andmaintenance" as an item for which the ownerhas responsibility.

The PTC specifies that a test supervisor whohas obtained an academic degree in a branchof engineering from a recognized school ofengineering, and who has at least two years ofpractical experience in fluid-flowmeasurement, may be considered qualified tosupervise the test. Code Case N-442, "1977Addendum to ASME PTC 25.3-1976, `Safetyand Relief Valves,' Class 1, 2, 3, and MC[metal containment] Section III, Division 1,"stated that the 1977 Addendum to PTC 25.3-1976 could be used as alternative rules forASME Section III safety and relief valvetesting. The 1977 Addendum specifies that aperson who supervises the test shall have aformal education in thermodynamics and fluidmechanics, experience in supervising tests,and at least 2 years practical experience in

A licensee often issues a purchase ordercontract for a testing contractor to conduct thesetpoint testing of safety valves and reliefvalves, either at a test facility or on site. Infollowing OM-1 requirements such that theowner specifies the qualifications, licenseestypically have specified the applicablerequirements in the purchase order and havedocuments from the testing contractor toverify that the individuals performing the testsmeet the specified qualifications. Thesecriteria also apply for testing supervised by theowner such that test procedures specify thequalifications of the individuals performing thetests and documents are available showingthese qualifications are met. A generalstatement is not sufficient.

NRC Recommendation

The staff has found acceptable either of twoalternatives to the qualification requirementsin the PTC:

(1) Following the requirements of OM-1,Paragraph 1.3.2.1, the licensee mayestablish the criteria for qualifying thetest supervisor and document thequalifications in the test implementationprocedure or work package for thesetpoint testing. Documentation that thetest supervisor meets the qualificationsmust be available in the plant records. The staff has determined theimplementation of the requirement ofOM-1, paragraph 1.3.2.1, for testsupervisor qualifications is acceptablepursuant to 10 CFR 50.55a (f)(4)(iv).

(2) The licensee may follow the guidance inCode Case N-442 which relaxes theeducational requirements specified inPTC 25.3-1976. This alternative

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necessitates a relief request because the vessel from overpressure and to enable thecode case is not approved as applicable to licensee a means to quickly depressurize theSection XI. primary system. If a small-break loss-of-

Basis for Recommendation failure of the high-pressure injection system,

The 1986 and later editions of ASME Section depressurize the vessel to enable the low-XI reference OM-1 for setpoint testing of pressure injection systems (i.e., low-pressurerelief devices. The staff may approve the use coolant injection and core spray) to injectof later editions, or portions thereof, pursuant coolant for core cooling. Licensees haveto 10 CFR 50.55a (f)(4)(iv). Therefore, it is typically identified these valves as Categoryacceptable to follow the requirements of OM- B/C for both the power-operated function and1 which state that the owner is responsible for the self-actuating function. establishing the qualification of personnel whoperform testing and maintenance of safety Automatic depressurization system (ADS)relief devices. valves are capable of (1) acting as simple

Responding to inquiry number IN-92-027, the operated from a remote location, or (3)ASME Code Committee, Section XI, stated responding to an automatic safety systemthat, although the test supervisor's signal independently of reactor pressure. qualifications of ASME PTC 25.3-1976, Because of the categorization of these valvesparagraph 3.02, apply when performing set as B/C, licensees typically request relief for anpoint testing in accordance with Section XI, alternative to measuring stroke time for theseIWV-3512, the provisions stated in PTC 25.3- valves, as these valves do not generally have1976, paragraph 3.02, are permissive (allow valve obturator position indication. Thediscretion). Therefore, the guidance for test alternatives the staff has accepted include thesupervisor qualifications in Code Case N-442 use of acoustic monitors, the indirectwould be acceptable for Section XI IST and measurement of stroke time, and theSection III design capacity verification. performance of enhanced maintenance on the

Appendix B to 10 CFR Part 50 specifies therequirements for quality assurance of activities The ADS valves perform dual functions. conducted for nuclear power plants. Included Many licensees identify the valves asare requirements for documenting tests Category B/C in the IST program, althoughconducted by a test contractor or facility or by the ASME OM Committee has indicated thatplant personnel. These documents would it is reviewing this issue to determine theconfirm that the test supervisor meets the proper category(ies) for these valves (R.requirements necessary for ensuring the Favreau, OM Committee Meeting, Septemberquality of the tests. 21, 1993) and that when using OM-1, it was

4.3.4 Frequency and Method of Testing testing requirements for safety and reliefAutomatic Depressurization Valvesin Boiling-Water Reactors

Most boiling-water reactors (BWRs) areequipped with dual-function main steamsafety relief valves to protect the reactor

coolant accident (LOCA) coincides with a

the opening of these valves would

mechanical relief valves, (2) being manually

valves.

considered as included all of the inservice

valves (the committee has not yet completedthe review, but a few plants have categorizedthe valves as Category C rather than B/C). IfCategory B/C, the Category B power-operatedfunction of the valves would be tested inaccordance with requirements of Section XI,

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Paragraph IWV-3400, at least during each reactor steam pressure is available. The NRCrefueling outage. The Category C function of discussed concerns for these valves inthe valves would be tested in accordance with NUREG-0123, "Standard Technicalrequirements of Section XI, paragraph IWV- Specifications for General Electric Boiling3510 (or OM-10) and PTC 25.3-1976 or OM- Water Reactors (BWR/5)," and NUREG-1. 0626, "Generic Evaluation of Feedwater

NRC Recommendation Accidents in GE-Designed Operating Plants

The Code requirements for measuring stroke Applications." In these documents, the stafftime govern the monitoring of power-operated recommends reducing the number ofvalves for degrading conditions. In many challenges to the dual function ADS valves inplants which identify the ADS valves as order to reduce their failure rate, becauseCategory B/C, position indication is not failure in the open position is equivalent to aprovided for the ADS valves, making direct small break LOCA. Therefore, the periodstroke time measurement impractical. Many between refueling outages is a reasonablelicensees meet the Code requirements for alternate frequency for verifying the Categorystroke time by using the acoustic monitors B function of these valves.downstream of these valves to measure thestroke time. This alternative is acceptable per The testing that verifies the Category CGL 89-04, Position 6, if a 2-second limiting function of these valves can typically bevalue is assigned using the guidance for performed as specified in the Code, as thisrapidly acting valves. Other acceptable testing is performed infrequently and presentsmethods include (1) measuring the stroke time no special problems. If the ASME OMat the set pressure test facility, with an Committee determines that these valves areexercise in-situ after reinstallation to ensure Category C (as opposed to Category B/C orcontrols have been properly connected, and A/C), meeting the Code requirements for(2) performing enhanced maintenance of the Category A or B will be unnecessary. ADS and pilot valves, with stroke timemeasurements of the pilot valves. The staff 4.3.5 Jack-and-Lap Process determined that the test frequencies in OM-10are acceptable pursuant to10 CFR 50.55a(f)(4)(iv). Therefore, thelicensee may perform testing using theacoustic monitors and the guidance of GL 89-04, Position 6, during refueling outages bypreparing a refueling outage justification forextending the test interval. Other proposedalternatives may necessitate NRC approval.

Basis for Recommendation

Testing these power-operated valves asCategory B valves may be difficult becausethey can be exercised only when sufficient

Transients and Small Break Loss-of-Coolant

and Near-Term Operating License

In Information Notice 91-74, "Changes inPressurizer Safety Valve Setpoints BeforeInstallation," the NRC stated that the setpointchanges in Dresser pressurizer safety valvescould result in part from changes made duringa "jack-and-lap" procedure which isperformed after setpoint testing and beforeinstallation to reduce seat leakage. Thisprocedure may have lacked adequate controls.

Many licensees avoid performing setpointtesting after jack-and-lap maintenancebecause this testing could lead to leakage.

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The Code requires that when the licensee hasactivity and evaluation within the qualityrepaired a valve or performed maintenance controls and quality assurance for the process. that could affect its performance, the licensee Controls include limits on the amount ofmust demonstrate that the performance material which is removed, the controls toparameters are acceptable by testing the valve ensure the settings and adjustments of thebefore returning it to service. The licensee valve parts which affect the setpoint are notmust test pressure relief devices as required by changed, and the requirements in theSection XI and OM-1 following replacement, maintenance procedure to address any unusualrepair, and maintenance. Section XI and OM- conditions that occur during the maintenance1 require that refurbished equipment be testedactivity. The licensee can also considerin accordance with the periodic testing industry experience to determine if changes inrequirements as applicable. OM-1 also the methods of performing this activity arerequires that, before resuming electric power necessary as plants accumulate more data.generation, the licensee shall verify the abilityto open and close for each pressure relief 4.3.6 Safety/Relief Valve Setpointvalve in the BWR main steam system if thisvalve has auxiliary actuating devices and hasbeen maintained or refurbished in place,removed for maintenance and testing, or both,and reinstalled. The licensee shall verify thiscapability by remotely actuating the valve atreduced system pressure. Further set pressureverification is not required (referenceParagraph 3.4.1.1(d) of OM-1).

NRC Recommendation

The staff recommends that, if a licenseechooses to use the jack-and-lap process andnot reverify the set pressure of the valves, itmust determine if the maintenance activity isof an extent that a setpoint test is requiredafter the valve is reassembled and reinstalled. If the jack-and-lap process is controlled suchthat the setpoint will not be affected, thelicensee may not need to perform a test onceagain, other than the remote actuationrequired for BWR main steam safety valves. Because the NRC staff cannot make thisdetermination by evaluating a relief request,relief is neither appropriate nor available forthis activity.

Basis for Recommendation

Action in accord with this recommendationnecessitates determination of the effect of this

Adjustments

The common corrective action for valves is toperform analysis, retest, or a repair orreplacement. However, the most appropriateaction to take may be to adjust the setpoint fora safety relief valve when the setpoint for asafety relief valve is not within the requiredrange of values. The Section XI terminologyfor a repair or replacement activity does notinclude setpoint adjustment; however,Paragraph 1.3.4.1.5(b), "Valves Not MeetingAcceptance Criteria," of OM-1 requires thatany valve exceeding its stamped set pressureby 3 percent or greater shall be repaired orreplaced, the cause of failure determined andcorrected, and the valve verified to havesuccessfully passed a retest before that valveis returned to service.

NRC Recommendation

The staff has determined that setpointadjustment is an acceptable means ofimplementing the corrective actionrequirements of IWV-3514 (1983 Edition) andOM-1. If the out-of-specification conditioncan be corrected by adjusting the setpoint, aSection XI repair or replacement activity isunwarranted.

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Basis for Recommendation that the valve can be put back into service.

A Section XI repair or replacement activity is may be unknown. The Boiling-Water Reactordefined as a repair by welding, brazing, or Owners' Group researched the root cause ofmetal removal of the pressure-retaining parts the setpoint drift in boiling-water reactorof a component or the replacement of safety valves, for example, and recommendedpressure-retaining parts. Although setpoint a change to the valves that may correct theadjustment does not constitute a Section XI condition and prevent recurrence.repair or replacement activity, it may be themost appropriate action to correct a setpoint 4.3.7 Setpoint As-Found Value drift. In Interpretation XI-1-89-65 for SectionXI, the Code committee stated that SectionXI, IWV-3514, does not imply that valve setpoint adjustments are a Section XI repair(IWA-4000). However, the Code committeestated that set point adjustments satisfy therequirements for corrective action specified inIWV-3514. The OM committee also stated inInterpretation 92-2, that in accordance withOM-1, adjustment of the valve setpointwithout valve disassembly can satisfy therequirement for corrective action specified inparagraphs 1.3.3.1.5(b) and 1.3.4.1.5(b) if thecause of failure is determined and corrected asrequired. NOTE: OMc-1994, Part 1, includes"adjustment" as an acceptable action whenvalves do not comply with their acceptancecriteria.

OM-1 requires the "cause" of failure to bedetermined and corrected. It is possible that acondition can be identified and corrected andthe valve setpoint verified to be within theacceptable range such that it may be placed inservice. Once the condition that necessitatedcorrective action has been identified, thelicensee may do further analysis into the "rootcause" of the particular condition, ifnecessary. Most corrective action programsare established to take such an approach. Anexample of the difference between "cause"and "root cause" can be shown for setpointdrift. When the safety valve setpoint has"drifted" above the acceptable limit,adjustments may correct the condition such

However, the root cause of the setpoint drift

The requirements of OM-1 differ significantlyfrom the requirements of PTC-25.3-1976. OM-1 specifies that the valve must be openedat least twice consecutively and be foundwithin Code tolerance each time. Indetermining the as-found setpoint, the licenseeperforms the first lift, compares the result withthe acceptance criteria, and determines theneed for additional tests. The first lift is theone that determines the need for correctiveaction and additional valve testing.

Before completing valve setpoint testing forthe as-left conditions, the licensee mustcomplete at least two consecutive openingswithin the Code tolerance and must not usethe average of the values. In Interpretation92-4, the OM committee stated that paragraph8.1.1.9, "Number of Tests" (steam service forPWRs), of OM-1-1981 refers to as-leftconditions, and that paragraph 8.1.3.8,"Number of Tests" (liquid service), of OM-1-1981 does not refer to as-found conditions. Inother words, paragraphs 8.1.1.9 and 8.1.3.8refer to the as-left set pressure number oftests. NOTE: This interpretation also appliesto similar paragraphs of Section 4 of OM-1 forBWRs.

If no adjustment or maintenance is requiredafter the initial as-found test, and the initial liftmeets the acceptance criteria, it appears thatthe number of tests required by OM-1 for thetwo as-left tests may take credit for the initial

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test. One additional test with acceptable NC/ND-7111: . . . (2) Changes inresults would be required. However, the differential pressure resulting frominitial test must be used to determine thermal imbalances, vaporcorrective actions, if necessary, and testing of condensation, and other similaradditional valves. phenomena, capable of causing an

NRC Recommendation of sufficient duration to be

None. This discussion is for clarification ofexisting requirements.

4.3.8 Vacuum Relief Valves

In OM Interpretation 92-5, as to whether therequirements of OM Part 1, paragraphs7.1.2.3, 7.2.2.3, 7.3.2.4, and 7.4.2.4 apply toall Class 2 and 3 vacuum relief valves whichare required to perform a specific function inshutting down a reactor or in mitigating theconsequences of an accident, the Codecommittee stated that the requirements of Part1 apply only to pressure relief devicesrequired for overpressure protection.

Paragraph 1.1.2(b) of OM-1 states that therequirements apply only to pressure reliefdevices required for overpressure protection. The definition of overpressure protection inOM-1 states that "[t]his term is defined inArticle 7000 of the applicable Subsection ofSection III of the ASME Boiler and PressureVessel Code." The definition of overpressurein ASME B&PVC Section III NC-7111 (Class2) and ND-7111 (Class 3) includes pressurechanges that require relief devices thatfunction to relieve vacuum. The definition isas follows:

internal or external pressure increase

compatible with the dynamicresponse characteristics of thepressure relief devices listed in thisArticle.

Footnote 2 to NC/ND-7150, "AcceptablePressure Relief Devices," states the following:

A pressure relief device is designedto open to prevent a rise of internalfluid pressure in excess of a specifiedvalue due to exposure to emergencyor upset conditions. It may also bedesigned to prevent excessiveinternal vacuum. It may be apressure relief valve, a non-reclosingpressure relief device, or a vacuumrelief valve.

To meet Code requirements, vacuum breakersthat are simple check valves are required to befull-stroke exercised in accordance with IWV-3520 or Paragraph 4.3.2 of OM-10 at thespecified frequency, and are required to betested in accordance with OM-1, if applicable,at the specified frequency to verify thecapability to open and close, the set pressure,and the performance of any accessories forsensing pressure and position. The setpointwould be the pressure (vacuum) force that isthe point where the valve is required to opento relieve vacuum. If the check valve has noleak tight criteria, leak testing is not required. If the requirements for vacuum breakers arenot applicable, only the requirements of OM-10 apply to the check valves.

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NRC Recommendation NRC Recommendation

Paragraph 1.3.4 of OM-1 is not clear as to the The following clarifications may be used byfrequency for testing vacuum breakers, other licensees when applying OM-1-1981 or OM-than those that function as "primary 1-1987 (Note: The paragraph numbers do notcontainment vacuum relief valves." The staff correspond between revisions of the OM-1recommends that licensees test Class 2 and 3 Code and are not cited below.)vacuum breakers, which are within the scopeof OM-1, at the frequency specified in (1) Valve Group–valves of the sameParagraph 1.3.4.1, "Pressure Relief Valves," manufacturer, type, system application,of OM-1. The frequency would, therefore, be and service media.at least once in each ten-year interval, exceptfor any additional testing of check valves as (2) Requirements for Testing Additionalnoted above. Valves–additional valves shall be tested

Basis for Recommendation requirements:

The test frequency is not clearly stated in OM-1; however, the vacuum breakers whichprovide an overpressure protection functionare considered within the scope of OM-1 bythe definition in NC/ND-7111.

4.3.9 Clarifications in OM-1, OMc-1994Addenda to the 1990 Edition of theOM Code

As licensees began applying the requirementsof OM-1, it became clear that clarificationswere needed. The OM working group hasclarified several issues in the 1994 addenda tothe 1990 OM Code. The clarificationsdiscussed below may be used without furtherNRC approval. Other clarifications identifiedby licensees may also be used without furtherNRC approval if it is determined to beclarification only and is documented in the ISTprogram or test procedures, as necessary. Theuse of other portions of the 1994 Addendawhich are more than clarifications wouldrequire relief.

in accordance with the following

a. For each valve tested for which the as-found set pressure (first test actuation)exceeds the greater of either the +tolerance limit of the ownerestablished set-pressure acceptancecriteria or + 3% of valve nameplate setpressure, two additional valves shall betested from that same valve group.

b. If the as-found set pressure of any ofthe additional valves exceed thecriteria noted therin, then all remainingvalves of that same valve group shallbe tested.

c. The Owner shall evaluate the causeand effect of valves that fail to complywith the set-pressure acceptancecriteria or the Owner-establishedacceptance criteria or other requiredtests, such as the acceptance ofauxiliary actuating devices, orcompliance with the Owner's seattightness criteria. Using thisevaluation, the Owner shall determinethe need for testing in addition to theminimum tests specified to address anygeneric concerns which could apply to

NUREG-1482����

valves in the same or other valve incorrect. The test intervals for Class 2 maingroups. steam safety valves were not stated clearly.

(3) Ten-Year Test Interval for Class 2 and 3 The purpose of the seat leakage determinationPressure Relief Valves–the 1994 addenda was not explained. Air or nitorgen at the sameclarifies that the Class 2 PWR main steam temperature may be used without a correlationsafety valves shall be tested in factor.accordance with the test frequencyrequirements for Class 1 valves in both 4.3.10 Valve Groups and Number of Valvesthe initial ten-year interval andsubsequent ten-year intervals (i.e., thetest frequency is based on a five-yearinterval).

(4) Seat Tightness Determination–seattightness is to be determined beforedetermining the set pressure only ifpracticable. This test need not beperformed at the same pressure as thefinal seat tightness test. This test may bequantitative or qualitative depending onthe observed condition (e.g., usingacoustic monitors would be qualitative). This test is primarily for grossdetermination of the as-found seattightness.

(5) Compressible Fluid Service Other thanSteam–air or nitrogen may be substitutedat the same temperature withoutalternative media correlation.

(6) Thermal Equilibrium–Thermalequilibrium need not be verified for liquidservice valves tested at ambienttemperature using a test mediumtemperature.

Basis for Recommendation

The earlier editions of Part 1 contained anumber of editorial errors that have beencorrected by the 1994 Addenda (OMc-1994). A number of clarifications have been made. The definition of valve group previously in afootnote to the testing schedule tables is nowin the definitions section. The previousreferences for addition valve testing were

to be Tested

From questions asked of the OM Part 1working group members, the participants atthe June 1994 meeting in San Jose, California,concluded that fractions of valve numbersresulting from calculating the number ofvalves to be tested are to be rounded to thenext higher whole number for compliance withthe requirements of OM-1. For example, aClass 2 valve in a subsequent ten-year intervalin a valve group by itself would be tested atleast once within any 48 months.

NRC Recommendation

This is for clarification only.

4.4 Miscellaneous Valves

The following issues and NRCrecommendations apply to miscellaneoustypes of valves.

4.4.1 Pressurizer Power-Operated ReliefValve Inservice Testing

Power-operated relief valves (PORVs) wereoften not purchased as safety-related valvesand the function of these valves to providepressure control for plant transients was notconsidered safety-related. The valves werenot considered overprotection devices asrequired by ASME Section III, but many havesince been used as low-temperatureoverpressure protection valves.

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NRC Recommendation shutdown mode, testing of the PORVs is

The staff recommends that licensees be aware 3 months. of previous NRC guidance that the PORVs beincluded in the IST program as Category B Basis for Recommendation valves and tested to the requirements ofSection XI. Recognizing that the PORVs have The NRC guidance on the IST requirementsshown a high probability of sticking open and for PORVs is included in GL 90-06,are not needed for overpressure protection "Resolution of Generic Issue 70, `Power-during power operation, the IWV-3410 Operated Relief Valve and Block Valveprovisions for exercising quarterly during Reliability,' and Generic Issue 94, `Additionalpower operation is "not practical" and, Low-Temperature Overpressure Protection fortherefore, exercising would be performed Light-Water Reactors,' Pursuant toduring cold shutdown conditions. 10 CFR 50.54(f)." In IN 89-32, "Surveillance

Previously approved NRC guidance (see Protection Systems," the NRC discussed thebelow) indicates that because the PORVs stroke times of PORV assumptions made infunction during reactor startup and shutdown plant safety analyses for these PORVs, andto protect the reactor vessel and coolant IST performed for these valves. Stroke timessystem from low-temperature of the valves were unacceptable or were notoverpressurization conditions, they should be measured in the direction required for low-exercised before system conditions warrant temperature overpressure systems to preventvessel protection, and exercised after the exceeding the limits in Appendix G tooperational readiness of the block valves is 10 CFR Part 50. Compliance with theensured, by exercising and stroke timing guidance of GL 90-06 has been coordinatedaccording to the following test schedule: between plants and NRC Project Managers for

(a) Perform full-stroke exercising at eachcold shutdown or, as a minimum, once 4.4.2 Post-Accident Sampling Systemeach refueling cycle.

(b) Perform stroke timing at each coldshutdown, or as a minimum, once eachrefueling cycle.

(c) Perform fail-safe testing at each coldshutdown, or as a minimum, once eachrefueling cycle.

(d) Include the PORV block valves in the ISTprogram and test them quarterly to ensureprotection against a small break LOCAshould a PORV fail open.

(e) If the plant frequently enters cold

not required more often than once every

Testing of Low-Temperature Overpressure-

each plant on a case-by-case basis.

Valves

NUREG-0737, "Clarification of TMI ActionPlan Requirements," Section II.B.3, details therequirements and capabilities of post-accidentsampling systems (PASSs) for sampling boththe reactor coolant and the containmentatmosphere. The PASS consists of pumps andvalves that perform these and possibly otherfunctions. The PASS also includes valves thatperform a containment isolation function.

NRC Recommendation

The IST program applies to any PASS valveswithin the scope of 10 CFR 50.55a and

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Section XI of the ASME Code. Such valves in and can exhibit a differing seat leakage ratethe PASS that perform a containment isolation after each closure, which would challenge thefunction are required to be included in the IST determination of degradation based on theprogram as Category A or A/C and be tested analysis of leakage rate. This problem will beto Code requirements except where relief has further compounded when valves are tested inbeen granted. groups. In measuring the trends in the leakage

The remaining valves in the PASS would obtain information on the condition of antypically be tested as required by the technical individual valve.specifications or other documents and need not be included in the IST program. However, Paragraph IWV-3426 of Section XI requiresthe staff recommends that if the licensee the licensee to assign permissible leakage rateselects to include these valves in the IST for each valve. The Code includes a formulaprogram, a note be included that the testing is for calculating a limit that was not otherwisebeyond the scope of 10 CFR 50.55a. assigned and requires the measured leakage

Basis for Recommendation and to the previous measurements to

Section II.B.3, "Post-Accident Sampling action. However, OM-10 requirements forCapability," of NUREG-0737 details the leak testing allow for testing valves in groups,requirements and capabilities for the licensee's trending leakage rates of the group, and takingPASS, which provides for sampling both the corrective actions if the group leakage limit isreactor coolant and the containment exceeded. atmosphere and consists of pumps and valvesto perform these functions. The PASS also NRC Recommendation contains valves that can isolate containmentwhere the system penetrates containment. Valves may be leak tested in groups as

4.4.3 Multiple Containment Isolation a containment penetration are tested as aValve Leak-Rate Testing

Some plants have containment penetrationswith multiple isolation branches from acommon header which include severalcontainment isolation valves (CIVs). In manycases it is not practical to perform a seatleakage test on each valve. Licenseestypically request relief and propose to test thevalves as a group to verify the leak rate is witha limiting value of leakage assigned to thegroup.

By assigning a limiting value of leakage rate toan individual valve, the licensee can ascertaintrends and determine the best time for repairor replacement, as necessary. Many valvesseat differently each time they are operated

rate of the valve group, the licensee would not

rate be compared to both the permissible value

determine if the valve requires corrective

allowed by OM-10. If two or more valves on

group, limiting leakage-rate values must beassigned to the group for the purpose ofmonitoring the condition of the valve andtaking corrective action. If the limiting valuesare exceeded, the licensee must take actionsto determine the leakage path. The licenseefor a plant that has not updated to OM-10need not obtain relief as the staff hasdetermined it is acceptable to leak test valvesin groups per Paragraph 4.2.2.3 of OM-10 inaccord with 10 CFR 50.55a (f)(4)(iv).

To implement this guidance, the IST programdocuments (or implementing procedures) mustinclude a discussion of the methodology forestablishing leakage limits for valves tested asa group. The licensee would typicallyestablish limits at values sufficient for finding

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leakage from any valve in the group, based on the valves to ensure all pathways werethe diameter of the smallest valve in the group repaired to ensure that leakage is withinor based on a conservative limit established toacceptable limits after maintenance. Thisanother criterion not related to the diameter ofprocedure eliminates unnecessary individualthe valve. If the licensee chooses to valve leakage testing conducted solely to meetimplement this guidance, the licensee must 10 CFR 50.55a. The licensee would obtain nocontinue to comply with the analysis of additional information by testing individualleakage rates and corrective action valves for leakage upon finding little or norequirements of Paragraphs IWV-3426 and leakage during the initial testing of a valveIWV-3427(a) of Section XI or Paragraph group. If the licensee finds increased group4.2.2.3 of OM-10 to the extent practical for leakage, it could assess the leakage pathwaygroup leakage testing. by evaluating individual valves. However, this

Basis for Recommendation of Appendix J to 10 CFR Part 50 and OM-10

The NRC approved the use of OM-10 with the seat of the valve.exceptions for CIVs to require the leakage testrequirements of paragraph 4.2.2.3 of OM-10 4.4.4 Post-Maintenance Testing Afterbe applied to CIVs (see 57 Federal Register34666, August 6, 1992).

In accordance with the Code, the licensee canestablish acceptance criteria with limits for agroup of valves. As noted, the limits can bebased on the smallest size valve in the group,or some other method. For example, at theClinton Power Station, tests were conductedto determine the maximum size of an openingthat could result from a particle that is belowthe system filtration size. The acceptancecriteria are based on the results of these tests. A method that ensures detection of leakagewithin safety analysis limits is acceptable. Fora discussion on the approach used at theClinton Power Station, reference "ModelingValve Leakage," by Steven R. Bell andRandall Rohrscheib, NUREG/CP-0137,"Proceedings of the Third NRC/ASMESymposium on Valve and Pump Testing."

Once a leakage rate exceeds the acceptancecriterion, the leakage pathway would bedetermined using methods structured forindividual valves, perform repairs upondetermining the leakage pathway, and retest

procedure must comply with the requirements

for the direction of the test pressure against

Stem Packing Adjustments andBackseating of Valves to PreventPacking Leakage

Paragraph IWV-3200 of Section XI requiresthat, upon performing maintenance to a valvein a manner that could affect its performance,the licensee shall, before returning the valve toservice, test it to demonstrate that theperformance parameters are within acceptablelimits. Adjusting stem packing is an exampleof maintenance that could affect performance. Paragraph 3.4 of OM-10 contains similarrequirements. Backseating a valve may affectthe performance of the valve.

The licensee may need to adjust the stempacking during power operations when it isimpractical to stroke valves that must remainin position for operations to continue. Recentexamples include main steam isolation valvesand main feedwater isolation valves. If theleakage does not pose a personnel safetyhazard if personnel come in contact with thefluid while adjusting packing, licensees oftenmay adjust the packing without removing thevalves from service. Alternatively,

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backseating of motor-operated valves may be tests can be performed after adjustments.used as a means to stop packing leakagewithout taking a valve out of service. Examples of such valves are the mainExercise caution when performing such feedwater isolation valve and main steammaintenance, as improper backseating or isolation valve, which remain open to continueadjustment of valve stem packing could power operations. The licensee must evaluateadversely affect the valve's functional any data available from previous testing withcapability. the packing torqued to the limit specified and verify that the valve was leak tight andNRC Recommendation previously stroked within acceptable limits

The staff has determined that, as an interim or from previous instances of backseating ameasure, whenever valve stem packing is valve. adjusted or a valve is backseated to preventpacking leakage and a stroke or leak test in theRelief is not appropriate because this action iscurrent plant mode is impractical, the licensee in accordance with the Code requirements ifcan assess the effect of this adjustment or the licensee can demonstrate that thebackseating on the valve's functional performance parameters will not be adverselycapability to open and close and to meet affected; however, packing adjustmentsstroke-time and leakage requirements and beyond the manufacturer's limits may not belater verify the stroke time and leakage rate by performed without both an engineeringa confirmatory test when the plant conditions analysis that shows performance parametersallow testing to be performed. of the valve are not adversely affected, and

The staff has determined that it is acceptable be performed after adjustments. for a licensee to perform an engineeringevaluation of the impact of adjusting valve In implementing this guidance, the licenseestem packing or backseating a valve to must perform a partial-stroke test if practicaldemonstrate that the performance parameters to obtain further assurance that the valve stemare within acceptable limits. If it is necessary is free to move. At the first opportunity whento adjust the stem packing or backseat a valve the plant enters an operating mode in whichto stop packing leakage and if a required testing is allowed, the licensee must test allstroke test or leak rate test is not practical in valves that have packing adjustments or havethe current plant mode, the licensee must been backseated that were made without post-justify by analysis that, among other things, maintenance testing to the extent practical. (1) that the packing adjustment is within The maintenance procedure used to adjust thetorque limits specified by the manufacturer for packing must include the limits, and anythe existing configuration of packing, (2) the changes to the limits must be subject to abackseating does not deform the valve stem, 10 CFR 50.59 review. The licensee wouldand (3) the performance parameters of the typically avoid adjusting redundant valvesvalve are not adversely affected, and a without performing post-maintenance testing. confirmatory test must be performed at the When plant conditions allow, however, thefirst available opportunity when plant licensee must partially stroke the valve toconditions allow testing. Packing adjustments ensure that the stem is not binding. beyond the manufacturer's limits may not be Backseating procedures are to includeperformed without (1) an engineering analysis precautions to prevent stem deformation. and (2) input from the manufacturer, unless

with the packing adjusted to the higher value,

approval of the manufacturer, unless tests can

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To implement this guidance, the licensee must test if it is established that adjustment ofevaluate valves individually unless it has packing will not affect the stroke time of aestablished a valve packing program in which specific valve.designated limits, justified by test data, allowadjustments that do not affect performance Responding to Inquiry IN-92-031, the Codeparameters. Specific or general relief is not committee stated that Subsection IWV-3200appropriate for this activity. If the licensee does not require a test to verify seat leakage ifcannot justify that the packing adjustment the owner establishes that an adjustment ofdoes not adversely affect performance packing will not in any way affect the requiredparameters, there would be no basis for relief seat leakage performance of a specific valve.and the Code requirements must be met. Therefore, the licensee must consider this NRC Information Notice 87-40, "Back Seatingissue for each valve individually. Valves Routinely to Prevent Packing

Basis for Recommendation backseating valves. Both Westinghouse and

The NRC would not require a licensee to shut performing backseating to minimizedown a plant to perform IST unless the deformation to valve stems. Backseating islicensee has no alternative to ensure that the not listed in IWV or OM-10 as an example ofoperational readiness of components is a maintenance activity. The licensee wouldmaintained or unless a safety issue exists. The have to assess the effect of backseating onIST requirements do not prohibit or discourage valve operation and determine if post-the licensee from making limited adjustments maintenance is required. GL 89-10 test resultsto packing to stop a leak that may be may indicate whether backseating of aadversely affecting the valve or surrounding particular valve affects the stroke time of acomponents. Therefore, the licensee can valve. Any information would need to beperform an analysis of the packing adjustment included in an evaluation. The assessmentsand, upon demonstrating that the adjustment would be valve specific.does not adversely affect the stroke time (orleakage rate) such that it would not exceed its4.4.5 Leak-Rate Testing Using OM-10limiting value, can make the adjustmentwithout a post-maintenance stroke timemeasurement (or leakage test). This guidanceapplies only to valves that need adjustmentduring power operation and cannot be fullystroked in the plant operating mode. Theguidance does not apply merely as aconvenience to the licensee and does notsupersede any related guidance associatedwith GL 89-10.

Responding to Inquiry IN-91-045, the ASMESection XI Boiler and Pressure VesselCommittee stated that Subsection IWV-3200of Section XI does not require a stroke-time

Leakage," gives information related to

General Electric had issued guidance on

Requirements

Though the leak-rate testing requirements ofParagraphs 4.2.2.3 of OM-10 and IWV-3420of Section XI differ only slightly, a licenseemay use the requirements of OM-10 formonitoring the leak-rates of valves.

NRC Recommendation

Paragraph 4.2.2.3 of OM-10 specifiesacceptable requirements for implementing aleakage-monitoring program for valves. Thestaff has determined that licensees may updatetheir programs to the requirements of

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Paragraph 4.2.2.3 of OM-10 pursuant to valve is included in actions in emergency10 CFR 50.55a (f)(4)(iv) and meeting all the operating procedures, but is not credited in therequirements of Paragraphs 4.2.2.1 and safety analysis, it does not fall within the4.2.2.3. scope of the IST program; however, such a

Basis for Recommendation appropriate frequency to ensure that it can

The leakage-monitoring requirements of OM- Applicable inservice tests could include10 differ from previous requirements in the exercising (but not stroke timing), leak testing,following areas: and position indication verification, at the

(1) OM-10 allows leak-rate testing for groups Passive manual valves that have positionof valves. indication would be subject to position

(2) OM-10 allows a pressure decay test for determining leakage. NRC Recommendation

(3) OM-10 changes the permissible Codeleakage rate of water from 30D ml/hr to0.5D gpm or 5 gpm (whichever is less),where D is the nominal valve size(diameter) expressed in inches.

(4) OM-10 eliminated the allowance for leaktesting valves (except check valves) ineither direction if the function differentialpressure is 15 psi or less.

These differences are not relaxations of theintent of the Code to monitor for degradingconditions.

4.4.6 Manual Valves

The staff has received questions about therequirements for including manual valves inthe IST programs. The Code includes manualvalves that meet the scope requirements of10 CFR 50.55a. To comply with the Code,exercising requirements for a manual valvemust be in accord with applicable ISTrequirements of IWV or OM-10 if the manualvalve is credited in the safety analysis forbeing capable of being repositioned to shutdown the plant, to maintain the plant in a safeshutdown condition, or to mitigate theconsequences of an accident. If the manual

valve may be periodically exercised at an

move freely for reasons other than IST.

frequency specified in the code, as practical.

indication verification.

None. This discussion clarifies existingrequirements.

4.4.7 Pressure Isolation Valves

Position 4 of GL 89-04 discussed concernswith the adequacy of testing pressure isolationvalves (see Appendix A). The leak ratetesting specified in a plant's technicalspecifications (TS) meets the intent of IWV-3420 and paragraph 4.2.2.3 of OM-10. Asnoted in Position 4, a licensee should ensurethat each pressure isolation valve isindividually leak tested (or the measuredleakage adjusted) in accordance with thedifferential pressure requirements of the Code. If the TS are not detailed enough to ensureindividual valve leak testing, the licensee isresponsible to ensure that the test proceduresare themselves adequate for individual valveleak testing.

NRC Recommendation

A licensee may consider the leakage testingperformed to meet TS requirements to alsomeet IST requirements if the intent of the codeis met (e.g., leakage limits are established,corrective actions taken as required, valvesindividually leak tested). However, a licensee

L(adjusted)L(test)

2dP(maximum)

dP(test)

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must ensure that the test differential pressure requirements of the IST program. Generally,specified in TS, if applicable, is equivalent to the same test will be used to meet both TS andthe "function maximum pressure differential," IST requirements. The major differenceor that the measured leakage is adjusted to the between TS and IST requirements related to"function maximum pressure differential" in the acceptance criteria specified in some TSsaccordance with the formula in the Code between a nominal leakage limit and as upper(IWV-3423(e) or paragraph 4.2.2.3(b)(4) of limit (if allowed by TS, then this is consideredOM-10). acceptable for acceptance criteria for IST).

Basis for Recommendation If the list of pressure isolation valves is

Increasing pressure usually improves theseating of a valve. The code allows that whenleak testing of those types of valves in whichthe service pressure will tend to diminish theoverall leakage channel opening, as bypressing the disk into or onto the seat with Have Other Leak-Tight Safetygreater force, the test differential pressuremay be lower than the function maximumdifferential pressure. The resulting leakage isto be adjusted according to the followingformula from the Code:

where

L = leak anddP = differential pressure.

While NRC has accepted other aspects of theTS, the licensee must ensure that any testingrequirements not specifically detailed in theTS are imposed on the pressure isolationvalves to comply with the code leakage testing

removed from TSs, the leakage testing must bedescribed in detail in the SAR or be identifiedas in accordance with the requirements ofIWV or OM-10.

4.4.8 Containment Isolation Valves Which

Function(s)

Valves which function as containmentisolation valves may have additional safetyfunctions for isolation or functioning of asystem such as emergency core cooling systemfunctions, pressure isolation, or trainseparation to prevent diversion of flow. Theleakage testing for Appendix J may notadequately test that additional functions basedon the pressure or fluid medium. For suchvalves, the requirements of both Appendix Jand OM-10, paragraph 4.2.2.3, or IWV-3420apply.

NRC Recommendation

This information is for clarification only toindicate that multiple safety-related isolationfunctions may require more than one methodof testing.

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5 SUPPLEMENTAL GUIDANCE ON INSERVICETESTING OF PUMPS

5.1 General Pump Inservice TestingIssues

5.1.1 Frequency of Inservice Tests —Comparison of the American Societyof Mechanical Engineers Code toTechnical Specifications

Paragraph (a) of IWP-3400, "Frequency ofInservice Tests," in Section XI of theAmerican Society of Mechanical Engineers(ASME) Boiler and Pressure Vessel Code (theCode) specifies the following:

An inservice test shall be run on eachpump nominally every 3 monthsduring normal plant operation. It isrecommended that this testfrequency be maintained duringshutdown periods if this canreasonably be accomplished,although this is not mandatory. If itis not tested during plant shutdown,the pump shall be tested within 1week after the plant is returned tonormal operations.

Paragraph 5.4, "Pumps in Systems Out ofService," in Part 6 of the ASME/ANSI[American National Standards Institute]Operations and Maintenance Standards (OM-6) includes similar requirements:

For a pump in a system declaredinoperable or not required to beoperable, the test schedule need notbe followed. Within 3 months priorto placing the system in an operablestatus, the pump shall be tested andthe test schedule followed inaccordance with the requirements of

this Part. Pumps which can only betested during plant operation shall betested within 1 week following plantstartup.

In Generic Letter (GL) 87-09, the U.S.Nuclear Regulatory Commission (NRC)clarified its position about the 1-weekallowance of the Code in the Bases section ofTechnical Specification 4.0.5 as follows:

Specification 4.0.5 establishes therequirement that inservice inspectionof ASME Code Class 1, 2, and 3components, and inservice testing ofASME Code Class 1, 2, and 3 pumpsand valves shall be performed inaccordance with a periodicallyupdated version of Section XI of theASME Boiler and Pressure VesselCode and Addenda as required by10 CFR 50.55a. . . . Under the termsof this specification, the morerestrictive requirements of theTechnical Specifications takeprecedence over the ASME Boilerand Pressure Vessel Code andapplicable Addenda. Therequirements of Specification 4.0.4to perform surveillance activitiesbefore entry into anOPERATIONAL MODE or otherspecified condition takes precedenceover the ASME Boiler and PressureVessel Code provision which allowspumps . . . to be tested up to oneweek after return to normaloperation.

Therefore, to comply with GL 87-09 guidance,if the testing schedule is not maintained duringplant shutdowns, the affected pump(s) must be

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tested before entering an operational mode that is, if a licensee uses the dischargewhich requires the pump(s) to be operable. pressure minus the suction pressure toThe only exceptions to this guidance are for calculate a value for differentialthose plants with specific technical pressure].specification allowances that state otherwise.

NRC Recommendation displacement pumps

No new guidance or recommendations arecontained in this section. This sectiondiscusses previously issued guidance andexperience. 5.1.2 Continued Measurement of

Parameters Deleted from OM-6

The following parameters required to bemeasured by Subsection IWP of Section XIwere not included in the requirements of OM-6 for the reasons stated (see NUREG/CP-0111, "Proceedings of the Symposium onInservice Testing of Pumps and Valves," paperentitled "Introduction to ASME/ANSI OMa-1989a Part 6 - Inservice Testing of Pumps inLight-Water Reactor Power Plants - andTechnical Differences Between Part 6 andASME Section XI, Subsection IWP," John J.Zudans, pg. 25-58):

(1) Inlet pressure

This parameter was not included inOM-6 because IWP did not includeacceptance criteria. It is included inIWP to help the owner prepare thetest and recognize that adequatesuction pressure needs to bespecified in the test procedure. OM-6 recognized that the owner isresponsible to address testinglimitations in the procedures."

[NOTE: Inlet pressure values may stillbe needed for the designs that do notinclude differential pressure instruments -

(2) Differential pressure for positive

Subsection IWP requires differentialpressure for both centrifugal andpositive displacement (PD) pumps. Since discharge pressure isindependent of inlet pressure for PDpumps, the requirement has beenchanged to require dischargepressure as the sole indicator ofpump degradation.

(3) Proper lubricant level or pressure

OM-6 does not require thisparameter because the OMcommittee found that it should beobserved as part of regularmaintenance practice, but that it haslittle value for quarterly pumptesting.

(4) Bearing temperature

OM-6 does not specify that bearingtemperature be measured. [Whendegrading conditions occur,][b]earing temperature increasesrapidly until the bearing fails. Themain reason for deleting thisrequirement is that it is unlikely thatbearing failure would be detected bya yearly test. The parameterindicates pending pump bearingfailure only when it is continuouslymonitored, which does not apply forstandby pumps.

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NRC Recommendation NRC Recommendation

The staff has determined that licensees not yetusing OM-6 for IST of pumps may (1)eliminate the parameters deleted from theinservice testing (IST) requirements by OM-6with consideration of the discussion above ofthe reasons why these parameters weredeleted, and (2) include them in amaintenance program, as applicable, pursuantto Section 50.55a (f)(4)(iv) of Title 10 of theCode of Federal Regulations (10 CFR 50.55a(f)(4)(iv)). Relief requests need not besubmitted to delete the measurement of theseparameters which are no longer required to bemonitored. There are no specific relatedrequirements for using this recommendation;however, discharge pressure for positivedisplacement pumps must be monitored withthe specified limits of OM-6. If thisrecommendation is used, the documents forthe IST program must discuss theimplementation.

Basis for Recommendation

The staff reviewed the OM Committee's basisfor deleting these parameters and agrees withits determination as stated above. Eliminatingthe requirements for monitoring certainparameters which have not proven to yielduseful data is consistent with the intent of theIST requirements and is, therefore, notdetrimental to the continued safe operation ofthe plants.

5.2 Use of Variable ReferenceValues for Flow Rate andDifferential Pressure DuringPump Testing

Some designs do not allow for testing at asingle reference point or a set of referencepoints. In these cases it may be necessary toplot pump curves to use as the basis forvariable reference points.

The NRC accepts the use of pump curves forreference values of flow rate and differentialpressure if the licensee clearly demonstrates ina relief request the impracticality ofestablishing a fixed set of reference values. To obtain approval for a proposed method ofevaluating these pump parameters to detecthydraulic degradation and determine pumpoperability, the licensee must demonstrate thatthe acceptance criteria are equivalent to theCode requirements in Table IWP-3100-2 (orTable 3b of OM-6) for allowable ranges usingreference values.

To use this test method, the licensee must plota valid pump characteristic curve fromempirical data or obtain one from the pumpmanufacturer and verify it with measurementstaken when the pump was known to be ingood operating condition. The following is anexample of an acceptable test plan.

Measure pump flow rate with the pumpoperating as found. Plot a point for thisflow rate on the pump characteristiccurve. Measure the pump differentialpressure with the pump operating asfound and compare this differentialpressure to the differential pressureobtained from the pump curve for themeasured flow rate. The pump isoperating in the acceptable range if themeasured differential pressure is from0.93 — 1.02 times the value from thepump curve, and is in the alert range ifthe measured differential pressure is from0.90 — 0.93 or 1.02 — 1.03 times thevalue from the pump curve. The pump isoperating in the required action range ifthe measured differential pressure is lessthan 0.90 or greater than 1.03 times thevalue from the pump curve at the testedflow rate.

Since pump vibration readings may vary

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widely with changes in pump flow rate and (7) When the reference curve may have beendifferential pressure, the licensee must affected by repair, replacement, orpropose a method of evaluating pump routine service, plot a new referencevibration measurements taken with the pump curve or revalidate the previous curve byoperating in possible as-found conditions to conducting an inservice test.ensure that a degraded pump would bedeclared inoperable and repaired. This guidance requires relief because the Code

The licensee must perform the following If the licensee implements this guidance, itelements in preparing pump curves for the must demonstrate the impracticality ofrelief request for IST of pumps: achieving reference conditions for IST. A

(1) Prepare pump curves, or validate the methodology to be used in evaluating thesemanufacturer's pump curves, when the pumps. pumps are known to be operatingacceptably. Basis for Recommendation

(2) When measuring the reference points for Where it is not practical to return to the sameplotting or validating the curve, use flow configuration for each subsequentinstruments at least as accurate (accuracy inservice pump test, it is necessary for theand range) as required by the Code. licensee to establish a method for evaluating

(3) Construct each curve with a minimum of flow systems. This may be the case forfive points, though fewer points may be service water or component cooling wateracceptable for a narrow range. systems and other systems where temperature

(4) Construct the curve with only those During quarterly pump testing, the licenseepoints beyond the "flat" portion (low flow may not be able to manually control each ofrates) of the curves in a range which these local stations and duplicate the overallincludes or is as close as practicable to system reference conditions, as required bydesign basis flow rates. the Code.

(5) Establish acceptance criteria for the Using the manufacturer's pump-specific curvespumps that do not conflict with the for flow and differential pressure, the licenseeoperability criteria for flow rate and may be able to evaluate the pump in as-founddifferential pressure in the technical system conditions. In implementing thisspecifications or the facility safety guidance, the licensee would confirm theseanalysis report. values by performing in-situ testing. Another

(6) If vibration levels vary significantly over range of conditions expected during thethe range of pump conditions, prepare a system's normal operation. It is also importantmethod for assigning appropriate to develop a method of evaluating pumpvibration acceptance criteria for regions vibration measurements taken with the pumpof the pump curve. operating over the range of possible as-found

does not allow for testing using pump curves.

relief request must include a description of the

the operational readiness of pumps in variable

or flow is controlled at a variety of locations.

method would be to plot pump curves over the

conditions, since this is a variable pump

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parameter. By evaluating these measurements [94.6 L/s] and maintain it steadily atof pump vibration, the licensee will ensure approximately 1500 gpm [94.6 L/s]. that a pump which is severly degraded, eitherhydraulically or mechanically, is declared NRC Recommendation inoperable and repaired. Appendix C includesan example of an acceptable relief request The staff has determined that, if the designdemonstrating the use of a pump curve. does not allow for establishing and

In Interpretation 92-6, the OM committee a steady flow rate or differential pressure atstated that reference values and acceptance approximately the set value does not requireband curves over a small range of expected relief for establishing pump curves. Theflow, for IST of a pump where system allowed tolerance for setting the fixedresistance cannot be varied, do not meet the parameter must be established for each caserequirements of OM Part 6. The committee individually including the accuracy of thealso stated that OM Part 6 specifies a instrument and the precision of its display. maximum value for the alert and required This will necessitate verification of the effectaction ranges in Table 3a. of precision on accuracy as considered in the

5.3 Allowable Variance fromReference Points and Fixed-Resistance Systems

Several licensees recently requested relieffrom the Code requirements for fixedreference points. Certain designs do not allowfor the licensee to set the flow at an exactvalue because of limitations in the instrumentsand controls for maintaining steady flow. Thecharacteristics of piping systems in otherdesigns do not allow for flow to be adjusted toexact values. The Code does not allow forvariance from a fixed reference value, statingonly that "[t]he resistance of the system shallbe varied until either the measured differentialpressure or the measured flow rate equals thecorresponding reference value." Licenseeshave requested relief to establish a range ofvalues similar to using a pump curve, but witha very narrow band. For example, onelicensee proposed to use a reference curvewith the tolerance around the selected value tobe ± 2 percent. Plant implementingprocedures may instruct operators to set theflow to 1500 gpm [94.6 L/s]. When this stepis performed, the operator would attempt toset the flow as close as possible to 1500 gpm

maintaining flow at an exact value, achieving

design of the instrument gauge. A totaltolerance of ± 2 percent of the reference valueis allowed without approval from the NRC. For a tolerance greater than ± 2 percent(greater than ± 2 percent may be necessarydepending on the precision of the instrument),a corresponding adjustment to acceptancecriteria may be made to compensate for theuncertainty, or an evaluation would beperformed and documented justifying agreater tolerance. In using this guidance, thevariance and the method for establishing thevariance must be documented in the ISTprogram documents or implementingprocedures.

In 10 CFR 50.55a(f)(4)(iv), the NRC allowsfor the licensee to use later editions of theCode which have been incorporated into10 CFR 50.55a(b). The staff determined thatthe use of Paragraph 5.2(c) of OM-6 forsystems in which resistance cannot be varied(fixed-resistance systems) is acceptablepursuant to 10 CFR 50.55a(f)(4)(iv). Norelated requirements apply other than therequirement to compare the flow and pressureto limits of Table IWP-3100-2, or OM-6 Table3b if using OM-6 limits.

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Basis for Recommendation full-scale range of 0 - 12,000 gpm [0 - 757.1

Section XI does not address the possibility thata flow rate or differential pressure may not becontrollable to an exact value. When theCode specifies that the system resistance bevaried until either the flow or differentialpressure equals the corresponding referencevalue, it does not intend that the "set value"have an acceptable range as stated in TableIWP-3100-2 (OM-6, Table 3b). Theacceptance criteria are only applied to theparameter being determined after theresistance is varied. Licensees recognize thatthe reference value for certain pumps can onlybe achieved within a specified tolerance. Licensees may set the repeatable parameter asclose as possible to the reference value duringeach test rather than treating any variance inthe value with a pump curve. If, uponestablishing trends in data, the licenseedetermines that the parameter varies such thatthe readings are outside the accuracy of theinstrument, it may need to establish pumpcurves and request relief for the applicablepumps (see Section 5.2).

The basis for allowing a variance of ± 2percent from the reference value is paragraphIWP-4150 of Section XI which specifies therequirements for instrument fluctuations. IWP-4150 allows symmetrical dampingdevices or averaging techniques to reduceinstrument fluctuations to within 2 percent ofthe observed reading for values specified inthe implementing procedures. Greatervariances must be justified and acceptancecriteria adjustments made as necessary.

If an analog gauge is used, the precision isdetermined by the increments in the scale andthus could be the limiting factor. Readingswould be acceptable to a degree of precisionno greater than one-half the smallestincrement. For example, a gauge that has a

L/s] has increments of 200 gpm [0 - 12.6 L/s]. The standard reading between incrementswould be no more than 100 gpm [6.3 L/s]. Ifthe indication is between 6000 gpm and 6200gpm [378.5 and 391.2 L/s], the operator could"read" the gauge at only three values: 6000gpm, 6100 gpm, or 6200 gpm, [378.5, 385.0,or 391.2 L/s] depending on whether theindication is in the middle or closer to the linefor either 6000 gpm or 6200 gpm [378.5 or391.2 L/s]. A reading of 6050 gpm [381.7L/s] would not be acceptable for an incrementof 200 gpm [12.6 L/s].

Paragraph 5.2(c) of OM-6 specifies that, if thepump is in a system for which the resistancecannot be varied, the "flow rate and pressureshall be determined and compared to theirrespective reference values." For thesepumps, both the pressure and flowrate aresubject to the acceptance criteria provided inTable IWP-3100-2 (OM-6, Table 3b). 5.4 Monitoring Pump Vibration in

Accord with OM-6

The NRC has received relief requests fromlicensees requesting approval to use therequirements of OM-6 for monitoring pumpvibration. The OMa-1988 edition of OM-6did not include the figure that accompaniesTable 3 in the OMb-1989 addenda. Table 3 inthe 1989 edition is referenced as "Fig. 1" infootnote 2 of Table 3a.

NRC Recommendation

OM-6 allows for monitoring pump vibration inunits of either pump displacement or pumpvelocity and includes acceptance criteria forboth units of measurement. The staff hasdetermined that if the licensee uses OM-6 formonitoring vibration in the IST program, the

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program must include all of the requirements measured vibration velocity indicates thefor such monitoring. Licensees may update mechanical condition of the pumps andtheir programs in accordance with this position reveals pump bearing degradation much morewithout further relief if they meet all related accurately than does measured vibrationrequirements for monitoring vibration in displacement.paragraphs 4.6.1, 4.6.4, 5.2, and 6.1 of OM-6,pursuant to 10 CFR 50.55a (f)(4)(iv). Advantages of measuring vibration velocity in

In following this guidance, the frequency mechanical condition of pumps, with theresponse range of the instrumentation must be exception of low-speed pumps, are widelyas specified in paragraph 4.6.1.6 of OM-6 for acknowledged in the industry. Many nuclearboth low-speed and high-speed pumps unless licensees measure pump vibration velocity tothe licensee demonstrates that the information detect pump degradation and obtain advancedgained at the low frequency response does not warning of incipient pump bearing failure. apply for the bearing design of the pumps. Upon obtaining this advanced warning, theAlthough the instruments in low frequency licensee can plan and prepare for maintenanceresponse ranges were only recently made during scheduled outages instead of sufferingcommercially available and may not be widely losses resulting from unplanned outages toused, the unavailability of instruments is not repair failed critical equipment. sufficient as the sole justification for eitherobtaining relief from the frequency response OM-6 includes a set of allowable ranges forrange requirements of OM-6, or obtaining inservice pump vibration velocity and forapproval of an alternative from the measured pump vibration displacement. requirements. These ranges are based on an evaluation of

Basis for Recommendation for pump vibration velocity established by

By using units of velocity rather than industry, and foreign agencies. The OM-6displacement in measuring vibration in pumps working group considered the data andthat operate above 600 revolutions per minute proposed the ranges of OM-6. The ASME(rpm), the licensee could more rapidly detect Code, Winter 1988 Addenda to the 1986wear in the anti-friction bearing and other edition, and the 1989 edition, reference OM-6types of pump degradation and thus could in its entirety. Effective September 9, 1992,effect repairs in a more timely manner. the NRC approved OM-6 in

Pump bearing degradation results in increasedvibration at frequencies 5 to 100 times the The OM committee changed the frequencyrotational speed of the pump. These high- response range requirements from one-half tofrequency bearing vibrations may not one-third of the minimum pump shaftsignificantly increase the measured rotational speed in order to encompass alldisplacement of pump vibration and could go noise contributors that could indicateundetected. However, the high frequency degradation. Instruments with a frequencyvibration would significantly increase the response range which meets thesemeasured velocity of pump vibration which requirements for slow-speed pumps may becould indicate the need for corrective action commercially available but not widely used. before the bearing fails. Because pump The unavailability of instruments, alone, is notbearings vibrate at high frequencies, the adequate justification for obtaining relief or

lieu of displacement for monitoring

empirical data and various acceptance criteria

U.S. industries, academia, international

10 CFR 50.55a(b).

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approval of an alternative, but may be a major such requests. However, licensees with suchelement of the justification. Additionally, approval must continue to assess the vibrationfrequencies less than running speed may not data and monitor increases that may bebe indicative of problems for certain types of indicative of a change. Recently, at thebearings; however, subharmonic frequencies Catawba plant, a pump with very lowmay be indicative of rotor rub, seal rub. loose vibration experienced an increase in vibrationseals, and coupling damage. The type of levels over three successive tests, thoughbearings and the other subharmonic concerns levels were below the criteria for smooth-would typically be discussed in the running pumps. Upon investigating the causejustification for relief. of the increase, the licensee determined that

Section XI, prior to the 1988 Addenda, replacement. The O&M Committee isrequired that vibration be 'read' in peak-to- assessing whether changes to the OM Code topeak. This could be interpreted to mean that it address acceptance criteria for smooth-is acceptable to measure root-mean-square running pumps are warranted.(rms), convert it to peak-to-peak, and read itas peak-to-peak. OM-6 removed thisambiquity and requires vibration to bemeasured in peak or peak-to-peak. Newerdigital equipment now measures directly inpeak. The NRC mandated ten-year update ofthe ISI and IST programs reflects the need forlicensees to incorporate new technologieswhich have been incorporated into the codesand standards. However, there is continuingdebate with the OM Committee on whetherthe use of rms measurements is acceptable fordetermining the operational readiness ofpumps. The OM Committee recentlyresponsed to an inquiry (File OMI 94-2) whichexplains that the intent of the OM Code (andOM-6) is to allow vibration to be measured inrms and mathematically converted to peakreadings. Readers are cautioned that the codevibration acceptance criteria are in peak orpeak-to-peak units and that the use of rms,without a mathematical conversion, is notacceptable. To comply with the requirements,licensees that use rms values for recordingdata must adjust the limits of OM-6, orconvert the data to peak values.

Several plants have requested an alternative tothe acceptance criteria of OM-6 for smooth-running pumps, and the NRC has approved

the bearing had degraded and required

5.5 Pump Flow Rate andDifferential PressureInstruments

The NRC received relief requests to continueusing instruments that do not meet either therange or accuracy requirements of the Code. The Code requires each analog instrument tohave a full-scale range 3 times the referencevalue or less, and each digital instrument to besuch that the reference values do not exceed70 percent of the calibrated range of theinstrument. OM-10 requires an accuracy of± 2 percent of full-scale for analoginstruments, ± 2 percent of total loop accuracyfor a combination of instruments, or± 2 percent of reading over the calibratedrange for digital instruments.

5.5.1 Range and Accuracy of AnalogInstruments

NRC Recommendation

When the range of a permanently installedanalog instrument is greater than 3 times thereference value but the accuracy of theinstrument is more conservative than the

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Code, the staff will grant relief when the ASME Code committee stated that Section XI,combination of the range and accuracy yields IWP-4110, does not allow the acceptablea reading at least equivalent to the reading instrument accuracy (Table IWP-4110-1) toachieved from instruments that meet the Code be based on the maximum full-scale rangerequirements (i.e., up to ± 6 percent). The use allowed; therefore, for new installation ofof a test gauge in lieu of a permanent instruments, the accuracy and rangeinstrument is acceptable if the reading is at requirements must be met (though, like-for-least equivalent to the Code. When using like instrumentation for existing installations istemporary instruments, the staff recommends not prohibited).that the licensee include in the IST records an instrument number for tracing each instrument When the licensee submits a relief request,and a calibration data sheet for verifying that each group of affected pumps could bethe instruments are accurately calibrated. The addressed separately if the instruments arelicensee need not obtain relief if the temporary permanently installed. A general relief requestinstruments meet the range and accuracy may be acceptable for temporaryrequirements of the Code. If relief is instrumentation. However, the NRC may notrequested, the licensee would typically approve relief if the readings will not bedescribe the effect on each group of equivalent to the Code requirements unlessapplicable pumps and would typically discuss the licensee can demonstrate that the varianceadjustment of acceptance limits to account for is not sufficient for the degradation to bethe inaccuracies. overlooked or replacing the instrument is

Basis for Recommendation compensating increase in the level of quality

Because the IST requirements originally intent of the Code requirements, the NRC mayspecified an instrument range of 4 times the require the licensee to adjust acceptance limitsreference values or less, the permanent to account for the inaccuracies, or theinstruments in many early licensed plants do instruments may need to be replaced.not meet the current requirements of the Code for an instrument range of 3 times the 5.5.2 Range and Accuracy of Digitalreference values or less. The NRC does notgenerally consider installation or replacementof instruments an undue burden, andcompliance with the instrument requirementsin later editions of the Code is not a backfit(see response to Question Group 105 inAppendix A). However, the use of anyavailable instruments that meet the intent ofthe Code requirements for the actual readingwould yield an acceptable level of quality andsafety for testing.

This position applies to the early licensedplants but not for the purchase of replacementinstruments that can be procured to meet thecurrent requirements of the Code. InInterpretation XI-1-89-55, for Section XI, the

excessively burdensome without a

and safety. If the instruments do not meet the

Instruments

NRC Recommendation

Subsection IWP of Section XI does notinclude requirements for digital instrumentsused to monitor the flow rate and differentialpressure of pumps. Thus, it is recommendedthat the requirements in OM-6 for digitalinstruments apply when using suchinstruments for IST. If the requirementscannot be met, relief could be requested. OM-6 requires digital instruments to be accuratewithin ± 2 percent over the calibrated range,which could also be stated as ± 2 percent ofreading. The Code requires that licensee shallselect digital instruments such that the

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reference value does not exceed 70 percent of implementing procedure. The licensee mustthe calibrated range of the instrument. verify that the reading scale for measuring theHowever, if the requirements in OM-6 are level and the calculational method yield anmet, the licensee need not request relief fromaccuracy within ± 2 percent. If directIWP because the requirements of OM-6 for measurements are impractical for other typesdigital instruments result in greater accuracy of pumps with suction from a tank, thethan the requirements in IWP. licensee must apply similar controls. The

Basis for Recommendation differential pressure by obtaining the

The accuracy of digital instruments is or differential pressure transmitter, or bygenerally based on a percentage of the reading determining the difference between thedisplayed. The ranges of most digital pressure at a point in the inlet pipe and theinstruments can be varied, and thus differ pressure at a point in the discharge pipe (IWP-from the ranges for analog instruments. The 4240 and paragraph 4.6.2.2 of OM-6). OM committee recognized these differences, Therefore, the licensee may implement aas indicated in the requirements of OM-6. calculational method without obtaining reliefOM-6 states the requirements for digital because the ASME Code allows for theinstrumentation. The licensees have posed determination of differential pressure from thequestions about the definition of a digital discharge pressure and the pressure in theinstrument. For instance, if an analog pump inlet. To implement this guidance, theinstrument supplies data to a digital display, method of determining the inlet pressure usingthe instrument would be considered digital, a calculational method must meet qualitythough the Code committee could provide a assurance requirements and be included in amore detailed definition. procedure.

5.5.3 Use of Tank or Bay Level to Basis for Recommendation Calculate Differential Pressure

The NRC has received relief requests to use atank or bay level to calculate differentialpressure when inlet pressure or differentialpressure direct measurement is not available.

NRC Recommendation

When inlet pressure gauges are not installed inthe inlet of a vertical line shaft pump, it isimpractical to directly measure inlet pressurefor use in determining differential pressure forthe pump. The staff has determined that, ifthe licensee uses a bay level to calculate thesuction (inlet) pressure as described in IWP-4240 or paragraph 4.6.2.2 of OM-6, thecalculation must be included in the

Code allows the licensee to determine

information from a differential pressure gauge

The method is in accordance with adetermination of differential pressure allowedby the Code. Though the inlet pressure is notdirectly measured, it is "measured" for thepurpose of determining the pressure at a pointin the inlet. By including the calculation inimplementing procedures, the licensee candetermine the differential pressure in a mannerthat is consistent and repeatable from test totest. This method will yield the informationneeded for monitoring the hydraulic conditionof the applicable pumps without the need toinstall suction (inlet) pressure gauges whichmay not be practical, depending on the designlimitations in the inlet of the pump.

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5.5.4 Accuracy of the Flow RateInstrument Loop

As clarified in interpretations to OM-6 andSubsection IWP of Section XI, the accuracyrequirements of analog instruments measuringprocess flow apply only to the calibration ofthe instruments. In determining accuracy, thelicensee is not specifically required to considerattributes such as orifice plate tolerances, taplocations, and process temperatures. However, factors associated with theseattributes which could affect themeasurements include the effects of wear, theeffects of accumulation of dirt or grease on anannubar flow coefficient, and the reversedinstallation of a one-direction orifice plate.

NRC Recommendation

The Code requirements for accuracy ensurethat the instrument loop accuracy is adequatefor monitoring pumps for degradingconditions. The accuracy for analoginstruments specified in Section XI IWP andOM-6 applies only to the calibration of theinstruments. The staff recommends that,when test results indicate that conditions inthe pump or the test circuit have changed,licensees consider corrective action for otherattributes that could affect the overall loopaccuracy of the measurements.

Basis for Recommendation

In Inquiries IN 91-3 (paragraph 4.6.1.1 ofOM-6) and IN 91-037 (Table IWP-4110-1 ofSection XI), the Code committees stated thatthe requirements for the final indication offlow rate on an analog instrument to be within2 percent of full scale of actual process flowrate applies only to the calibration of theinstrument and does not take into accountattributes such as orifice plate tolerances, taplocations, and process temperature.

5.6 Operability Limits of Pumps

Although IWP-3210 discusses the expansionof the ranges for pump acceptance criteria,OM-6 does not include such a provision. TheOM-6 Working Group stated that it could notendorse the IWP philosophy in letting theowner specify any acceptance criteria deemedappropriate when the limits of the applicabletable could not be met. OM-6 requires theacceptance criteria to be met. There areprovisions for the Owner to review the testresults and, if justified, establish newreference values (see paragraph 4.5 of OM-6). Operability limits of pumps must always meet,or be consistent with, licensing basisassumptions in a plant's safety analysis. Reference GL 91-18 for NRC inspectionguidance on operabilitly of components (alsosee Section 7 of this document).

NRC Recommendation

The staff has determined that licensees withprograms established to comply withSubsection IWP may continue to follow IWP-3210 as allowed until the program is updatedwith the values and acceptance criteria fromthe later edition, or portions thereof. WhenSubsection IWP-3210 is used, the Coderequires that the expanded ranges bedocumented in the record of tests, also statingthe basis for finding that the pumpperformance does not demonstrate degradingconditions. Licensees must obtain relief ifexpanded ranges are needed for plants usingOM-6. The request for relief must include thelicensee's basis for the expanded ranges andthe basis for finding that the pumpperformance does not demonstrate degradingconditions. The basis for acceptable pumpperformance, in either case, would pertain tothe pump and not the system, though pumpperformance must meet system requirementsto remain in an analyzed condition.

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Basis for Recommendation requirements for monitoring vibration in

In Section XI Interpretation XI-1-79-19, the recommended to be used with theCode committee clarified the intent of the implementation of expanded ranges, thoughallowance in IWP-3210 by stating that IWP- are not imposed. The use of this guidance3210 refers to Table IWP-3100-2 which must be documented in the IST program.specifies three ranges: Acceptable Range,Alert Range, and Required Action Range. Also note that OM-6, Table 6100-1 has aThe limits within each of these ranges refer to tighter acceptance band for vertical line shaftthe pump and not to the system, that is, the pumps. Refer to Section 5.9.ranges are for the pump test data. If theseranges cannot be met, the Owner can, for Basis for Recommendation example, specify new range limits fordifferential pressure from a range of 0.93 — The OM committee eliminated the high "alert"1.02 to a range of 0.89 — 1.03. Using the lesslimits and increased the high "required action"conservative ranges, the Code requires the limits because hydraulic performance ofowner to show that the overall pump pumps does not improve. The required actionperformance has not degraded from its upper limits ensure that problems withintended function. Establishing limits that are instruments will not be overlooked. more conservative than the Code limits may According to J. Zudan's paper published inbe necessary to ensure that design limits are NUREG/CP-0111, the centrifugal pumpmet. hydraulic acceptance criteria was relaxed in

5.7 Use of OM-6 Table 3b Rangesfor Hydraulic Parameters

OM-6 contains new limits for test parametersand no longer includes the upper limits for the"alert range." The OM committee alsoincreased the "required action range" to 1.10times the reference value.

NRC Recommendation

The staff has assessed the use of the newlimits and determined that an acceptable levelof quality and safety is maintained with thesenew limits, and the new limits are acceptablepursuant to 10 CFR 50.55a (f)(4)(iv) using theranges of Table 3b in OM-6 for the IST ofpumps, or groups of pumps, in an ISTprogram. The requirements of Paragraph 6.0,"Analyses and Evaluation," are consideredrelated requirements. OM-6 and the

accordance with OM-6 (see Section 5.4) are

OM-6 because the vibration requirementsspecified in OM-6 give a better indication ofmechanical condition of the pumps. Therefore, the increased limits for hydrauliccondition are recommended to be used inconcert with the improved monitoring of themechanical condition, though the vibrationmonitoring is not imposed as a specific relatedrequirement. The expanded limits areconsidered acceptable for assessingdegradation; however, it is not acceptable toestablish limits that allow degradation belowthe limits assumed in the safety analyses forthe function of the pumps.

5.8 Duration of Tests

IWP-3500, "Duration of Tests," requires that,before measuring specified parameters, thelicensee run each pump for at least 5 minutesunder conditions as stable as the systempermits. Paragraph 5.6, "Duration of Tests," of

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OM-6 requires only 2 minutes of run time with respectively, based on the fact that "inherentstable pump conditions before obtaining test deficiencies in vibration testing" such thatdata. "degradation will be identified sooner through

NRC Recommendation the "low" required action values for flow rate

The staff has determined that the licensee mayfollow the requirements of Paragraph 5.6 OM-6 for the duration of tests if it determines theshorter duration represents stable operationpursuant to 10 CFR 50.55a (f)(4)(iv). If alicensee elects to use this guidance, the usemust be documented in the IST program. Norelated requirements apply. The NRCrecommends not operating a pump onminimum recirculation (see NRC Bulletin 88-04, "Potential Safety-Related Pump Loss,"and Position 9, "Pump Testing UsingMinimum-Flow Return Line With or WithoutFlow Measuring Devices," of GL 89-04).

Basis for Recommendation

The OM committee stated that a 2-minute runtime is adequate after the pump operationbecomes stable. The staff agrees, particularlyfor pumps tested using a minimum flowrecirculation line.

5.9 Vertical Line Shaft Pumps

The OM Task Group on Pumps has recentlyproposed to define "vertical line shaft pumps"as "a vertically suspended pump, where thepump driver and pumping element areconnected by a line shaft within an enclosingcolumn which contains the pump bearings,making pump bearing vibration measurementsimpracticable." OM-6, Table 6100-1, hastighter acceptance criteria for such pumps(0.93 versus 0.90). NUREG/CP-0111includes a basis for this change, stating thatthe "low" alert range for flow ratemeasurements of vertical line shaft pumps andpositive displacement pumps was changedfrom (0.90 to 0.94)Q to (0.93 to 0.95)Q ,r r

changes in hydraulic parameters." Further,

measurements of vertical line shaft pumpswere change from 0.90 Q to 0.93 Q , and ther r

"low" alert range for differential pressuremeasurements of vertical line shaft pumps waschanged from (0.90 to 0.93)P to (0.93 tor

0.95)P . Additionally, the location specified inr

paragraph 4.6.4(b) of OM-6 for the vibrationmeasurements is stated as the upper motorbearing housing.

NRC Information Notice 94-45, "PotentialCommon-Mode Failure Mechanism for LargeVertical Pumps," discuss inadequacies withthe vibrtion monitoring of vertical line shaftpumps. An informative paper entitled"Inservice Testing of Vertical Pumps," byRobert E. Cornman, Jr., and Kurt E.Schumann, is included in NUREG/CP-0137,"Proceedings of the Third NRC/ASMESymposium on Valve and Pump Testing." OM-6, Table 6100-1, has tigher acceptancecriteria for flow and differential pressure thanwere included in earlier editions of Section XIfor vertical line shaft pumps (.93 versus .90). This change was explained in J. Zudan's paperin NUREG/CP-0111 which states that the"low" alert range for flow rate measurementsof vertical line shaft pumps and positivedisplacement pumps was changed from (0.90to 0.94)Q to (0.93 to 0.95)Q , respectively,r r

based on the fact that "inherent deficiencies invibration testing" such that "degradation willbe identified sooner through changes inhydraulic parameters." Further, the "low"required action values for flow ratemeasurements of vertical line shaft pumpswere change from 0.90 Q to 0.93 Q , and ther r

"low" alert range for differential pressuremeasurements of vertical line shaft pumps waschanged from (0.90 to 0.93)P to (0.93 tor

0.95)P .r

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NRC Recommendation however, the value recorded would be the

The discussion is for information only with norecommended action.

5.10 Adjustments for InstrumentInaccuracies

Another issue of interest to the NRC and tothe industry concerns instrument inaccuracies. For example, technical specifications or thesafety analysis report require a pump toproduce 1000 gpm at 500 psid (design), butthe IST reference values are 1000 gpm (fixed)and 550 psid. The low end of the acceptablerange for differential pressure from OM-6(0.90) would be 495 psid, althoughconservatively set at 500 psid. If this test isalso to prove operability of the pump inaddition to meeting IST requirements, and the2 percent instrument inaccuracies were takeninto account for flow and differential, there isthe possibility that the pump is putting out lessthan the required values. In this example, theinstrument accuracies would be taken intoaccount if they have not been incorporatedwhen the design numbers were developed.

When pump test procedures are developed,limits in the safety analysis cannot be ignored. The requirements for inservice testing arewritten generally. If specific plant limits aremore conservative, to ensure compliance withdesign basis assumptions, such limits must beclearly indicated as the "operability" limits andused for acceptance criteria of IST as well. For example, see Section 5.2, item (5) of theelements listed for using pump curves. Whenobtaining values using instrumentation thatmeets the accuracy requirements specified forthe purpose of data, such as for IST, the valueas read would be used. If a licensee isattempting to perform a critical test, moreaccurate instrumentation may be necessary;

value read if the accuracy of theinstrumentation met the specified accuracy. Only when instruments are used that cannotmeet the specified accuracy for a test wouldan adjustment be necessary to meet the Code. Design analyses most likely do not account forinstrument accuracy readings; however, whenthe pump selection is made, the designergenerally selects from a catalog of availablesizes and chooses one with margin above theanalyses numbers. The "comprehensive pumptesting" approach recently approved forincorporation into the OM Code specifies aninstrument accuracy of 0.5 percent fordifferential pressure, but continues to specify2 percent for flow rate instruments.

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6 REVISED STANDARD TECHNICALSPECIFICATIONS

6.1 Introduction

Section 4 of the technical specifications (TS)for many licensed operating power reactorsincludes a general surveillance requirementfor the inservice testing of pumps andvalves. Several licensees have requestedrevisions to technical specifications toremove unique surveillance requirements forpumps and valves and to add the generalsurveillance requirement for IST. TS 4.0.5states, in part, the following:

4.0.5 Surveillance Requirementsfor inservice inspection and testingof ASME [American Society ofMechanical Engineers] Code Class1, 2, and 3 components shall beapplicable as follows:

a. Inservice inspection of ASMECode Class 1, 2, and 3 componentsand inservice testing of ASMECode Class 1, 2, and 3 pumps andvalves shall be performed inaccordance with Section XI of theASME Boiler and Pressure VesselCode and applicable Addenda asrequired by 10 CFR 50, Section50.55a(g), except where specificwritten relief has been granted bythe Commission pursuant to10 CFR 50, Section50.55a(g)(6)(i).

NOTE: Effective September 8,1992, the requirements forinservice testing were moved fromparagraph (g) to paragraph (f) inSection 50.55a of Title 10 of theCode of Federal Regulations

(10 CFR 50.55a).

The requirements of TS 4.0.5 prohibitlicensees from implementing alternativetesting methods described in IST programrelief requests before receiving U.S. NuclearRegulatory Commission (NRC) approval.

The Bases section of Technical Specification4.0.5 states, in part, the following:

This specification ensures thatinservice inspection of ASMECode Class 1, 2, and 3 componentsand inservice testing of ASMECode Class 1, 2, and 3 pumps andvalves will be performed inaccordance with a periodicallyupdated version of Section XI ofthe ASME Boiler and PressureVessel Code and Addenda asrequired by 10 CFR 50.55a. Relieffrom any of the aboverequirements has been provided inwriting by the Commission and isnot a part of these TechnicalSpecifications.

6.2 History

The industry's codes and standards approvedfor use by the Commission are as stated in10 CFR 50.55a. Before March 15, 1976, theregulations contained no requirements forIST of pumps and valves. The ASME Boilerand Pressure Vessel Code (the Code) firstincluded Subsections IWP and IWV toSection XI in the Summer 1973 Addenda. The rules effective March 15, 1976 (41Federal Register 6256, published February12, 1976), required that an operating licensefor a utilization facility be subject to the

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conditions specified in 10 CFR 50.55a(g), 10 CFR 50.55a(g) by reference in technicalwhich included new requirements for the specifications (1) to avoid duplication ofIST of pumps and valves. The regulations requirements, (2) to alleviate the need forprovided for alternatives to the requirements technical specification changes whenever aif compliance would result in hardship testing program is updated, and (3) towithout a compensating increase in the level simplify the process for obtaining relief fromof quality and safety, or if the proposed impractical ASME Code requirements. alternatives would give an acceptable level of quality and safety. The regulations also The NRC discussed relief requests asprovided for relief from Code requirements follows in the letters to licensees:if a licensee determined that conformancewas impractical for its facility. The Generally, the licensee will knowregulations continue to include these well in advance of the beginning ofprovisions. any inspection period, whether or

After publishing the rules that took effect requirement will be impractical forMarch 15, 1976, the NRC issued letters to his facility. Thus, the licenseelicensees informing them of the rule change should request relief from ASMEand recommending that they propose Code requirements as far astechnical specification changes with the possible in advance of, but not lessfollowing standard statement: than 90 days before, the start of

Inservice testing of ASME Code submittals are particularlyClass 1, Class 2, and Class 3 pumps important for the first 40-monthand valves shall be performed in inservice and 20-month pump andaccordance with Section XI of the valve testing period [NOTE: ThisASME Boiler and Pressure Vessel [testing period] was later changedCode and applicable Addenda as to 120-month intervals for bothrequired by 10 CFR 50.55a(g), inservice inspection and IST.]except where specific written relief because they will enable the NRChas been granted by the NRC staff to evaluate the informationpursuant to 10 CFR 50, Section received from all licensees and50.55a(g)(6)(i). determine which ASME Code

In letters of November 1976, the NRC impractical for various classes offurther discussed the regulation, which plants. Early submittals willrequired updates of the inservice inspection thereby facilitate earlier feedbackprograms at 40-month intervals and the IST to licensees regarding theprograms at 20-month intervals. The NRC acceptability of their requests.suggested that licensees submit requests forrelief from ASME Code requirements as far The NRC Staff recognizes that itin advance as possible of the start of any 20- will not be possible in all cases formonth period for testing pumps and valves a licensee to determine in advancebut at least 90 days before that period. The that any particular ASME CodeNRC stressed the need to incorporate requirement will be impractical for

not a particular ASME Code

the inspection period. Early

requirements may be generally

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his facility. In cases where, during applicable Addenda as required bythe process of inservice testing, 10 CFR 50.55a;certain requirements are found tobe impractical due to unforeseen b. Testing frequencies specified incircumstances, the licensee may Section XI of the ASME Boiler andrequest relief at that time. These Pressure Vessel Code andoccurrences are not expected to be applicable Addenda as follows:many and are expected to result inonly minor changes to an inservicetesting program.

All relief from ASME Coderequirements that are determinedto be impractical for a facility willbe granted in the form of a letterwithin the provisions of§50.55a(g)(6)(i). This writtenrelief should be incorporated intothe document describing theinservice inspection and testingprogram retained by the licensee. .. the written relief itself will notbecome an explicit part of thefacility license . . .

The NRC approved a change to TS 4.0.5 tosimply refer to the regulations. Theadministrative section of the revisedstandard technical specifications includesthe following requirements for IST program:

5.7.2.12 Inservice TestingProgram

This program provides controls forinservice testing of ASME CodeClass 1, 2, and 3 componentsincluding applicable supports. Theprogram shall include thefollowing:

a. Provisions that inservice testingof ASME Code Class 1, 2, and 3pumps, valves, and snubbers shallbe performed in accordance withSection XI of the ASME Boiler andPressure Vessel Code and

ASME Code andapplicable Addenda Required Frequenciesterminology for for performing in-inservice testing service testing activities activities Weekly At least once per 7 daysMonthly At least once per 31 daysQuarterly or every 3 months At least once per 92 daysSemiannually or every 6 months At least once per 184 daysEvery 9 months At least once per 276 daysYearly or annually At least once per 366 daysBiennially or every 2 years At least once per 731 days

c. The provisions of SR[surveillance requirement] 3.0.2are applicable to the aboverequired Frequencies forperforming inservice testingactivities;

d. The provisions of SR 3.0.3 areapplicable to inservice testingactivities; and

e. Nothing in the ASME Boilerand Pressure Vessel Code shall beconstrued to supersede therequirements of any TS.

NOTE: The 25% extension allowed in TS3.0.2 facilitates surveillance scheduling andconsiders plant operating conditions thatmay not be suitable for conducting thesurveillance (e.g., transient conditions orother ongoing surveillance or maintenanceactivities). According to the bases for TS3.0.2 in the revised standard technicalspecifications, the 25% extension is notintended to be used repeatedly merely as anoperational convenience to extend

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surveillance intervals beyond those an updated IST program, the regulationsspecified. GL 87-09 and GL 89-14 allow a licensee up to 12 months after therecommended TS changes related to the beginning of the updated interval to obtainextension for technical specifications which NRC approval of those new Codehave not been updated to the revised requirements which cannot be met and tostandard technical specifications. request relief. The licensee has the burden

6.3 Discussion

In the 1976 letters to licensees, the NRCstaff recognized that situations would arisewhich would put the licensee in a conditionthat is not in strict compliance with the TS4.0.5 requirement to comply with ASMESection XI "except where specific writtenrelief has been granted." Therefore, if TS4.0.5 was interpreted literally, it results in aperiod of noncompliance for situationswhere a test cannot be performed in accordwith the code requirements due toimpractical conditions. For example, the TScould be interpreted to require a shutdownbecause a pump or valve that wouldotherwise require IST and that was thesubject of a relief request must beconsidered inoperable until the NRC grantsrelief from the requirements of ASMESection XI. However, the operability of theequipment should be assessed according tothe guidance in GL 91-18, "Information toLicensees Regarding Two NRC InspectionManual Sections on Resolution of Degradedand Nonconforming Conditions and onOperability." Depending on the results ofthe operability determination, the conflictcould result in the licensee exceeding alimiting condition for operation when thecomponent can meet its functionalrequirements.

The revised standard technical specificationsreflect the position that the licensee mustestablish and implement the program inaccord with 10 CFR 50.55a. For preparing

to demonstrate the impracticality of meetingthe code requirements. The regulations statethat the impracticality of the coderequirements be demonstrated to thesatisfaction of the Commission no later than12 months from the interval start date. Ifduring the interval, a licensee finds animpractical requirement, the licensee mustsubmit a relief requestafter finding the needfor relief. To comply with the regulations,the licensee must obtain NRC approvalpursuant to 10 CFR 50.55a(f)(6)(i) beforeeliminating the test from the IST program. NRC Recommendation

The staff recommends that licensees revisetheir TS to incorporate the revised standardtechnical specifications for IST programs. With the revised standard technicalspecifications incorporated into its TS, uponfinding a Code requirement impracticalbecause of limitations in the design(including prohibitive dose rates),construction, or system configuration, thelicensee would prepare the determinationdescribing the impractical conditions and theapplicable code requirements that cannot bemet. The licensee follows the requirementsin 10 CFR 50.55a(f)(5)(iii) and (f)(5)(iv) ifwithin the initial interval or if within the first12 months of a new interval. If animpractical requirement is identified duringsubsequent intervals and not within the first12 months, the licensee must meet therequirements of 10 CFR 50.55a(f)(5)(iii) andnotify the Commission and submit theinformation supporting the determination ofimpracticality, and obtain NRC's approval

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pursuant to (f)(6)(i), prior to the time that requirement, the licensee may follow thethe next test or inspection is required. requirements of 10 CFR 50.55a(f)(5)(iii). Licensees should follow the guidance in GL Note that the specification does not allow91-18, "Information to Licensees Regarding the licensee to implement alternative testingTwo NRC Inspection Manual Sections on under paragraphs 50.55a (a)(3)(i) and (ii)Resolution of Degraded and Nonconforming until authorized by the Director of the OfficeConditions and on Operability," November of Nuclear Reactor Regulation. The7, 1991, for determining actions to assess the technical specification change will ensureoperability of equipment when an ASME that there is no inconsistency for the 12Code noncompliance is identified. The months following the beginning of a newlicensee should indicate in the submittal of interval.the impracticality determination the date bywhen NRC approval is needed to ensure Basis for Recommendationcompliance with the regulations.

For 120-month updated programs, it isrecommended that relief requests besubmitted prior to the interval start date toallow a period for NRC review 12 monthsafter the interval start date (i.e., submit theupdated program 3 to 6 months prior to thestart date, or earlier).

Upon determining an impractical

When a Code requirement is practical but analternate method is requested pursuant to10 CFR 50.55a(a)(3), approval from theNRC is required before implementing thealternative method of testing (1) proposed toachieve levels of quality and safetyequivalent to those of the Code method or(2) proposed to avoid an undue hardshipwithout yielding a compensating increase inthe level of quality and safety.

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7 IDENTIFICATION OF CODE NONCOMPLIANCE

7.1 Nonconforming Conditions

Generic Letter 91-18 gives guidance on theresolution of degraded and nonconformingconditions. The licensee would follow theguidance in GL 91-18 after finding adegraded or nonconforming condition such 7.2 Design Bases Reviews as finding a component that should be in theIST program. As related to IST, GL 91-18 To continue to follow the GL 91-18defines a "code noncompliance" as either a guidance for nonconforming conditionsmissed surveillance test or the identification while in the process of performing a designof a component that must be added to the bases review, the licensee may write aIST program, and either of these represent a "justification for continued operation" fornonconforming condition. That is, the the design bases review that would describe:"qualification" of the system, subsystem, or (1) the process for performing thecomponent (SSC) is being called into programmatic review, (2) the actions to bequestion. A nonconforming condition that taken when a component or test that was notdeals with the qualification of a component previously in the IST program is identified,must be dealt with at a level of quality and (3) the schedule for performing the testingsafety commensurate with the safety once the need has been identified. Thisfunction of the component. To resolve the design bases review process description/qualification issue, the licensee may prepare justification for continued operability woulda "justification for continued operation," not be applicable to nonconformanceswhile corrective action is being taken. identified outside such a process. AnCorrective action may include processing a example of a letter prepared by a licenseerequest for exigent code relief or preparing a for such a review is given in Appendix F;cold shutdown or refueling outage however, while the example was written atjustification. the completion of the IST program scope

The "operability" of the component is a performing the testing, it is recommendedseparate issue. If a licensee determines that, that the document be developed prior to orbecause of a nonconforming condition, a at the beginning of the review.component is inoperable, the requirements

of technical specification limiting conditionsfor operation must be met. At that time, alicensee may determine that testing is not inthe best interest of safety and seekenforcement discretion from the NRC.

review and gives the schedule for

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8 REFERENCES

American Society of Mechanical Engineers, IWV-3512 and IWV-3514; Valve SetBoiler and Pressure Vessel Code, Section Point Adjustments," File Number IN90-III, Division 1, Subsection NC, "Class 2 002, January 15, 1991.Components," New York, 1986.

--- Boiler and Pressure Vessel Code, 442, "1977 Addendum to ANSI/ASMESection III, Division 1, Subsection ND, PTC 25.3-1976, Safety and Relief"Class 3 Components," New York, 1986. Valves, Class 1, 2, 3, and MC,"

--- Boiler and Pressure Vessel Code, NewYork Section XI, "Rules for Inservice

Inquiry IN91-045, "Section XI, IWV- Components," Summer 1973 Addenda3200; Valve Stroke-Time Test," March through 1989 Edition.10, 1992.

Inquiry IN92-025A, "Section XI, IWV- Requirements," 1986.3410 and IWV-3520; Valve Testing —Extended Shutdown," February 9, Section XI, Subsection IWP, "Inservice1993. Testing of Pumps in Nuclear Power

Inquiry IN92-031, "Section XI, IWA- through 1989 Edition.3200; Valve Testing — Adjustment ofPacking," August 27, 1992. Section XI, Subsection IWV, "Inservice

Interpretation XI-1-79-19, "Section XI, Plants," Summer 1973 AddendaDivision 1, Operability Limits of through 1989 Edition.Pumps, IWP-3210," File Number BC-79-150, December 12, 1979. Section XI, Code Case N-415,

Interpretation XI-1-89-10, "Section XI, Relief Devices," September 5, 1985.Division 1, IWV-3300, IWV-3412, andIWV-3413; Valve Exercising Test," File Section XI, Code Case N-427, "CodeNumber IN88-015, November 14, 1988. Cases in Inspection Plans," December

Interpretation XI-1-89-55, "Section XI,IWP-4110, Table IWP-4110-1, and Section XI, Code Case N-444,IWP-4120; Pump Instrument "Preparation of Inspection Plans,"Accuracy," File Number IN90-021, December 7, 1987.January 9, 1991.

Interpretation XI-1-89-65, "Section XI, "Alternative Rules for Pump Testing,"

Section III, Division 1, Code Case N-

February 23, 1987.

Inspection of Nuclear Power Plant

Section XI, Subsection IWA, "General

Plants," Summer 1973 Addenda

Testing of Valves in Nuclear Power

"Alternative Rules for Testing Pressure

5, 1985.

Section XI, Code Case N-465,

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November 30, 1988. Paragraphs 1.3.3.1.5, 1.3.4.1.5, and

Section XI, Code Case N-472, "Use of — Corrective Action," File NumberDigital Readout and Digital OMI-91-2, March 24, 1992.Measurement Devices for PerformingPump Vibration Testing," March 8, Interpretation 92-4, "OM-1-1981,1989. Paragraphs 8.1.1.9 and 8.1.3.8; Set

Section XI, Code Case N-473, 91-3d, March 24, 1992."Alternate Rules for Valve Testing,”March 8, 1989. Interpretation 92-5, "OM-1987 With

--- Performance Test Codes, PTC 25.3- Paragraphs 1.1.2, 7.1.2.3, 7.2.2.3,1976, "Safety and Relief Valves," New 7.3.2.4, and 7.4.2.4; Applicability —York, 1976. Class 2 and 3 Vacuum Relief Valves,"

American Society of Mechanical Engineers/ 1992.American National Standards Institute(ASME/ANSI), Operations and Interpretation 92-6, "OM-1987 WithMaintenance Standards, New York, 1987. Addenda Through OMc-1990, Part 6,

--- Operations and Maintenance Standards, Testing," File Number OMI-91-5,New York March 24, 1992.

Part 1 (OM-1), "Requirements for Interpretation 93-1, "OM-1987 WithInservice Performance Testing of OMa-1988 Addenda, Part 10, paras.Nuclear Power Plant Pressure Relief 4.2.1 and 4.3.2; OM Code-1990, ISTCDevices," 1981 and 1987. 4.2 and ISTC 4.5; Valve Testing —

Part 6 (OM-6), "Inservice Testing of Number OMI-92-4, January 7, 1993.Pumps in Light-Water Reactor PowerPlants," 1988 Addenda and 1989 General Electric, Service Information LetterAddenda. 477, "Main Steam Isolation Valve Closure,"

Part 10 (OM-10), "Inservice Testing ofValves in Light-Water Reactor Power Oak Ridge National Laboratory, "UtilityPlants," 1988 Addenda. Survey PWR Safety Injection Accumulator

American Society of Mechanical Engineers/ ORNL/NRC/LTR-94/04, February 17, 1994. American National Standards Institute(ASME/ANSI), Code for Operation and U. S. Code of Federal Regulations, Title 10,Maintenance of Nuclear Power Plants, "Energy," Chapter 1, Part 50, "DomesticNew York, 1990. Licensing of Production and Utilization

Interpretation 92-2, "OM-1-1981,

1.3.1.3; Adjustment of Valve Setpoint

Pressure Testing," File Number OMI-

Addenda Through OMc-1990, Part 1,

File Number OMI-91-4, March 24,

Paragraph 5.2 and Table 3a,; Pump

During Extended Shutdown," File

December 13, 1988.

Tank Discharge Check Valve Testing,"

Facilities."

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U. S. Nuclear Regulatory Commission, Systems," March 26, 1982.Federal Register, Vol. 41, No. 30, "Codesand Standards for Nuclear Power Plants" --- Information Notice 83-03, "Check Valve(10 CFR Part 50), February 12, 1976, p. Failures in Raw Water Cooling System of6256. Diesel Generators," March 10, 1983.

--- Federal Register, Vol. 57, No. 3152, --- Information Notice 83-54, "Common"Codes and Standards for Nuclear Power Mode Failure of Main Steam IsolationPlants" (10 CFR Part 50), August 6, 1992, p. Nonreturn Check Valves," August 11, 1983.34666.

--- "Generic Evaluation of Feedwater Inservice Testing of Main Steam IsolationTransients and Small Break Loss-of-Coolant Valves," October 30, 1985.Accidents in GE-Designed Operating Plantsand Near-Term Operating Licensee --- Information Notice 86-50, "InadequateApplications," January 1980. Testing to Detect Failures of Safety-Related

--- Generic Letter 87-09, "Sections 3.0 and 18, 1992.4.0 of the Standard Technical Specifications(STS) on the Applicability of Limiting --- Information Notice 87-01, "RHRConditions for Operation and Surveillance [Residual Heat Removal] ValveRequirements," May 4, 1987. Misalignment Causes Degradation of ECCS

--- Generic Letter 89-04, "Guidance on [Pressurized-Water Reactors]," January 6,Developing Acceptable Inservice Testing 1987.Programs," April 3, 1989.

--- Generic Letter 89-10, "Safety-Related Valves Routinely to Prevent PackingMotor-Operated Valve Testing and Leakage," August 31, 1987.Surveillance," June 28, 1989.

--- Generic Letter 90-06, "Resolution of Inservice Testing Program Deficiencies,"Generic Issue 70, `Power-Operated Relief August 29, 1988.Valve and Block Valve Reliability,' andGeneric Issue 94, `Additional Low- --- Information Notice 89-32, "SurveillanceTemperature Overpressure Protection for Testing of Low-Temperature Overpressure-Light-Water Reactors,' Pursuant to Protection Systems," March 23, 1989. 10 CFR 50.54(f)," June 20, 1990.

--- Generic Letter 91-18, "Information to of Borg-Warner Pressure Seal Bonnel CheckLicensees Regarding Two NRC Inspection Valves Caused by Vertical Misalignment ofManual Sections on Resolution of Degraded Disk," August 31, 1989.and Nonconforming Conditions and onOperability," November 7, 1991. --- Information Notice 91-56, "Potential

--- Information Notice 82-08, "Check Valve Atmosphere," September 19, 1991.Failures on Diesel Generator Engine Cooling

--- Information Notice 85-84, "Inadequate

Pneumatic Components or Systems," June

[Emergency Core Cooling System] in PWRs

--- Information Notice 87-40, "Back Seating

--- Information Notice 88-70, "Check Valve

--- Information Notice 89-62, "Malfunction

Radioactive Leakage to Tank Vented to

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--- Information Notice 91-74, "Changes in Feedback Report - Solenoid-Operated ValvePressurizer Safety Valve Setpoints Before Problems," Vol. 6, February 1991.Installation," November 25, 1991.

--- Information Notice 94-08, "Potential for Digest," issued annually.Surveillance Testing to Fail to Detect anInoperable Main Steam Isolation Valve," --- NUREG/CP-0111, "Proceedings of theFebruary 1, 1994. Symposium on Inservice Testing of Pumps

--- Information 94-44, "Main Steam Isolation Valve Failure to Close on Demand --- NUREG/CP-0123, "Proceedings of theBecause of Inadequate Maintenance and Second NRC/ASME Symposium on PumpTesting," June 16, 1994. and Valve Testing, July 1992.

--- "Minutes of the Public Meetings on --- NUREG/CP-0123, "Proceedings of theGeneric Letter 89-04," October 25, 1989. Second NRC/ASME Symposium on Pump

--- “NRC Inspection Manual” (sections November 1992. published periodically).

Inspection Procedure 73756, "Inservice Third NRC/ASME Symposium on Valve andTesting of Pumps and Valves," March Pump Testing," July 1994.16, 1987.

Part 9900, "Technical Guidance - Evaluation of Surveillance Test IntervalsMaintenance - Voluntary Entry into Including Test-Caused Risks," March 1992.Limiting Conditions for OperationAction Statements to Perform --- Regulatory Guide 1.26, "Quality GroupPreventive Maintenance," Classifications and Standards for Water-, April 18, 1991. Steam-, and Radioactive-Waste-Containing

Temporary Instruction 2515/110, Revision 3, February 1976."Performance of Safety-Related CheckValves," November 19, 1992. --- Regulatory Guide 1.147, "Inservice

Temporary Instruction 2515/114, ASME Section XI Division 1," Revision 11,"Inspection Requirements for Generic October 1994.Letter 89-04, Acceptable InserviceTesting Programs," January 15, 1992. --- SECY-77-439, "Single Failure Criterion,"

--- NUREG-0737, "Clarification of TMIAction Plan Requirements," November --- SECY-92-223, “Resolution of Deviations1980. Identified during the Systematic Evaluation

--- NUREG-1275, "Operating Experience

--- NUREG-1350, "NRC Information

and Valves," October 1990.

and Valve Testing," Supplement 1,

--- NUREG/CP-0137, "Proceedings of the

--- NUREG/CR-5775, "Quantitative

Components of Nuclear Power Plants,"

Inspection Code Case Acceptability —

August 17, 1977.

Program,” June 19, 1992.

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--- "Standard Technical Specifications for Meetings on Generic Letter 89-04,General Electric Boiling Water Reactors September 26, 1991.(BWR/5)," Revision 3, Fall 1980.

--- "Supplement to Minutes of the Public September 15, 1994. --- Letter, W. T. Russell to R. K. Buckles,

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APPENDIX A

POSITIONS, QUESTIONS, RESPONSES, AND CURRENT CONSIDERATIONS REGARDING

GENERIC LETTER 89-04

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Staff Positions In Generic Letter 89-041 Full Flow Testing of Check Valves

2 Alternative to Full Flow Testing of Check Valves

3 Back Flow Testing of Check Valves

4 Pressure Isolation Valves

5 Limiting Values of Full-Stroke Times for Power-Operated Valves

6 Stroke Time Measurements for Rapid-Acting Valves

7 Testing Individual Scram Valves for Control Rods in Boiling Water Reactors

8 Starting Points for Time Periods in Technical Specification Action Statements

9 Pump Testing Using Minimum-Flow Return Lines With or Without FlowMeasuring Devices

10 Testing Containment Isolation Valves

11 Scope of Inservice Testing Programs

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NRC STAFF POSITION 1,“FULL FLOW TESTING OF CHECK VALVES”

Section XI of the ASME Code requires (4) A description of the instrumentationcheck valves to be exercised to the positions used and the maintenance andin which they perform their safety functions. calibration of the instrumentation,A check valve's full-stroke to the openposition may be verified by passing the (5) A description of the basis used to verifymaximum required accident condition flow that the baseline data has beenthrough the valve. This is considered by the generated when the valve is known tostaff as an acceptable full-stroke. Any flow be in good working order, such asrate less than this will be considered a recent inspection and maintenance ofpartial-stroke exercise. A valid full-stroke the valve internal [components], andexercise by flow requires that the flowthrough the valve be known. Knowledge of (6) A description of the basis for theonly the total flow through multiple parallel acceptance criteria for the alternativelines does not provide verification of flow testing and a description of correctiverates through the individual valves and is not actions to be taken if the acceptancea valid full-stroke exercise. criteria are not met.

Full flow testing of a check valve as An acceptable alternative to this full-described above may be impractical to stroke exercising requirement is statedperform for certain valves. It may be in position 2 below.possible to qualify other techniques toconfirm that the valve is exercised to the Questions and Answers for Position 1position required to perform its safetyfunction. To substantiate the acceptabilityof any alternative technique for meeting theASME Code requirements, licensees must asa minimum address and document thefollowing items in the IST program:

(1) The impracticality of performing a fullflow test,

(2) A description of the alternativetechnique used and a summary of theprocedures being followed,

(3) A description of the method and resultsof the program to qualify the alternativetechnique for meeting the ASME Code,

Question Group 1

Questions

Item 1 of Attachment 1 to the generic letterrequests that flow through a check valve beknown for a valid full-stroke exercise test. Does this mean a direct flow indication anda recorded flow rate is [sic] the onlyacceptable method for the test? Forexample, BWR minimum flow lines are notinstrumented with flow indicators.

Is direct flow rate instrumentation requiredfor verification of full-stroke capability forall check valves? For example, the dieselcooling water check valves?

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Verifying full flow through small check Responsevalves in auxiliary systems or gas systems istypically impractical. As an alternate, willthe NRC accept a qualitative evaluation ofsystem response or performance in the placeof flow measurements?

For check valves where design accident flowis not specified, what guidance can you givefor full-flow testing?

Response

Any quantitative measure that has break. Consequently, that flow path isacceptance criteria that demonstrate the restricted or throttled to minimize significantrequired flow through the check valve may diversion of flow. The Technicalbe used to satisfy the full-stroke Specification requirement was not intendedrequirement. An indirect measure of flow to verify individual check valve operability. may be acceptable. For example, a change The licensee is expected to justify the use ofin tank level over a specified period could be a test method that does not verify full strokeused. In another case, the acceptance of individual check valves. criterion could be based on a change in flowrate of an instrumented line when flow isadmitted from a non-instrumented linecontaining the check valve being tested. Inany event, some form of quantitative criteriashould be established to demonstrate full-stroke capability.

Question Group 2

Questions valves in the lines are full-stroke exercised.

Why isn't knowledge of total flow throughmultiple parallel lines acceptable, when thetotal flow through each path was knownwhen it was established? Questions

Regarding full flow testing of check valves,why is knowledge of total flow throughparallel flow lines unacceptable? This seemsto challenge conservative TechnicalSpecification requirements for flowbalancing.

The objective of inservice testing is toevaluate and investigate the possibility ofdegradation of components and to takecorrective action before the components fail. Verification of total header flow rate mightnot identify a problem, developing oroccurring, with an individual check valve inone of the parallel flow paths. With respectto the balancing of flow, the TechnicalSpecification requirement is based on theflow from one loop being lost through a

Current Considerations

In a safety evaluation of January 24, 1992(Docket 50-334), the NRC informed theDuquesne Light Company of the results ofan evaluation of flow through parallel linesand stated a flow test through parallel lineswithout individual flow measurement maynot be sufficient to indicate that the check

(See Section 4.1.2).

Question Group 3

Can check valves with external operatorsand position indicators be tested only withthese devices and never exercised with flowor disassembled?

Is it the intent of the NRC to require full-stroke flow testing of all check valves or is itacceptable to perform manual exercising andpartial stroke testing of check valves as

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permitted by IWV-3522(b)? Response

Position 1 implies that the only methodacceptable to the NRC for full strokeexercising is a full flow test. No mention ismade of check valves with external featureswhich can be used for full stroke exercising. Do the 6 criteria presented have to beaddressed in the IST program to justify usingan external operator?

Response

The ASME Code in IWV-3522(b) allows fullstroke testing of check valves either withflow or with a mechanical exerciser. Fullflow testing is preferable where practical,but Position 1 of Generic Letter 89-04 wasnot intended to imply that the ASME Codeprovisions for mechanical exercising werenot acceptable. Such mechanical exercisingis clearly acceptable and is certainly pre-ferable to valve disassembly as a means ofensuring valve operability. If an externaloperator is used to exercise a check valve,the provisions of IWV-3522(b) must be met,but the six criteria in Position 1 of thegeneric letter need not be addressed.

Current Considerations

Paragraph 4.3.2.4(b) of OM-10 addressesthe use of mechanical exercisers for checkvalves. (See Section 4.1).

Question Group 4

Questions

What is considered the maximum required differential pressure across a valve. (Seeaccident condition flow? Section 4.1).

In reference to Items 1 and 2 of Attachment1, please clarify the term "maximumrequired accident condition flow."

The phrase "maximum required accidentcondition flow" is intended to mean at leastthe largest flow rate for which credit is takenin a safety analysis for this component inany flow configuration. The safety analysesare those contained in the plant's final safetyanalysis report (FSAR), or equivalent, butare not limited to the accident and transientanalyses. Question Group 5

Question

Is it the intent of the stated position ofAttachment 1 that a satisfactory test of avalve in the open direction requires onlymeasurement of full accident flow throughthe valve and not the measurement ofdifferential pressure (with associatedacceptance criteria) as per IWV-3522(b)?

Response

The ASME Code does not require themeasurement of valve differential pressurewhen exercising check valves with flow. Itshould be recognized, however, that such ameasurement might provide usefulinformation for evaluating the condition ofthe valve.

Current Considerations

Certain test methods for verifying the full-stroke of check valves necessarily involvemeasurement of both the flow and

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Question Group 6 Response

Question The full flow test is intended to demonstrate

For check valves which are never requiredto open fully (i.e., thermal expansion orsiphon breakers), verification of design(safety) function is the testing required forforward flow. Is this correct?

Response

In addition to verifying its safety functionperformance, quantifiable acceptancecriteria should be developed for the testingof these components. For example, apressure decay test with specifiedacceptance criteria would be considered areasonable test.

Current Considerations

Verifying that the system is full is also an In reference to Item 1.3 of Attachment 1,acceptable means for verifying that the please clarify what the NRC would expect akeep-fill check valves are capable of "qualification program" to include (i.e., howopening to provide flow when necessary. extensive). (See Section 4.1.1).

Question Group 7

Questions that, where full flow testing is impractical, it

In reference to Item 1 of Attachment 1, fornon-parallel full flow test, does the flowobtained need to be documentedquantitatively, or can it be qualitative (i.e.,greater than _____ gallons per minute)?

What is an acceptable flow condition when,for example, the safety analysis requires 250gallons per minute (gpm) flow but 600 gpmcan be delivered? Would passing greaterthan, or equal to, 250 gpm be a valid fullflow test, or would 600 gpm need to bedelivered?

that the necessary flow rate can be achievedand to detect any degradation of the checkvalve. Therefore, acceptance criteria for thetest should involve more than theachievement of flow above a minimum rate. The acceptance criteria should also includethe allowable variation of test results. Toenable that test results to be compared, theinitial parameters for the test should bestandardized to the maximum extentfeasible. The acceptance criteria for the fullflow test and the bases for those criteriashould be documented and available forreview by NRC inspectors.

Question Group 8

Question

Response

Position 1 of Generic Letter 89-04 indicates

might be possible to qualify other techniquesto confirm that the check valve is exercisedto the position required to perform its safetyfunction. One of the stated conditions forthis approach is that the licensee shoulddescribe the test method and results of theprogram to qualify the alternate techniquefor meeting the ASME Code. The languageof Position 1 in this regard was chosen toallow the licensees flexibility in qualifyingalternatives to full flow testing. In general,the licensee should demonstrate that thealternate test is quantifiable and repeatable. The alternate test should also meet the intentof the ASME Code. This qualification of thealternate test should be documented by the

NUREG-1482 #��

licensee and available for review by NRC However, with the progress made ininspectors. The Nuclear Industry Check developing and using nonintrusive testingValve Group (NIC) is said to be techniques, the staff recommends thatinvestigating the qualification of various licensees investigate and employ thesetesting techniques, such as ultrasonics and techniques where practical. The criteriaradiography for check valves. The results of listed in Position 1 could be applied to thethose and other industry efforts might be of nonintrusive techniques. Further guidancevalue to the individual licensee in providing and requirements for the use of nonintrusivefor the use of alternatives to full flow techniques are being incorporated into thetesting. OM codes and standards by the OM-22Current Considerations for Position 1 Working Group on check valves. (See

The guidance established for Position 1remains valid for inservice testing.

Section 4.1).

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NRC STAFF POSITION 2ALTERNATIVE TO FULL-FLOW TESTING

OF CHECK VALVES

The most common method to full-stroke and inspection may be performed duringexercise a check valve open (where disk reactor refueling outages. Since this fre-position is not observable) is to pass the quency differs from the Code requiredmaximum required accident flow through the frequency, this deviation must bevalve. However, for some check valves, specifically noted in the IST program.licensees cannot practically establish or verifysufficient flow to full-stroke exercise the (c) Where the licensee determines that it isvalves open. Some examples of such valves burdensome to disassemble and inspectare, in PWRs, the containment spray header all applicable valves each refuelingcheck valves and combined LPSI [low- outage, a sample disassembly andpressure safety injection] and safety injection inspection plan for groups of identicalaccumulator header check valves and, in valves in similar applications may beBWRs, the HPCI or RCIC check valves in the employed. The NRC guidelines for thispump suction from the suppression pool. In plan are explained below:most commercial facilities, establishing designaccident flow through these valves for testing The sample disassembly and inspectioncould result in damage to major plant program involves grouping similarequipment. valves and testing one valve in each

The NRC staff position is that valve The sampling technique requires thatdisassembly and inspection can be used as a each valve in the group be the samepositive means of determining that a valve's design (manufacturer, size, modeldisk will full-stroke exercise open or of number, and materials of construction)verifying closure capability, as permitted by and have the same service conditionsIWV-3522. If possible, partial valve stroking including valve orientation. quarterly or during cold shutdowns, or after Additionally, at each disassembly thereassembly must be performed. licensee must verify that the dis-

The staff has established the following stroking and that the internals of thepositions regarding testing check valves by valve are structurally sound (no loosedisassembly: or corroded parts). Also, if the

(a) During valve testing by disassembly, the capability of the valve, the disk shouldvalve internals should be visually be manually exercised.inspected for worn or corroded parts, andthe valve disk should be manually A different valve of each group isexercised. required to be disassembled, inspected,

(b) Due to the scope of this testing, the each successive refueling outage, untilpersonnel hazards involved and system the entire group has been tested. If theoperating restrictions, valve disassembly disassembled valve is not capable of

group during each refueling outage.

assembled valve is capable of full-

disassembly is to verify the full-stroke

and manually full-stroke exercised at

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being full-stroke exercised or there is to longer than once every 6 years, licenseesbinding or failure of valve internals, should develop the following information:the remaining valves in that groupmust also be disassembled, inspected, (a) Disassemble and inspect each valve in theand manually full-stroke exercised valve grouping and document in detail theduring the same outage. Once this is condition of each valve and the valve'scompleted, the sequence of capability to be full-stroked.disassembly must be repeated unlessextension of the interval can be (b) A review of industry experience, forjustified. example, as documented in NPRDS,

Extending the valve sample disassembly and similar service.inspection interval from disassembly of onevalve in the group every refueling outage or (c) A review of the installation of each valveexpanding the group size would increase the addressing the "EPRI Applicationstime between testing of any particular valve in Guidelines for Check Valves in Nuclearthe group. With four valves in a group and an Power Plants" for problematic locations.18-month reactor cycle, each valve would bedisassembled and inspected every six years. IfQuestions and Answers for Position 2 the fuel cycle is increased to 24 months, eachvalve in a four-valve sample group would bedisassembled and inspected only once every 8years.

Extension of the valve disassembly/inspectioninterval from that allowed by the Code(quarterly or cold shutdown frequency) tolonger than once every 6 years is a substantialchange which may not be justified by thevalve failure rate data for all valve groupings. When disassembly/ inspection data for a valvegroup show a greater than 25% failure rate,the licensee should determine whether thegroup size should be decreased or whethermore valves from the group should bedisassembled during every refueling outage.

Extension of the valve disassembly/inspectioninterval to one valve every other refuelingoutage or expansion of the group size abovefour valves should only be considered in casesof extreme hardship where the extension issupported by actual in-plant data fromprevious testing. In order to support extensionof the valve disassembly/inspection intervals

regarding the same type of valve used in

Question Group 9

Question

Does the Generic Letter Attachment 1, item2c use of "orientation" refer to physicalorientation (e.g., horizontal or vertical) orplant orientation?

Response

Orientation, as used in Generic Letter 89-04,refers to the physical orientation (horizontal orvertical) as well as the physical relationship tomajor components. For example, a checkvalve at the discharge of a pump has adifferent orientation than one at the pumpsuction.

Question Group 10

Questions

When manually exercising per position 2c, isthis done per Code or just a physical stroke

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checking for binding? Disassembly, together with inspection, to

When valves are disassembled and manually an option only where full stroke exercisingexercised in lieu of full-flow testing, is cannot practically be performed by flow or byadherence to the quantitative aspects and the other positive means allowed by IWV-acceptance criteria of IWV-3522(b) required? 3522. Additionally, partial stroke exercise

Response after the disassembly and inspection is

The staff believes the requirement in IWV-3522 (b) of the ASME Code to measure theforce or torque while manually exercisingcheck valves only applies to manual exercisingfrom outside the valve where the observationof the valve internals cannot be made. Thismeasurement permits a quantitative evaluationof the performance of the valve in thatchanges in the measured force or torque maybe indicative of degradation of the valveinternals. While the valve is in a partiallydisassembled condition the valve internalsshould be inspected and the condition of themoving parts evaluated. This inspection andevaluation should include verification by handthat the valve disk is free to move, butmeasurement of force or torque is notrequired. Following reassembly, a partial flowtest is expected to be performed.

Current Considerations Question

Paragraphs 4.3.2.4(b) and (c) of OM-10 In light of the stated position of requiringclearly divide the disassembly and inspection check valve internal inspection at least oncefrom manual exerciser use. (See OM-10). every six years, is it permissible to schedule

Question Group 11 a six year frequency vs. each refuel outage?

Questions

Does the utility have the option of eitherinspection through disassembly or performingfunctional testing to satisfy IST requirements? Can either be used regardless of the previoustesting mode?

Response

verify full stroke capability of check valves is

testing with flow is expected to be performed

completed but before returning the valve toservice. If the previous test was performedusing flow, the licensee is expected todocument the justification for any changefrom that test method. Also, for the casewhere plant conditions prevent full stroketesting with flow, the licensee shouldperiodically evaluate whether plant conditionshave been altered in such a way that fullstroke testing using flow is possible. If so, thelicensee should revise the test procedures toprovide for such testing.

Current Considerations

OM-10 allows for disassembly and inspectionas an alternative to tests. (See Paragraph4.3.2.4(c) of OM-10).

Question Group 12

the inspections for the total group of valves on

This is especially important where plantpreparations for inspection of multiple valvesare essentially equal to those for a single valveand they represent a considerable cost interms of monetary outlay as well as scheduleand availability impacts.

Response

Position 2 of Generic Letter 89-04 takesadvantage of the benefits that can be obtained

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through sampling techniques. The NRC staff, IST personnel are appropriately trained andhowever, recognizes that the position may qualified for performing the valvehave a significant impact on outage time. For disassembly/inspections. Generic Letter 89-example, some plants have combined injection 04 alone does not impose any requirements forheader check valves that are physically visual testing certifications (such as VT-3)located in a position relative to the reactor beyond those currently in the ASME Code. coolant system (RCS) loops such that their Nevertheless, licensees must implement thedisassembly would require draining the RCS to provisions of ANSI/ASME N45.2.6,a level that would necessitate core offload. In "Qualifications of Inspection, Examination,order to alter the inspection frequency as and Testing Personnel for Nuclear Powersuggested by this question, licensees should Plants," according to their commitments baseduse the criteria in Position 2 to justify and to on the implementation section of Regulatorydocument the proposed disassembly schedule. Guide 1.58. The NRC staff encourages thoseThe justification should address the licensees that have not formally committed tosignificance of the loss of benefits of sampling following Regulatory Guide 1.58 to review thein light of the condition, service history, and ANSI standard and regulatory guide forapplication of the valves. For additional guidance in developing a program for thediscussion of this issue, see the response to qualification of inservice testing personnel. Question 19.

Question Group 13

Questions

Does disassembly/inspection require certified disassembled/inspected in a non-refuelingvisual testing personnel, or can detailed outage, does the next valve need to beinspection procedures be performed by inspected at the next refueling outage, or canmaintenance personnel without certified it still be scheduled for its original refuelinginspectors? outage?

Do personnel performing the visual Responseinspections addressed on Position 2 have to beVT-3 certified, ANSI 45.2.6 (i.e., MechanicalInspector) certified, or may engineeringpersonnel competent in check valve techniquerequirements perform this visual inspection?

Response

The personnel performing the disassembly/ inspection schedule on thedisassembly/inspection must be qualified to sampling program. The justification shouldevaluate the condition of the valve and to rely on the maintenance history and knownassess its continued operability. The licensee valve condition from previous inspectionsis responsible for the development and rather than subjective qualitative judgement. implementation of a program to ensure that Position 2 in Generic Letter 89-04 indicates

Question Group 14

Question

If a check valve within a sample group is

This question is difficult to answer withoutmore detailed information. In general, inorder to alter the disassembly/inspectionschedule as suggested by the question, thelicensee should justify and document theproposed change. The justification shouldaddress the effect of the proposed

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the criteria that need to be addressed. can be performed, this testing is expected toCurrent Considerations be performed after the disassembly and

If it is practical to disassemble and inspect the the valve to service.selected valves at a frequency not determinedby refueling outages, the licensee may Disassembly and inspection of a check valveestablish a schedule for these valves that does is not considered a "test" as implied by thenot conform to a refueling outage schedule. question. Disassembly is not a true substituteHowever, because disassembly and inspectionfor an operability test using flow, but isis a maintenance activity and not a allowed as an alternative to a flow test where"surveillance," entry into an LCO to perform that test is not practical. Disassembly andthe activity may not be acceptable (See inspection does, however, provide a valuableSection 3.1.2). means of determining the internal condition of

Question Group 15 disassembly and inspection involved the iden-

Question

Is it the intent of Position 2 of the GenericLetter 89-04 that during valve testing bydisassembly, that the valve be completelydisassembled and each internal valve partremoved, if possible, and 100% of the partvisually inspected, or may only the valvebonnet be removed and the valve internalsinspected in place without the removal of theinternal valve parts unless evidence ofdiscrepant conditions are found which thenwould require further inspection and probableremoval of the part? Note: Inspection of thevalve internal parts without removal of thepart would be by direct visual inspection, useof mirrors, or by remote inspection equipmentsuch as boroscope fiberoptics.

Response

When performing check valve disassemblyand inspection to satisfy the requirements ofthe ASME Code for inservice testing,disassembly is required only as far asnecessary to assess the condition of the valveand to allow manual exercising of the disk. (Itmust be recognized, however, that the Coderequirements for inservice inspection aredifferent from those associated with inservicetesting.) If a partial stroke exercise with flow

inspection are completed but before returning

the valve. A recent example of the value of

tification of broke bolting material in AnchorDarling check valves at two nuclear powerplants. This occurrence is discussed in NRCInformation Notice 88-85, dated October 14,1988.

The NRC staff is encouraging thedevelopment and use of alternate techniquesto evaluate the position of check valve disks. The Electric Power Research Institute (EPRI)and the Institute of Nuclear Power Operations(INPO) are recommending an inspectionperiodically for check valves that aresubjected to potentially harsh serviceconditions. The NRC staff encourages theseactivities as well. The industry group NIC isalso investigating methods to demonstrate theoperability of check valves.

Current Considerations

Refer to NRC Information Notice 89-62,"Malfunction of Borg-Warner Pressure SealBonnet Check Valves Caused by VerticalMisalignment of Disk," for an example of avalve disk installation problem.

NUREG-1482 #���

Question Group 16 disassembly and inspection in conformance

Questions

Even though the check valve flow testing canbe performed as required by ASME SectionXI, may the valve test be performed bydisassembly as permitted by Position 2 inGeneric Letter 89-04 when it is considered bythe utility that testing by disassembly willprovide the same or greater assurance that thevalve will function properly? (Note: Ifpossible, partial valve stroking quarterly, or atcold shutdown, or after re-assembly would beperformed.) If the answer is yes, (a) can thetest frequency, sample, etc., as described inGeneric Letter 89-04 Position 2 be used in lieuof ASME Section XI requirement-even if theSection XI test could be performed, i.e., atcold shutdown; (b) must a relief request beprocessed or may this "test by disassembly" benoted in the valve IST program submittal tothe NRC; and (c) must a relief request beprocessed or may the frequency sample, etc.,be noted in the valve IST program submittal tothe NRC? May the valve testing by disassembly/visual

Response Letter 89-04 be applied to reverse flow testing

The various methods aimed at evaluating theoperability of check valves are not equallyacceptable to the NRC staff. At the outset, Position 2 of Generic Letter 89-04 addressesthe ASME Code requires a full stroke exercise the use of disassembly and inspection as anusing flow (or a mechanical exerciser) to be alternative to forward flow testing of checkperformed quarterly. Where full stroke valves. The use of disassembly and inspectionexercising cannot be performed quarterly, the to verify closure capability (i.e., back flow)Code allows the performance of this test may be found to be acceptable depending onduring cold shutdowns. Full stroke exercising whether verification by flow or pressureduring refueling outages may be an acceptable measurements is practical. As the genericalternative if the test cannot be performed at letter does not address this use, however, thecold shutdown, but this approach would submission and approval of a relief requestrequire submission of a relief request. For before implementation is required. those cases where full stroke exercising Disassembly and inspection is not acceptablecannot be performed quarterly, during cold for demonstration of leak-tight integrity. shutdown, or during refueling outages,

with Position 2 of Generic letter 89-04 isallowed as an alternative. If the provisions ofPosition 2 are followed, a relief request neednot be submitted for NRC review but thisdeviation from the ASME Code should bedocumented. (See also the response toQuestion 15).

Current Considerations

A relief request is no longer required fordeferral of testing to refueling outages. However, if testing can be practicallyperformed, but specific situations occur thatcould cause delays or other problems duringrefueling outages making a test burdensome,the licensee may request relief fromperforming disassembly and inspection duringthat one refueling outage. (See Section 3.1.1).

Question Group 17

Question

inspection identified in Position 2 of Generic

of check valves? Response

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Current Considerations Current Considerations

In Position 2, the NRC stated that disassembly Tests performed involving nonintrusiveand inspection could be acceptable for closure techniques and tests that measure flow andverification. The response to Question 17 differential pressure may be acceptable at lesscaused confusion as to whether relief is than full-flow. (See Section 4.1.2).required, or the approval granted in GL 89-04is acceptable for using Position 2 in verifying Question Group 19closure. The staff determined that Position 2is acceptable for closure verification when noother means is practical. If the check valveincludes a bonnet-hung disk, the staffrecommends that the procedures includeenhanced requirements for maintenance andquality control to ensure that the disk isproperly oriented when it is reinstalled. Nonintrusive methods such as radiography oracoustics may be used as an alternate methodto verify closure. (See Section 4.1).

Question Group 18

Question

We are only able to perform a partial flow testof the accumulator discharge check valves dueto limitations based on system configuration. Do we have to supplement this test withdisassembly of the check valves?

Response

The safety injection accumulator discharge need to offload the reactor core, such as whencheck valves are typically very difficult to testing the combined injection header checkexercise with flow to the position required to valves at some plants, or to operate at mid-perform their safety function. If a partial flow level of the reactor coolant loops may beexercise is all that can be performed, then considered. The radiation exposure thatsome other technique, as discussed in Position would result from the disassembly and1 of Generic Letter 89-04, might be developed inspection is a factor to be considered underto periodically verify the capability of these the ALARA (As Low As Reasonablyvalves to move to their safety function Achievable) principle, but it should be judgedposition. If this is not feasible, the licensee is in combination with all of the other factors. expected to follow the provisions for thedisassembly alternative contained in Position 2Current Considerations of the generic letter.

Question

Regarding disassembly of check valves, pleasedefine "extreme hardship" when speaking withregard to extension of disassembly interval.

Response

The existence of "extreme hardship" thatwould allow extension of the disassemblyschedule in Position 2 of Generic Letter 89-04is dependent on the particular circumstancesat the plant. To determine whether extremehardship exists, the licensee should conduct adetailed evaluation of the various competingfactors. First, the licensee should determinethe effect on plant safety that would resultfrom the proposed schedule extension. Themaintenance history of the component andother information relevant to its reliabilityshould be reviewed to determine whether thedecrease in assurance of plant safety resultingfrom the schedule extension is justified. A

A one-time extension may also be acceptableif unique or unanticipated activities during an

NUREG-1482 #���

outage prevent the plant staff from Position 2 for an alternate disassemblydisassembling and inspecting the valves. For schedule are followed, it is acceptable toexample, if outage activities preclude draining implement the alternative and an SER will notthe refueling water storage tank (RWST), be issued. The NRC staff, however, maywhich is necessary to disassemble a check review the alternative and its justificationvalve, a one-time extension may be warranted. during plant inspections. Such extensions may be documented underthe provisions of GL 89-04 and further NRC Current Considerations for Position 2approval is not required. (See Position 2above regarding extension of the interval).

Question Group 20

Questions statements in Position 2. Paragraph 4.3.2.4(c)

Position 2 goes into the scheduling ofdisassembly/inspection in a very detailedmanner. Are other scheduling schemesacceptable as long as they have each valvedisassembled/inspected within 6 years? Would approval of an alternate schedule haveto be in the form of an SER [safety evaluationreport] or acceptance of details provided in aconfirmation letter (existing schedule fordisassembly/ inspection agreed upon in ISTprogram review with NRC, but SER neverissued)?

Response

As stated in Position 2 of Generic Letter 89-04, the burden is on the licensee todemonstrate the extreme hardship necessaryto comply with the identified sampledisassembly/inspection schedule. The staffconsiders the sampling aspect of the positionto provide assurance of the continuedoperability of the valves that are not inspectedduring any given outage. Therefore, thelicensee should justify through the provisionslisted in Position 2, any deviation from thestated scheduled. That justification should beprovided in the IST program submitted to theNRC staff, but need not be included in theconfirmation letter. Where the provisions of

The staff has determined that the use ofPosition 2 is acceptable for verifying thecapability of valves both to open and to close. The response to Question 17 contradicted the

of OM-10 allows that "[a]s an alternative tothe testing [exercising in accordance withparagraph 4.3.2.4 (a) and (b)], disassemblyevery refueling outage to verify operability ofcheck valves may be used." (See Section 4.1for discussion on check valves).

In evaluating the use of disassembly andinspection versus nonintrusive testing, alicensee has many factors to consider. Through participation in the Nuclear IndustryCheck Valve Users' Group (NIC), the industryhas seen the benefits in costs savings andpersonnel exposure. Because the NRCthrough Position 2, and the O&M Committeethrough OM-10, have indicated thatdisassembly and inspection is an acceptablealternative when full flow cannot be measuredor attained, licensees do have the option. However, operations and maintenance costsshould be adequate incentive for licensees toimplement nonintrusive testing where suchcosts savings can be realized.

The NRC recently distributed a report to allPWRs which compiled a utility surveyconducted by Oak Ridge National Laboratory(ORNL/NRC/LTR-94/04, "Utility SurveyPWR Safety Injection Accumulatory TankDischarge Check Valve Testing," February 17,1994). The report indicates the benefits of

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performing nonintrusive testing of these valves.

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NRC STAFF POSITION 3,“BACK FLOW TESTING OF CHECK VALVES”

Position 3 Questions and Answers for Position 3

Section XI requires that Category C check Question Group 21valves (valves that are self actuated inresponse to a system characteristic)performing a safety function in the closedposition to prevent reversed flow be tested ina manner that proves that the disk travels tothe seat promptly on cessation or reversal offlow. In addition, for category A/C checkvalves (valves that have a specified leak ratelimit and are self actuated in response to asystem characteristic), seat leakage must belimited to a specific maximum amount in theclosed position for fulfillment of theirfunction. Verification that a Category C valveis in the closed position can be done by visualobservation, by an electrical signal initiated bya position-indicating device, by observation ofappropriate pressure indication in the system,by leak testing, or by other positive means.

Examples of ASME Code Class check valvesthat perform a safety function in the closedposition that are frequently not back flowtested are:

(a) main feedwater header check valves

(b) pump discharge check valves on parallelpumps

(c) keep full check valves

(d) check valves in steam supply lines toturbine driven AFW pumps

(e) main steam non-return valves

(f) CVCS volume control tank outlet checkvalves

Question

With reference to generic letter item 3, if aleak test is performed to verify Category Ccheck valve seat position, would any leak ratebe acceptable so long as the system meets itsminimum requirements to perform its safetyfunction?

Response

When performing a test to verify closurecapability of a check valve that does not havea defined seat leakage limit, the achievementof the necessary system flow rate through theintended flow path might be an adequatedemonstration of the closure capability of acheck valve. For example, when verifying theclosure capability of the check valves on thedischarge of parallel pumps, achievement ofthe required safety flow rate from one runningpump with the idle pump's discharge checkvalve providing the barrier for recirculationflow would be considered an acceptable testconfiguration. In addition, the licensee shouldevaluate the consequences of the back flowthrough the check valve. This evaluationshould consider the loss of water from thatsystem and connecting systems, the effect thatthe leakage might have on components andpiping downstream of the valve, and anyincrease in radiological exposure resultingfrom the leakage.

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Current Considerations function at some PWR plants to separate the

A plant's safety analysis may include a leakage grade source. limit for a particular valve, or only require thatthe valve closes to inhibit gross leakage. Question Group 23When a valve has a safety-related function toclose to prevent diversion of flow betweentrains of a system, there may be a leakagelimit based on the total system requirements. The Code does not specifically require thatthese valves be Category A. The basis forassigning valves to categories should beavailable for inspection.

Question Group 22

Questions

Are the items listed in Attachment 1, number3a, d, e, f, specific to PWR's? Thenomenclature is not familiar to BWRs.

Section 3 of Generic Letter 89-04 deals withback flow testing of check valves. It has a listof several valves that NRC states provide asafety function. Some of these valves do notappear to provide a safety function and wewould like to hear the NRC's reason forclassifying these valves as safety related.

Response

All of the listed systems do not necessarilyapply to each plant. A licensee should In general, the leak rate limits should be setevaluate at least the listed systems to within certain bounds. If the leak limits aredetermine if they apply to its facility and too low, unnecessary repairs or adjustments toshould make any necessary modifications to the valve can result. If too high, failure of theits IST program. In regard to a particular tests required by Appendix J to 10 CFR Partquestion, items 3d, e, and f are specific to 50 could occur, leading to concerns for leak-pressurized water reactors (PWRs) while 3a tight integrity of the containment. (feedwater header check valves) may Appropriate permissible leak rates can only bebe applicable to both boiling water reactors developed and refined by analyzing and(BWRs) and PWRs. One example provided in trending the leak rate data of specific valvesPosition 3 to the generic letter is the volume or leak rate data from similar valves at othercontrol tank outlet check valve in the plants. Therefore, the NRC staff is not in achemical and volume control system. This position to specify leak rates. The licenseecheck valve may serve an important safety should document its methods for establishing

non-safety grade water source from the safety

Question

In regard to Attachment [1], Position 3, how isindividual seat leakage determined for10 CFR 50, Appendix J, Type C, testedvalves? Tech Specs specify only penetrationtotals.

Response

IWV-3426 of Section XI of the ASME Coderequires that a permissible leak rate bespecified by the plant owner (licensee) for aspecific valve. If leak rates are not specifiedby the licensee, permissible leak rates areprovided in IWV-3426. It should be notedthat Section XI provides no criteria orguidance for licensees on the method toestablish or to specify the permissible leak rateof a particular valve. Apparently, the Coderecognizes that leak behavior of a valve variesaccording to the type of valve, the vendor, thevalve size, the service conditions, the safety-related functions, and other factors, and thatthere is no simple leak rate rule that may beapplicable to all valves.

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the initial permissible leak rates and Current Considerations procedures for improving the leak rate limits.

Current Considerations frequently, such as quarterly, the verification

Refer to Section 4.4.3, "Multiple Containment and the valves can then be exercised open onIsolation Valve Leak-Rate Testing" herein. an extended frequency such as at each cold

Question Group 24 conditions during post-maintenance testing

Questions

In regard to Attachment 1, Position 3, doesthis backseat check require a full-strokeexercise and is it performed at the Codespecified frequency regardless of normal plantpositions?

In reference to Item 3 of Attachment 1, does avalid back-flow test on a check valve firstrequire the valve to be exercised to the openposition then back tested, or is it valid tomerely perform the back flow test?

Response Previous to this, it was permissible to verify

If a particular valve performs a safety functiononly in the closed position, demonstration of afull-stroke open before verification of closurecapability is not required by the ASME Code. This closure verification is required to beperformed at the frequency specified by the Verification of closure capability of stopCode. If (1) the valve performs a safety check valves by using the handwheel meetsfunction in the closed position, (2) the normal the ASME Code requirements. This, however,position for the valve is closed, and (3) this is not the preferred method of test. The NRCposition can be verified during normal plant staff considers reverse flow testing to be aoperation, then quarterly documentation of more reliable indication of valve operability. this verification satisfies the Coderequirements. If a valve performs a safety Modified Response function in both the open and closed positions,however, the Code requires that the valve beexercised to the open position and then beverified to close.

If the verification of closure is practical more

can be performed without opening the valve,

shutdown or refueling outage. Plant

may prevent the licensee from partially orfully stroking a valve open after reassemblingit. If the disk was stroked or removed, a leaktest may verify that the valve can closeproperly. A post-maintenance open strokeexercise may be performed to restore a valveto service with the verification of closureperformed when plant conditions allow. (SeeSection 4.1.3; also see Paragraph 4.3.2.2(a) ofOM-10).

Question Group 25

Question

closure of stop-check valves simply byoperation of the stem (shaft). Is thisacceptable instead of reverse flow testing?

Response

This response was modified in Revision 1 tothe minutes, September 26, 1991, as follows:

(a) If the stop-check valves do notperform a safety-related function in

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the closed position, valve closure is operational readiness.only necessary to ensure repeatableopening stroke time testing. Valves This guidance expands on the responsemay be closed by using a handwheel provided in the meeting minutes. The staff'sor a hand switch. response contained in the meeting minutes did

(b) If the use of a handwheel or a hand prompt closure was required to ensure that aswitch to close a valve achieves the safety-related function would besafety-related function of the system, accomplished. then exercising the valve by thismethod meets the ASME Code If the valve can be stroked open and thenrequirements of IWV-3522. verified to seat promptly on cessation or

(c) If a prompt closure of these valves the use of a hand wheel or hand switch on aon cessation or reversal of flow is quarterly frequency may be part of therequired to accomplish a safety- program in concert with the other testing, ifrelated function closure must be practical.verified by reverse flow testing orsuch other positive means as acoustic Question Group 26monitoring or radiography.

(d) These valves should be disassembledfor verifying valve closure when noother means of verification ispossible. However, disassemblyprovides limited information onvalve capability to seat promptly oncessation or reversal of flow. Furthermore, if the method involvesextensive disassembly, a post-reassembly test would be necessaryper IWV-3200 because disassemblyand inspection can increase theprobability of human error when thevalve is reassembled. The licenseeshould investigate the use ofnonintrusive testing techniques andshould implement them if they aredemonstrated to be effective toassess closure capability,degradation, and incipient failure. The infrequent disassembly andinspection of the valves areappropriate to assess overall checkvalve condition, while reverse flowtesting and nonintrusive testingprovide an assessment of continued

not address instances in which verification of

reversal of flow only at an extended interval,

Question

Regarding back flow testing of check valves,what is the position of the generic letter in thephrase "verify by other means"?

Response

The majority of the wording in the sentence inwhich this particular phrase appears was takendirectly from IWV-3522 of Section XI of theASME Code. The NRC staff included thephrase "by other positive means" to beconsistent with the wording of the Code. When Generic Letter 89-04 was written, thestaff did not have in mind any particulartechniques that it would consider acceptable.

Current Considerations

Paragraph 4.3.2.4 of OM-10 allows for otherpositive methods of verification. Recentexamples from inservice testing programsinclude verifying that a parallel centrifugalpump does not spin in reverse to verify closureof a pump discharge check valve, monitoringan upstream pressure indicator, monitoring a

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tank level, measuring the flow rate of a backflow test). However, if plant conditionsredundant train, and opening an upstream vent make a forward flow test impracticaland drain valve. quarterly, or during cold shutdown outages,

Current Considerations for Position 3 without testing the forward flow. When leak-

Licensees may refer to NRC InformationNotice 91-56, "Potential Radioactive Leakageto Tank Vented to Atmosphere," forinformation on the categories assigned tovalves which function to close. These valvesmay also function to prevent leakage above anassumed limit to prevent the plant fromexceeding the limits in 10 CFR Part 100. Position 4.1.1 herein discusses backflowtesting of check valves in series.

The staff has received relief requests forbackflow testing in which licensees interpretthe requirements such that a forward flow testis required before the verification of closure(i.e., perform the forward flow test before the

the licensee may practically verify closure

tightness is not required, backflow testing canbe performed by several methods includingverifying of system parameters. Paragraph4.3.2.4 of OM-10 allows that other positivemeans may be used for verification. Recentexamples of acceptable backflow tests includeverifying that a parallel pump does not rotatebackwards when the other pump is tested toverify that the pump discharge check valve isclosed, monitoring pressure upstream,performing system hydrostatic or pressuretests, performing radiography, usingnonintrusive methods, and performing leaktests (even if a leakage limit does not apply). These various methods meet the "otherpositive means" of the Code.

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NRC STAFF POSITION 4,“PRESSURE ISOLATION VALVES”

Position 4

a. General

Pressure isolation valves (PIVs) aredefined as two normally closed valves inseries that isolate the reactor coolantsystem (RCS) from an attached low-pressure system. PIVs are located at allRCS low-pressure system interfaces. The10 CFR 50.2 contains the definition of theRCPB. PIVs are within the reactorcoolant pressure boundary (RCPB).

The following summary is based upon thestaff's review of responses to GenericLetter 87-06, Periodic Verification ofLeak Tight Integrity of Pressure IsolationValves. All plants licensed since 1979have a full list of PIVs in the plantTechnical Specifications (TS) along withleak test requirements and limitingconditions for operation (LCOs). Theplants licensed prior to 1979 fall intoseveral categories. Some pre-1979 plantshave a full list of PIVs along with leaktest requirements and LCOs in the plantTS. Some pre-1979 plants have onlyEvent V PIVs (see below) in the plant TS. Some pre-1979 plants have no TSrequirements regarding PIVs.

All PIVs listed in plant TS should be listedin the IST program as Category A or A/Cvalves. The TS requirements should bereferenced in the IST program.

b. Event V PIVs

Event V PIVs are defined as two checkvalves in series at a low-pressure/RCSinterface whose failure may result in aLOCA that by-passes containment. Event V refers to the scenario describedfor this event in the WASH-1400 study.

On April 20, 1981, the NRC issued anOrder to 32 PWRs and 2 BWRs whichrequired that these licensees conduct leakrate testing of their PIVs, based on plant-specific NRC supplied lists of PIVs, andrequired licensees to modify their TSaccordingly. These orders are known asthe "Event V Orders" and the valveslisted therein are the "Event V" PIVs. The Event V PIVs are a subset of PIVs.

Based upon the results of recentinspections, it has been determined thatthe following implementation problemstill exists with respect to testing of PIVs. The staff has determined that in somecases the procedures are inadequate toassure that these valves are individuallyleak tested and evaluated against theleakage limits specified in the TS; in othercases, the procedures were adequate butwere not being followed. Specifically,some check valves were tested in seriesas opposed to individually and somecheck valves were not tested whenrequired.

Licensees should review their testingprocedures to ensure the Event V PIVsare individually leak rate tested.

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Questions and Answers for Position 4 Current Considerations

Question Group 27

Questions

Is it the intent of Generic Letter 89-04 that theonly Reactor Coolant System PressureIsolation Valves (PIVs) to be included in theIST program are those listed in the TechnicalSpecifications and those which are Event VPIVs?

For plants licensed prior to 1979 which do notlist all RCS Pressure Isolation Valves in theirTechnical Specifications, is it the intent ofPosition 4 of Generic Letter 89-04 that onlyPIVs listed in the Technical Specifications andPIVs which are "Event V" be included in theIST Program?

Does the NRC anticipate requiring (in thefuture) that all RCS PIVs be included in theIST program? The responses to Generic Letter 87-06 are

Response Generic Issue 105, "Interfacing Systems

The position in Generic Letter 89-04represents only a limited area of the staff'sconcerns regarding PIVs. The generic letterposition only applies to those PIVs listed inindividual plant Technical Specifications. However, the staff recognizes that the PIVs inthe Technical Specifications for many plants,particularly older plants, are a subset of thePIVs in the plant. In view of this fact andother concerns regarding PIVs, the staff hasrecently undertaken a program to reevaluatevarious aspects of PIVs, including testing.Sample inspections are underway as part ofthis NRC program.

The staff recommends that valves defined aspressure isolation valves other than those inTS are at least verified closed in accordancewith the inservice testing program, and ensurethat the testing described in response to GL87-06 is maintained or justified. (See Section4.1.1).

Question Group 28

Questions

What, if anything, is being done with thelicensee responses to Generic Letter 87-06? The generic letter references PIVs in Section4; however, it appears that there are nochanges required due to Generic Letter 87-06. Is this true?

Response

being used as input for the resolution of

LOCAs at Light Water Reactors," underinvestigation by the NRC Office of NuclearRegulatory Research. No further licenseeaction is required at this time with respect toGeneric Letter 87-06.

Current Considerations

The results of studies of interfacing systemloss of coolant accidents (LOCA) are providedin NUREG/CR-5124, "Interfacing SystemsLOCA: Boiling Water Reactors," andNUREG/CR-5102, "Interfacing SystemsLOCA: Pressurized Water Reactors."

Current Considerations for Position 4

Those plants licensed with all PIVs listed inthe TS have a specified leakage limit for each

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PIV. In responding to GL 87-06, many of the established by the licensee; however, sincelicensees for plants having TS for only Event two valves are required for reactor coolantV PIVs described the PIVs and testing applied pressure boundary applications, theto each set of valves, indicating that the Event requirements of 10 CFR 50, Appendix A,V valves were the only PIVs which were leak General Design Criterion 15 and Criterion 32tested. In recent program submittals, licensees apply for whichever valves are designatedstated that the designations for certain PIVs reactor coolant pressure boundary valves (seehave been changed from those listed in GL Section 4.1.1; NOTE: Not all reactor coolant87-06 to designate other valves in the same pressure boundary valves are PIVs).lines as PIVs. The designations are

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NRC STAFF POSITION 5,“LIMITING VALUES OF FULL-STROKE TIMES

FOR POWER-OPERATED VALVES”

Position 5

The Code intent with respect to measuring thefull-stroke times of power operated valves isto verify operability and to detect valvedegradation. Measurement of full stroke timesfor air operating valves fulfills this intent. However, reviews of operating experiencehave identified several problems with motoroperated valves (MOVs) including limitationswith stroke time as a measure of operationalreadiness of the MOV. As a result, theindustry has made extensive efforts toimprove the knowledge and understanding ofoperational characteristics of motor operatedvalves. This effort has been conducted byindustry groups (NUMARC, INPO, NMAC,EPRI), individual licensees, equipmentvendors, and national standards groups.

We believe the information and knowledgedeveloped by these groups should be reviewedand utilized. Some of the information publiclyavailable includes an INPO white paper titled,"Motor-Operated Valve PerformanceUpdate," issued October 4, 1988. Thisdocument identifies MOV problem areas andprovides the key elements for acomprehensive MOV program. Anotherdocument is the "Technical Repair Guidelinesfor the Limitorque Model SMB-000 ValveActuator," issued by the Nuclear MaintenanceApplication Center (NMAC) in January 1989. This guide addresses several areas such assetting torque and limit switches, preventivemaintenance, actuator failure modes, failureanalysis to determine root cause and correc-tive action, and preoperational and post-maintenance testing.

NRC staff concerns regarding MOVoperability led to the issuance of Bulletin 85-03 and Bulletin 85-03, Supplement 1. Expansion of this bulletin in the form of ageneric letter is being considered by the NRC.

In spite of the limitations of stroke time testingof MOVs, IWV-3413(a) of the ASME Coderequires that the licensee specify the limitingvalue of full-stroke time of each poweroperated valve. The corrective actions ofIWV-3417(b) must be followed when theselimiting values are exceeded. The Code doesnot provide any requirements or guidelines forestablishing these limits nor does it identify therelationship that should exist between theselimits and any limits identified for the relevantvalves in the plant TS or safety analysis.

The purpose of the limiting value of full-stroketime is to establish a value for takingcorrective action on a degraded valve beforethe valve reaches the point where there is ahigh probability of failure to perform its safetyfunction if called upon. The NRC has,therefore, established the guidelines describedbelow regarding limiting values of full-stroketime for power operated valves.

The limiting value of full-stroke timeshould based on the valve referenceor average stroke time of a valvewhen it is known to be in goodcondition and operating properly. The limiting value should be areasonable deviation from thisreference stroke time based on thevalve size, valve type, and actuatortype. The deviation should not be so

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restrictive that it results in a valve Responsebeing declared inoperable due toreasonable stroke time variations. However, the deviation used toestablish the limit should be such thatcorrective action would be taken fora valve that may not perform itsintended function.

When the TS or safety analysis limit for avalve is less than the value established usingthe above guidelines, the TS or safety analysislimit should be used as the limiting value offull-stroke time.When the TS or safety analysis limit for avalve is greater than the value establishedusing the above guidelines, the limiting valueof full-stroke time should be based on theabove guidelines instead of the TS or safetyanalysis limit.

Questions and Answers for Position 5

Question Group 29 motor-operated valves. In light of this

Question

Attachment 1, Position 5 in part states: "Thedeviation should not be so restrictive that itresults in a valve being declared inoperabledue to reasonable stroke time variations. However, the deviation used to establish thelimit should be such that corrective actionwould be taken for a valve that may notperform its intended function." Given thatMOVs operated by AC induction motors fail ifslowed by more than approximately 10%, avalve normally stroking in 15 seconds will failto operate by a change of 1.5 seconds. Bycomparison, a reasonable deviation fromnormal stroke time of 15 seconds caused byerror in measurement might be 2 seconds. Thefact that the reasonable deviation for this 15 In regard to Attachment 1, Position 5, what issecond valve is larger than the possible actual considered a reasonable deviation from thedeviation before failure makes the two quoted reference stroke time? goals of Attachment 1, Position 5, mutuallyexclusive. Request resolution. In regard to Attachment 1, Position 5, can the

The staff agrees that stroke times for ACmotor-operated valves probably will notchange appreciably before failure, especiallyfor MOVs that have relatively short stroketimes. If the ASME Code-identified testingdoes not provide useful information forevaluating the continued operability of thesevalves, then the licensee should propose analternative to the Code requirements that doesprovide such information. The Code requiresthe licensee to establish limiting values of fullstroke time for all power-operated valves andalso requires measurement of stroke time to anaccuracy of within 10 percent for thisparticular case. The Code does not prohibitthe measurement of stroke time moreaccurately or the setting of the limiting valueat less than 25 percent above the normalstroke time. The NRC and industry recognizethat the Code-specific criteria are notsufficient for assuring operability of AC

recognition, the staff issued Bulletin 85-03 torequire that licensees establish programs toensure that operator switches for MOVs incertain important plant systems are selected,set, and maintained properly. As a result, inpart, of the responses to that bulletin, thescope of the effort has been expanded inGeneric Letter 89-10 to include many otherMOVs important to plant safety. NRC staffactions such as these will be need tocompensate for weaknesses in the ISTprovisions of the ASME Code until anadequate IST standard is available.

Question Group 30

Questions

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deviation be different for valves with different Current Considerations functions and/or actuators?

What is meant by "reasonably limiting value requirements for using reference values forof full-stroke time?" stroke time acceptance criteria. Paragraph

What methods are considered acceptable for for establishing a limiting value for valveestablishing the limiting value for full stroke stroke time. Any multipliers other than thosetimes for power operated valves as given in listed in Paragraph 4.2.1.8 would requirePosition 5 of Generic Letter 89-04? relief for each valve, or group of valves.

In reference to Item 5 of Attachment 1, isthere any generic guidance on what is Question Group 31acceptable to the NRC on this item?

What is "reasonable" value for deviating fromthe reference stroke time established for valvetesting?

Response

The NRC staff has attempted to provide thegeneral philosophy for establishing the limitingstroke time. The establishment of specificvalues for the limiting stroke time is dependenton a variety of parameters relevant to theparticular valve and the conditions at theplant. The parameters include operatingcharacteristics, operating environments,actuator types, and valve stroke times. In thatthe test should confirm the operability of thecomponent and not the system, the limitingvalue is not to be considered a function of thevalve's safety significance. As the limitingvalue is specific to the valve, the staff is not ina position to provide values for limiting stroketimes. The licensee needs to use its bestjudgement in assigning these values. Thejustification for the assigned values isexpected to be documented and available tothe plant site for review by NRC personnel. One aspect of the staff review will be acomparison of the limiting stroke time to thetechnical specification value.

Paragraph 4.2.1.8 of OM-10 includes the

4.2.1.4 of OM-10 includes the requirements

Refer to Section 4.2.7 herein.

Questions

In regard to Attachment 1, Position 5(paragraphs 2, 3 and 5), why are Tech Specsor Safety Analysis limiting criteria notacceptable for valve operability ifmaintenance is triggered by componentevaluation?

With respect to the application of stricteracceptance criteria for valve stroke times,apparently the NRC has some idea as to thephilosophy and limits that would beacceptable. This information should be sharedwith licensees.

Define the "limiting value of full-stroke time." Is this number the operability number for thevalve even if the Tech Spec stroke time ismuch higher?

Response

The Technical Specifications provideassurance that important plant systems arecapable of performing their safety functions ina timely manner during selected plantaccidents. The provisions of Section XI of theASME Code are intended to ensure thecontinued operability of particular plantcomponents. The distinct bases for these two

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documents lead to criteria that may differ Question Group 33significantly. Nevertheless, the TechnicalSpecifications and ASME Code are bothneeded to provide confidence that the nuclearpower plant can be operated safely. Therefore, the more restrictive criteria of thetwo documents must be followed even thoughthis might result in a component or systembeing declared inoperable. The response toquestions on position 8 of Generic Letter 89-04 also address the relationship of the ASMECode to the Technical Specifications.

Current Considerations

The TS and SAR limits are useful forperforming analysis of data when a valve hasindicated degraded performance and beendeclared inoperable. In accordance with Coderequirements (paragraph 4.2.1.9 of OM-10),the data may be analyzed to verify that thenew stroke time represents acceptable valveoperation. (See Section 4.2.7).

Question Group 32

Question

Is it required to measure stroke times of valvesthat are not provided with remote positionindication?

Response

The ASME Code requires the measurement ofaccordance with the multipliers in paragraphstroke time for all power-operated valves 4.2.1.8, such an approach would necessitateregardless of whether they have remote separate relief on each valve when the testingposition indication. The staff has endorsed is conducted per OM-10.this requirement. Without specifics, the staffis not in a position to comment on alternate Question Group 34techniques that may be found acceptable.

Current Considerations

Section 4.2.9 includes a discussion ofalternatives that might be acceptable.

Question

When considering comparison of power-operated (stroke time) valves according tovalve type, valve actuators, valve size, etc.,we find there is no consistency when usingthis comparison. However each valveconsistently tests well. We are currentlylooking at a quantitative method ofestablishing maximum allowable stroke times. Is this an acceptable method?

Response

If we understand the intent of the openingsentence of the question, we agree that criteriafor setting the limiting value of full-stroke timemay vary for each valve type, stroke time,size, etc. The use of a quantitative multiplieron a reference time may be an acceptablemethod for setting these values. However, asdiscussed in some of the responses above, thelicensee should document the justification forits quantitative methods of establishing maxi-mum allowable stroke times. This justificationshould be available at the plant site for reviewby NRC personnel.

Current Considerations

This approach may be in accordance withparagraph 4.2.1.8 of OM-10. If it is not in

Question

When the stroke time of a power operatedvalve exceeds its [limiting value for] stroketime, as established in accordance withPosition 5 of the Generic Letter 89-04, but is

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still within its plant Technical Specification or Question Group 35FSAR [final safety analysis report] stroke timelimit, can performing an evaluation whichdetermines if the valve may remain operablebe used to satisfy Position 5 in lieu of makingit mandatory that the valve be declaredinoperable?

Response

The limiting value of full stroke time isrequired to be established for all power-operated valves. The limiting value should bethat point at which the licensee seriouslyquestions the continued operability of thevalve. It is expected to be a value determinedto be reasonable for the individual valve basedon that valve's characteristics and pastperformance, but not to exceed any safetyanalysis requirements. The value should notbe based solely on the system requirements orvalues specified in safety analyses for systemperformance. When the identified limitingvalue is exceeded, the licensee shall declarethe component inoperable and shall enter anyapplicable Technical Specification limitingcondition for operation (LCO). Following thedeclaration that the valve is inoperable, thelicensee may perform an analysis to identifythe root cause of the problem with the valve. If this analysis clearly demonstrates that thevalve remains capable of performing its safetyfunction, the analysis might constitute thecorrective action required by the Code. Theanalysis should be documented.

Current Considerations

Paragraph 4.2.1.9, "Corrective Action," ofOM-10 provides the requirements related tothis response.

Question

If the limiting value of full stroke time is lessthan the "alert limit" identified in the Code,does the trending still have to be done?

Response

If the limiting value of full stroke time isexceeded, then the licensee shall declare thevalve inoperable and shall perform correctiveaction. Where the limiting value is less thanthe 25 percent or 50 percent "alert limits" fortrending as specified in the ASME Code,trending as envisioned by the Code becomes amoot point. The licensee could identify areduced percentage alert limit for this valve toprovide early warning of problems with thisvalve, but this is not required either by theCode or by Generic Letter 89-04.

Current Considerations

OM-10 includes reference values for stroke-time measurement requirements (refer toSection 4.2.7 of the guidelines). Theserequirements do not include alert values.

Question Group 36

Question

In reference to Item 5 of Attachment 1, isItem 5 in fact a rewrite of the stroke timecriteria that are to be applied in accordancewith OM-10?

Response

The information in Position 5 of GenericLetter 89-04 was not intended simply to be arewrite of the information in ASME StandardOM-10. This position has evolved over the

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years and is considered reasonable by the staffCurrent Considerations for establishing limiting values of full stroketime for power-operated valves. As such, the Paragraph 4.1.2.9, "Corrective Action," ofposition represents a clarification of existing OM-10 includes the requirements forASME Code requirements. For its part, analyzing test data.ASME Standard OM-10 does not provideguidance for the establishment of the limiting Question Group 38value of full stroke time. This standard, how-ever, does require that a valve be declaredinoperable immediately upon discovering thatit fails to exhibit the required change ofobturator position or exceeds the limitingvalue of full stroke time.

Question Group 37

Question

Since establishing maximum stroke time limits is specification in implementing proceduresmay in some cases at first prove too sufficient? If procedures are sufficient, canrestrictive, is it acceptable for corrective existing limits referenced in the plan beaction to be an engineering evaluation which removed in a future revision? If planincreases the time limit (based on more specification is required, is this limited todetailed analysis)? Technical Specification and safety analysis

Response stroke time limits that are required also be in

The Commission regulations in 10 CFR 50.59allow licensees to perform engineeringevaluations of plant structures, systems, andcomponents. If the stroke time limit is The specific limiting values of full stroke timeexceeded, the valve must be declared for each power operated valve as determinedinoperable and any applicable Technical according to Position 5 of Generic Letter 89-Specification limiting condition for operation 04 are not required to be identified in the ISTentered. At that point, an engineering program. These limiting values, however,analysis may be performed to verify that the should be provided in a document such as thevalve is capable of performing its safety individual test procedure or a generalfunction. This analysis should include more procedure that identifies the criteria forthan a determination that the new value is less establishing these values. The concern for thethan the FSAR or Technical Specification specification of limiting values is the result oflimit. For example, a root cause investigation weaknesses that the NRC staff has foundshould be performed to determine the reasons while reviewing IST procedures. for the stroke time increase.

Questions

We have been informed that we could omitthe valve stroke time limits from our ISTSubmittal. Where can we find guidance onwhat is really required in a submittal(minimum scope)?

Do specific valve stroke time requirements (orlimits) need to be specified in the IST plan, or

stroke time limits, or must owner specified

the plan?

Response

As a general rule, IST programs should containsufficient information to indicate whatparameters are being measured, how tests arebeing performed, and the bases for the

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acceptability of any departures from the in test implementing procedures, but need notASME Code. For example, the program include them in the IST program document. should indicate forward flow testing or back The IST program document may specify theflow testing, or both, for check valves. type of valve and valve actuator for the

Current Considerations criteria apply. (See Section 2).

In Section 2, the staff describes the content ofthe IST program. Recognizing that referencevalues of stroke-times may be changed, the For using reference values in performinglicensee may consider including these values stroke time tests, refer to Section 4.2.7.

licensee to consider in determining which

Current Considerations for Position 5

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NRC STAFF POSITION 6,“STROKE TIME MEASUREMENTS

FOR RAPID-ACTING VALVES”

Position 6

The Code requires the following for poweroperated valves with stroke times 10 secondsor less: (a) Limiting values of full-stroke timesshall be specified [IWV-3413(a)], (b) Valvestroke times shall be measured to (at least) thenearest second [IWV-3413(b)] and (c) If thestroke time increased by 50% or more fromthe previous test, then the test frequency shallbe increased to once each month untilcorrective action is taken [IWV-3417(a)]. Paragraph IWV-3417(b) specifies correctiveactions that must be taken.

With reference to (c) above, measuringchanges in stroke times from a reference valueas opposed to measuring changes from theprevious test is an acceptable (and possiblybetter) alternative to the staff. However, sincethis is different from the Code requirement,this deviation should be documented in theIST program.

Most plants have many power operated valvesthat are capable of stroking in 2 seconds orless such as small solenoid operated valves. Licensees encounter difficulty in applying theCode 50% increase of stroke time correctiveaction requirements for these valves. Thepurpose of this requirement is to detect andevaluate degradation of a valve. For valveswith stroke times in this range, much of thedifference in stroke times from test to testcomes from inconsistencies in the operator ortiming device used to gather the data. Thesedifferences are compounded by rounding theresults as allowed by the Code. Thus, theresults may not be representative of actualvalve degradation.

The following discussion illustrates theproblem that may exist when complying withthe Code requirements for many of theserapid-acting valves.

A valve may have a stroke time of 1.49seconds during one test and a stroke timeduring the following test of 1.51 seconds. Ifstroke times are rounded to the nearest secondas allowed by the Code, the differencebetween these tests would exceed the 50%criteria and would require an increasedfrequency of testing until corrective action istaken. This can result from a stroke timedifference of 0.02 seconds, which is usuallynot indicative of significant valve degradation.

Power operated valves with normal stroketimes of 2 seconds or less are referred to bythe staff as "rapid-acting valves." Relief maybe granted from the requirements of SectionXI, Paragraph IWV-3417(a) for these valvesprovided the licensee assigns a maximumlimiting value of full-stroke time of 2 secondsto these valves and, upon exceeding this limit,declares the valve inoperable and takescorrective action in accordance with IWV-3417(b).

An acceptable alternative to the Code stroketiming requirements is the above stated rapid-acting valve position. Since this represents adeviation from the Code requirements, itshould be specifically documented in the ISTprogram.

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Questions and Answers for Position 6 change to the program body?

Question Group 39

Question

With reference to the Generic Letter item 6,paragraph 4, where does the two-secondscome from and what is the bases for the two-second only criteria, could this be a minimumof 3 or 4 seconds?

Response

The two-second criterion is based on thestaff's consideration of the response time ofpersonnel and equipment and the difficultiesinvolved in applying the ASME Coderequirements in this situation. Any alternativeto Position 6 of Generic Letter 89-04 or theASME Code requirements may be submitted,along with a sound basis, for staff reviewthrough a relief request. As relief requestscontaining alternatives to the Coderequirements are expected to address thefundamental purpose of inservice testing, seethe summaries of the opening presentations fora discussion of this subject.

Current Considerations

Paragraph 4.2.1.8(e) of OM-10 includes the 2-second limiting value as described in Section4.2.2 of the guidelines.

Question Group 40

Questions

Generic Letter 89-04 states that previousanalysis (IWV-3417(a)) can be replaced witha conservative "reference value" comparison. Generic Letter 89-04 states this should bedocumented in the IST program. Should thischange be made by relief request or by a text

Generic letter position on power operatedvalve stroke times of greater than ten secondsis to place the valve in increased frequency ifstroke time is greater than 25% of the baseline stroke time.

Response

When the staff prepared the discussion inPosition 6 of Generic Letter 89-04, theobjective of the first paragraph was to set thestage for the discussion on "rapid acting"valves, and it was not intended to address allaspects of stroke time for power-operatedvalves. Nevertheless, the staff believes thatthe use of a reference value stroke time as abase line for comparison of routine test valuesis a better method of evaluating change invalve performance than that specified ASMECode IWV-3400. Therefore, if a licenseewishes to use reference values rather thanprevious test values for comparing stroketimes for valves with normal stroke timesequal to or less than ten seconds, the genericletter provides the vehicle for this deviationfrom the Code and a relief request need not besubmitted. As the generic letter does notaddress valves with normal stroke timesgreater than ten seconds, a licensee mustsubmit a relief request for staff review andapproval before using reference values as abase line for stroke times for these values. Question Group 41

Questions

Can an MOV or power-operated valve have adual classification under "rapid acting" and"less than 10 seconds?" For example, we havevalves that stroke closed in less than 2 secondsand open in less than ten seconds. Therefore,is the classification and the previous test (or

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reference test) percentage based on opening tive concerning measurements of changes intime or closing time? stroke time allowed by Generic Letter 89-04

Response stroke time of less than ten seconds. [NOTE:

If the valve performs a safety function in bothpositions, and the stroke time in one directionis less than two seconds, then for that strokedirection, the licensee may use either theacceptance criteria of ASME Code or thestaff's position for rapid acting valves. Wherethe stroke time for the valve in the otherdirection is greater than two seconds, the Paragraph 4.2.1.8(e) of OM-10 includes the 2-acceptance criteria for that stroke time range, second limiting value for stroke timeas identified in the Code, should be followed measurement. Sections 4.2.2 and 4.2.3 relatewhen testing the valve in the greater-than- to rapid-acting valves.two-second direction. Similarly, the alterna-

may be used for the stroke direction that has a

Although both MOVs and power-operatedvalves are mentioned, the question is moreapplicable to air-operated valves. Normally,MOVs do not have widely different stroketimes for the open and close directions.]

Current Considerations for Position 6

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NRC STAFF POSITION 7,“TESTING INDIVIDUAL SCRAM VALVES FOR

CONTROL RODS IN BOILING WATER REACTORS”

Position 7

BWRs are equipped with bottom-entryhydraulically driven control rod drivemechanisms with high-pressure waterproviding the hydraulic power. Each controlrod is operated by a hydraulic control unit(HCU), which consists of valves and anaccumulator. The HCU is supplied chargingand cooling water from the control rod drivepumps, and the control rod operating cylinderexhausts to the scram discharge volume. Various valves in the control rod drive systemperform an active function in scramming thecontrol rods to rapidly shut down the reactor.

The NRC has determined that those ASMECode Class valves that must change positionto provide the scram function should beincluded in the IST program and be tested inaccordance with the requirements of SectionXI except where relief has been granted in apreviously issued Safety Evaluation Report oras discussed below.

The control rod drive system valves thatperform an active safety function inscramming the reactor are the scram dischargevolume vent and drain valves, the scram inletand outlet valves, the scram discharge headercheck valves, the charging water header checkvalves, and the cooling water header checkvalves. With the exception of the scram dis-charge volume vent and drain valves,exercising the other valves quarterly duringpower operations could result in the rapidinsertion of one or more control rods morefrequently than desired.

Licensees should test these control rod drivesystem valves at the Code-specified frequencyif they can be practically tested at thatfrequency.

However, for those control rod drive systemvalves where testing could result in the rapidinsertion of one or more control rods, the rodscram test frequency identified in the facilityTS may be used as the valve testing frequencyto minimize rapid reactivity transients andwear of the control rod drive mechanisms. This alternate test frequency should be clearlystated and documented in the IST program.

Industry experience has shown that normalcontrol rod motion may verify the coolingwater header check valve moving to its safetyfunction position. This can be demonstratedbecause rod motion may not occur if thischeck valve were to fail in the open position. If this test method is used at the Code requiredfrequency, the licensee should clearly explainin the IST program that this is how thesevalves are being verified to close quarterly.

Closure verification of the charging waterheader check valves requires that the controlrod drive pumps be stopped to depressurizethe charging water header. This test shouldnot be performed during power operationbecause stopping the pumps results in loss ofcooling water to all control rod drivemechanisms and seal damage could result. Additionally, this test cannot be performedduring each cold shutdown because the con-trol rod drive pumps supply seal water to thereactor recirculation pumps and one of therecirculation pumps is usually kept running.

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Therefore, the HCU accumulator pressure correlation between the scram time and valvedecay test as identified in the facility TS may stroke time may be obtained, and furthermore,be used as the charging water header check conservative limits are placed on the controlvalve alternate testing frequency for the rod scram insertion times. If the above test isreasons stated above. If this test is not used to verify the operability of scram inletaddressed in the licensee's TS this closure and outlet valves, it should be specificallyverification should be performed at least documented in the IST program.during each refueling outage, and thisalternate test frequency should be specifically Questions and Answers for Position 7 documented in the IST program.

The scram inlet and outlet valves are power-operated valves that full-stroke in millisecondsand are not equipped with indication for bothpositions; therefore, measuring their full-stroke time as required by the Code may beimpractical. Verifying that the associatedcontrol rod meets the scram insertion timelimits defined in the plant TS can be anacceptable alternate method of detectingdegradation of these valves. Also, trendingthe stroke times of these valves may beimpractical and unnecessary since they areindirectly stroke timed, and no meaningful

No questions.

Current Considerations for Position 7

At many plants, certain of the valvesdescribed in Position 7 are non-Code classvalves. The IST program typically designatesthe Code class of each of the valves includedin the program, and those not in a Code classsystem. Most licensees have used theguidance in Position 7 with no variation. (SeeSection 2.2).

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NRC STAFF POSITION 8,“STARTING POINTS FOR TIME PERIODS

IN TECHNICAL SPECIFICATION ACTION STATEMENTS”

Position 8

ASME Section XI, IWP-3220, states "All testdata shall be analyzed within 96 hours aftercompletion of a test". IWP-3230(c) states, inpart, "If the 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 byASME, Section XI, Subsections IWP andIWV, are also in systems covered by TS and,if declared inoperable, would result in theplant entering an ACTION statement. TheseACTION statements generally have a timeperiod after which, if the equipment is stillinoperable, the plant is required to undergosome specific action such as commence plantshutdown.

The potential exists for a conflict between theaforementioned data analysis interval versusthe TS ACTION statement time period. Section XI, IWP-6000 requires the referencevalues, limits, and acceptance criteria to beincluded in the test plans or records of tests. With this information available, the shiftindividual(s) responsible for conducting thetest (i.e., shift supervisor, reactor operator)should be able to make a timely determinationas to whether or not the data meets therequirements.

When the data is determined to be within theRequired Action Range of Table IWP-3100-2the pump is inoperable and the TS ACTIONstatement time starts. The provisions in IWP-

3230(d) to recalibrate the instrumentsinvolved and rerun the test to show the pumpis still capable of fulfilling its function are analternative to replacement or repair, not anadditional action that can be taken beforedeclaring the pump inoperable.

The above position, which has been stated interms of pump testing, is equally valid forvalve testing.

In summary, it is the staff's position that assoon as the data is recognized as being withinthe Required Action Range for pumps orexceeding the limiting value of full-stroke timefor valves, the associated component must bedeclared inoperable and the TS ACTION timemust be started.

If a test is under way (regardless of whethertest data have been taken) and it is obviousthat a gauge is malfunctioning, the test may behalted and the instruments should be promptlyrecalibrated. One example might be a wildlyfluctuating gauge. It should be noted,however, that, in many situations whereanomalous data are indicated, it may not beclear that the problem lies with the gauge. Inthese cases, the licensee should attribute theproblem to pump performance. The licenseewould then declare the pump inoperable andevaluate the condition of the pump during thetime allotted by the applicable TechnicalSpecification.

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Questions and Answers for Position 8 Response

Question Group 42 The Standard Technical Specifications in

Questions

10 CFR 50.55a(g) states that IST programscomply with Section XI. Section XI states forvalves that "If the condition is not, or cannotbe, corrected within 24 hours, the valve shallbe declared inoperative." This is in directdisagreement with the Generic Letter whichstates that the LCO must be declaredimmediately. How do you justify thisdisagreement with the Code?

Generic Letter 89-04 implies that the 24 hourtime period for declaring valves operableversus inoperable does not apply. Can theutility continue to use the 24 hours beforedeclaring a valve inoperable?

Position 8 specifically states that licenseescannot use the 24-hour grace period fordeclaring a valve inoperable (IWV-3417(b))and must make such declaration immediatelyupon recognition of exceeding a stroke timelimit. Position 5 states that the intent ofdeveloping more restrictive stroke time limitsis to identify a valve problem "before the When a piece of equipment enters thevalve reaches the point where there is a high required action range, why must the Techprobability of failure to perform if its safety Specs action statement be entered withoutfunction is called upon." Per Position 5, some time to reflect on why it has entered theexceeding the more restrictive limit does not required action range? A reasonable approachimply that the valve is inoperable but that the would be to establish a limited reflection time,probability of failure is increased. With this for example the existing shift, to review howphilosophy, the 24-hour grace period is even the test was conducted and review previousmore reasonable. tests to see what the problem is. In declaring

This question is in reference to Item 8 of be upon review of how the test wasAttachment 1: "Starting point for time period conducted, generates needless paperwork andin Technical Specifications ACTION impacts INPO availability statistics (i.e.,statement." This item eliminates the 24-hour HPCI, RCIC, RHR). clock for valves which exceed Section XI Responselimits. In most cases, the TechnicalSpecifications limits are higher than theSection XI limit. This item needs discussion.

Section 4.0.5 specifically state that the morerestrictive requirements of the TechnicalSpecifications take precedence over theASME Code. For example, the TechnicalSpecification definition of OPERABLE doesnot grant a grace period before a device that isnot capable of performing its specifiedfunction is declared inoperable. Thatdefinition takes precedence over the ASMECode, which allows up to 24 hours beforedeclaring inoperable a valve that (1) isincapable of exhibiting the required change ofdisk position or (2) has exceeded its limitingvalue of full stroke time. Therefore, if a valveis tested and the data indicate that it is inoper-able as defined by the required action range,then that valve must be declared inoperable atthat time and not 24 hours later. Thiselimination of the 24-hour grace period beforedeclaring a valve inoperable is consistent withthe requirements of ASME Standard OM-10.

Question Group 43

Question

equipment inoperable when it really may not

For some time, the NRC staff has beenconcerned with the unrestricted grace period

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for declaring a component inoperable allowed Responseby the ASME Code. One example of thisgrace period is the 24-hour delay allowed byIWV-3417 of Section XI following a failure ofa valve to exhibit the required change of diskposition. The staff's concern in this area hasbeen expressed to individual licensees onmany occasions. In order to provide guidancethat is consistent with the Standard TechnicalSpecifications and that can be applied generi-cally, the staff developed Position 8 ofGeneric Letter 89-04 which states that theunrestricted grace period in the ASME Code isunacceptable. Once a component is declaredinoperable, the action statement in theTechnical Specifications would provide timefor evaluation of the situation, including per-forming the test, before change is required inplant operating mode. A licensee maypropose alternatives to the NRC staff'sposition. For example, a valve stroke timethat is less than the limiting stroke time couldbe established as an alert time. If the alerttime is exceeded and the limiting time is not,the licensee would initiate a 24-hour periodfor evaluating the condition of the valvebefore declaring it inoperable.

Question Group 44

Question

Address the conflicts between the backgroundof the generic letter which states "The intentof testing is to detect degradation affectingoperation and assess whether adequatemargins are maintained" and Position 8regarding the starting point for TechnicalSpecification ACTION statements. This willrequire declaring components inoperablewhich are capable of fulfilling their safetyfunction (i.e., operable).

The staff does not see a conflict between thestatement in the background and Position 8 ofGeneric Letter 89-04. Testing is intended todetect degradation of a component and toprovide assurance that adequate margins aremaintained. Where testing indicates that acomponent has undergone such degradationthat its operability is in question (e.g., thelimiting value of full stroke time for a valvehas been exceeded), Position 8 of the genericletter requires that the component be declaredinoperable. Question Group 45

Question

Referring to paragraph 8, after testing a pumpand declaring it inoperable, is it acceptable toreplace the process instruments with testinstruments which are more accurate thenretest, rather than recalibrating processinstruments?

Response

Accuracy of the instrumentation is animportant consideration in the performance ofa test. In addition, the test must be performedin a manner that allows the test results to becompared for trends. This consistent perfor-mance of a test is sometimes referred to as"repeatability." Where instruments with dif-ferent characteristics (such as with respect torange and accuracy) are used for each test, theability to monitor the results for trends may belost. Therefore, the staff prefers that the sameset of instruments be used in performing testson a particular component. This can beaccomplished most readily by use of properlycalibrated process instruments installed in thesystem. The installation of testinstrumentation that are more accurate than

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the process instruments is allowed by the If it is obvious that a test has been runASME Code. For the example cited by the incorrectly (i.e., a recorded parameter is out ofquestion, after declaring the pump inoperable the range of the device being tested), do webecause of the test results from process still enter the action statement before re-instruments, the operability of the pump may running the test? be verified by more accurate test equipment. Because the same instruments should be used Responsefor tests to monitor the results for trends, thelicensee should recalibrate the processinstruments for their continued use or shouldestablish a procedure to use the more accuratetest instruments from that point forward.

Current Considerations

Paragraph 4.5 of OM-10 discussesestablishment of new reference values as maybe necessary when using different instruments. Paragraph 6.1, "Acceptance Criteria," of OM-6 allows that "[w]hen a test shows deviationsoutside of the acceptable range . . . theinstruments involved may be recalibrated andthe test rerun." (See Section 5.6).

Question Group 46

Questions

In reference to Item 8 of Attachment 1, it "Information to Licensees Regarding Twostates that the provisions to recalibrate in NRC Inspection Manual Sections onIWP-3230(d) Resolution of Degraded and Nonconformingcan only be done after the component is Conditions and on Operability," the NRC helddeclared inoperable. What if, during a pump workshops for regional offices and industrytest, before test data is taken, it is clearly representatives and gave guidance onobserved that a gauge is malfunctioning. Do I nonconforming conditions that apply to ISTneed to declare the pump inoperable, or can I requirements.stop testing and recalibrate?

If a test is under way (regardless of whethertest data have been taken) and it is obviousthat a gauge is malfunctioning, the test may behalted and the instruments should be promptlyrecalibrated. One example might be a wildlyfluctuating gauge. It should be noted,however, that, in many situations whereanomalous data are indicated, it may not beclear that the problem lies with the gauge. Inthese cases, the licensee should attribute theproblem to pump performance. The licenseewould then declare the pump inoperable andevaluate the condition of the pump during thetime allotted by the applicable TechnicalSpecification.

Current Considerations

Section 3.1.2 and Section 6 discuss furtherinformation. After issuing GL 91-18,

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NRC STAFF POSITION 9,“PUMP TESTING

USING MINIMUM-FLOW RETURN LINESWITH OR WITHOUT FLOW MEASURING DEVICES”

Position 9

An inservice pump test requires that the pumpparameters shown in Table IWP-3100-1 bemeasured and evaluated to determine pumpcondition and detect degradation. Pumpdifferential pressure and flow rate are twoparameters that are measured and evaluatedtogether to determine pump hydraulicperformance.

Certain safety-related systems are designedsuch that the minimum-flow return lines arethe only flow paths that can be utilized forquarterly pump testing. Furthermore, some ofthese systems, do not have any flow path thatcan be utilized for pump testing during anyplant operating mode except the minimum-flow return lines. In these cases, pumpingthrough the path designed for fulfilling theintended system safety function could result indamage to plant equipment. Minimum-flowlines are not designed for pump testingpurposes and few have installed flowmeasuring devices.

In cases where flow can only be establishedthrough a non-instrumented minimum-flowpath during quarterly pump testing and a pathexists at cold shutdowns or refueling outagesto perform a test of the pump under full orsubstantial flow conditions, the staff hasdetermined that the increased interval is anacceptable alternative to the Coderequirements provided that pump differentialpressure, flow rate, and bearing vibrationmeasurements are taken during this testing and

that quarterly testing also measuring at leastpump differential pressure and vibration iscontinued. Data from both of these testingfrequencies should be trended as required byIWP-6000. Since the above position is adeviation from the Code-required testing, itshould be documented in the IST program.

In cases where only the minimum-flow returnline is available for pump testing, regardless ofthe test interval, the staff's position is that flowinstrumentation which meets the requirementsof IWP-4110 and 4120 must be installed in themini-flow return line. Installation of thisinstrumentation is necessary to provide flowrate measurements during pump testing so thisdata can be evaluated with the measuredpump differential pressure to monitor forpump hydraulic degradation.

NRC Bulletin 88-04, dated May 5, 1988,advised licensees of the potential for pumpdamage while running pumps in the minimum-flow condition. The above guidelines formeeting the Code or performing alternativetesting is not intended to supercede the thrustof this Bulletin. Licensees should ensure thatif pumps are tested in the low flow condition,the flow is sufficient to prevent damage to thepump.

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Questions and Answers on Position 9 duce data of marginal value and provide little

Question Group 47

Question

With reference to the Generic Letter item 9, incases where only the minimum flow returnline is the available path, would the genericletter be revised to consider reducing the 5-minute time required for stabilizing the pumpas required by IWP-3500(a) to a lesser timesuch as 2 or 3 minutes in order to minimize thepossibility of pump damage occurring duringthe pump's operational test?

Response

The staff does not intend to revise GenericLetter 89-04 to change any current positionsor to address additional issues. If there is aproblem concerning compliance with theASME Code, requests for relief from the Codemay be submitted.

Current Considerations

Paragraph 5.6, "Duration of Tests," of OM-6specifies the minimum run time as 2 minutes. Refer to Section 5.8 of the guidelines.

Question Group 48

Question

If mini-flow recirculation lines areinstrumented for flow, are quarterly testsalone, which measure flow, differentialpressure, and vibration, acceptable?

Response

Mini-flow recirculation line tests are notprohibited by Section XI of the ASME Code. The staff, however, believes that a mini-flowtest can be detrimental to a pump and is not adesirable test configuration. These tests pro-

confidence in the continued operability of thepump. The staff would prefer a morecomprehensive test performed at somereduced frequency rather than relying only onthe mini-flow test that is performed quarterly. This particular issue may be a topic of anothergeneric letter addressing inservice testing inthe future.

Current Considerations

Paragraph 3.2, "Bypass Loops," of OM-6allows that "[a] bypass test loop may be used,provided the bypass is designed to recognizethe pump manufacturer's operating conditionsfor minimum flow operation."

Question Group 49

Question

Many mini-recirculation lines have no meansto adjust flow to a reference value prior totaking data. Thus, this recirculation flow isrelatively fixed. Since Table IWP 3100-2limits are placed in differential pressure, whatcriteria should be used to place limits on flow? Even with a fixed-flow system, measured flowwill demonstrate some variation test-to-testdue to instrument repeatability, operatorinterpolation of needle position on meter face,etc. Table IWP 3100-2 limits do not seemappropriate for flow in this case. To allowboth flow and differential pressure to varywithin 13% ranges does not appear to meetthe intent of Section IWP.

Response

In most cases, mini-flow recirculation lines donot have flow adjustment capability. TheASME Code recognizes this in IWP-3110,which permits the use of one or more fixedsets of reference values for pump testing. TheCode identifies acceptance criteria for bothdifferential pressure and flow rate in Table

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IWP-3100-2. It is not permissible for both event of a plant emergency, the system couldparameters to vary during a test. With one be realigned for operation in short order. parameter set at a reference value, the other Where one train of a safety system will be dis-parameter is compared to the acceptance abled for an extended period or both trains ofcriteria. the system must be made inoperable to

Current Considerations testing schedule that provides for verification

Refer to Section 5.3 of the guidelines. performed during periods (e.g., refuelingParagraph 5.2(c) of OM-6 allows that outages) when availability of the system is not"[w]here system resistance cannot be varied, essential to plant safety. flow rate and pressure shall be determined andcompared to their respective reference Current Considerations values."

Question Group 50

Questions

It is more desirable to test pumps at substantialflow conditions than on mini-recirculationlines. Should entire trains of safety systems bedeclared inoperable and 72 hour actionstatements entered solely to realign these sys-tems for inservice testing? Does the obtainingof "better" pump data justify the increased riskto the public during the time the systemcannot perform its safety function?

Response

As stated in the question, it is more desirableto test pumps with substantial flow than inmini-flow recirculation configurations. TheNRC staff, however, does not agree with thequestioner that the performance of inservicetesting results in increased risk to the public. Inservice testing is intended to provideassurance of the continued operability ofpumps and valves. To provide this assurance,it is considered acceptable for a TechnicalSpecification action statement to be enteredon infrequent occasions in order to test a com-ponent. Where a system must be taken out ofservice to perform a test, it is likely that, in the

perform a test, the licensee should propose a

of component operability with testing

Refer to Section 3.1.2.

Current Considerations for Position 9

The OM committee has prepared changes tothe OM Code to include a "comprehensivepump test" for testing at full or substantialflow conditions to monitor Code parameters. The changes were in the 1994 Addenda to theOM Code.

When testing using the guidance in Position 9,if a pump is in the alert or required actionrange, it is recommended that efforts be madeto take corrective actions during the outageand repeat the test post-maintenance. Whencorrective actions cannot be taken during theoutage (e.g., a pump rebuild is needed, butparts are not available), or when maintenancemust be performed during power operations(e.g., to clean mussel buildup from the pumpinternal cavity), it is recommended that testingto the extent practical during power operationsbe conducted following corrective actions andprior to returning the pump to service. Additionally, it is recommended that anevaluation of the results be performed andcompared to historical results of both thequarterly testing on minimum recirculationand the full- or substantial-flow testingperformed during outages to further ensure

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that the pump rebuild was adequate. To meetopportunity. Position 9 guidance, the full-flow testingwould be conducted at the first available

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NRC STAFF POSITION 10,“TESTING CONTAINMENT ISOLATION VALVES”

Position 10

All containment isolation valves (CIVs) thatare included in the Appendix J, programshould be included in the IST program asCategory A or A/C valves. The staff hasdetermined that the leak test procedures andrequirements for containment isolation valvesspecified in 10 CFR 50, Appendix J areequivalent to the requirements of IWV-3421through 3425. However, the licensee mustcomply with the Analysis of Leakage Ratesand Corrective Action requirements ofParagraph IWV-3426 and 3427(a).

IWV-3427(b) specifies additionalrequirements on increased test frequencies forvalve sizes of six inches and larger and repairsor replacement over the requirements of IWV-3427(a). Based on input from many utilitiesand staff review of testing data at some plants,the usefulness of IWV-3427(b) does notjustify the burden of complying with thisrequirement. Since this position represents adeviation from the Code requirements, itshould be documented in the IST program.

Questions and Answers for Position 10

Question Group 51

Questions

In regard to Attachment 1, Position 10, whycan't valves other than containment isolationvalves (CIVs) that are 6 inches or larger beexempt from the needless requirement ofIWV-3427(b)?

Does the exemption from IWV-3427(b)

pertain to pressure isolation valves (PIVs) aswell as Appendix J valves?

Do PIVs have relief from IWV-3427(b)? Item10 on Attachment 1 only discusses CIVs.

Response

The relief from IWV-3427(b) of the ASMECode granted through Generic Letter 89-04only applies to CIVs under containment leakrate testing. This position was written inresponse to numerous relief requestsconcerning CIVs from licensees that citeddifficulties in trending leak rate data. Wewere not aware of similar difficulties withPIVs during reactor coolant system leaktesting. The relief from the explicitrequirements of IWV-3427(b) should not betaken as an indication that the NRC staff isdisregarding the value of trending CIV leaktesting data. Until more information isavailable on appropriate leak rate limits andon reasonable scatter of data, however,Position 10 will remain in effect for CIVs. The NRC staff anticipates developing a morecomprehensive position of the subject in afuture generic communication to licensees.

Current Considerations

Alternatively, the licensee may conduct leak-rate IST in accordance with OM-10, whichdoes not include the IWV-3427(b)requirement. Refer to Section 4.4.5.

Current Considerations for Position 10

In revising 10 CFR 50.55a(b), the NRCincorporated, by reference, the 1989 edition ofSection XI, and created an exception to the

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requirements for containment isolation valves with IWV, Position 10, or paragraph 4.2.2.3 ofin paragraph 4.2.2.2 of OM-10. Until this OM-10. Recently, the OM committee createdexception is deleted from the regulation, a task force to respond to the staff's concernsleakage rates for containment isolation valves and a paper was presented to the OMare required to be monitored in accordance Subcommittee on Performance Testing in

Baltimore, Maryland, September 1993. (SeeSection 4.4.5).

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NRC STAFF POSITION 11,“SCOPE OF INSERVICE TESTING PROGRAMS”

Position 11

The 10 CFR 50.55a requires that inservicetesting be performed on certain ASME CodeClass 1, 2, and 3 pumps and valves. SectionXI Subsections IWP-1100 and IWV-1100defines the scope of pumps and valves to betested in terms of plant shutdowns andaccident mitigation. The plant's FSAR (orequivalent) provides definitions of thenecessary equipment to meet these functions. The staff has noted during past IST programreviews and inspections that licensees do notalways include the necessary equipment intheir IST programs. Licensees should reviewtheir IST programs to ensure adequate scope. Examples that are frequently erroneouslyomitted from IST programs are as follows:

(a) BWR scram system valves

(b) control room chilled water system pumpsand valves

(c) accumulator motor operated isolationvalves, 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 fail-safe position

(h) valves in mini-flow lines

It should be recognized that the aboveexamples of pumps and valves do not meet the

IWP and IWV scope statement requirementsfor all plants.

The intent of 10 CFR 50 Appendix A, GDC-1,and Appendix B, Criterion XI, is that allcomponents, such as pumps and valves,necessary for safe operation are to be tested todemonstrate that they will performsatisfactorily in service. Therefore, while10 CFR 50.55a delineates the testingrequirements for ASME Code Class 1, 2, and3 pumps and valves, the testing of pumps andvalves is not to be limited to only thosecovered by 10 CFR 50.55a.

Questions and Answers for Position 11

Question Group 52

Question

IWV-1200 specifically exempts control valvesfrom testing. Why are these valves includedin the list of examples in IST program scope aspart of Attachment 1?

Response

IWV-1200 of the ASME Code does notexempt valves that have a required safetyfunction from the provisions of Section XI. Code interpretation XI-1-83-59 states that it isa requirement of Section XI that flow controlvalves that have one or more defined safety-related functional requirements be classifiedCategory A or B, as applicable, and tested inaccordance with the requirements ofSubsection IWV. This philosophy applies toall control valves that have one or moredefined safety-related functionalrequirements.

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Current Considerations Response

On October 8, 1985, the ASME Codecommittee revised interpretation XI-1-83-59Rwith the reply stating "[i]t is the Owner'sresponsibility to categorize valves as requiredby IWV-1400 and in accordance with thecriteria IWV-2200." Refer to Section 4.2.9.

Question Group 53

Questions of the ASME Code for inservice testing of

Please clarify the last three lines of GenericLetter item 11 of Attachment 1.

The scope statement of Position 11 is muchtoo vague. The position with respect toprogram scope must be clarified and explainedto provide further guidance and should alsoaddress the backfit issue. In addition, in thepast, it has been the practice of addingadditional components to the scope of ISTPrograms via the authority of10 CFR 50.55a(g)(ii). How will this beaddressed in the future?

Do safety-related components outside of Class1, 2, and 3 need to be tested in accordancewith the Code and be included in the ISTprogram, or is it the intent to have some formof testing to demonstrate operability?

In reference to Item 11 of Attachment 1,please clarify the intent of the last sentence ofthis item: "Therefore, while 10 CFR 50.55adelineates the testing requirements for ASMECode Class 1, 2, and 3 pumps and valves, thetesting of pumps and valves is not to belimited to only those covered by10 CFR 50.55a."

How will the NRC review pump and valvetesting not included in the scope of the ISTprogram? Will the ASME Code requirementsbe applied to these components?

Criterion 1 in Appendix A to 10 CFR Part 50requires, among other things, that componentsimportant to safety be tested to qualitystandards commensurate with the importanceof the safety functions to be performed. Appendix B to Part 50 describes the qualityassurance program, which includes testing, forsafety-related components. Paragraph (g) of10 CFR 50.55a requires the use of Section XI

components covered by the Code. For othercomponents important to safety, the licenseealso has the burden of demonstrating theircontinued operability. The list provided inPosition 11 contains examples of componentsthat have been shown by our experience to befrequently omitted from a routine testingprogram. The licensee should review thesafety significance of these identifiedcomponents to ensure that the inservicetesting is adequate to demonstrate their con-tinued operability. NRC inspectors willevaluate the adequacy of such testing. TheCode-required IST program is a reasonablevehicle to provide a periodic demonstration ofthe operability of pumps and valves notcovered by the Code. If non-Codecomponents are included in the ASME CodeIST program (or some other licensee-developed inservice testing program) andcertain Code provisions cannot be met, theCommission regulations (10 CFR 50.55a) donot require a "request for relief" to besubmitted to the staff. Nevertheless,documentation that provides assurance of thecontinued operability of the non-Codecomponents through the performed testsshould be available at the plant site.

Current Considerations

Refer to Section 2.2.

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Question Group 54 they undergo component testing.

Questions

The Diesel Generator air start system directionthat was in the initial draft of Generic Letter89-04 has now been dropped. Can we removethe testing from our program?

In Position 11, why were the emergency dieselgenerator support system components deleted Are the items listed in Attachment 1 numberfrom the list in the final version of the letter? 11c, d, and e specific to PWRs?

Response Response

Typically, the Emergency Diesel Generator air The listed items were not intended to apply tostart system is not Code Class 1, 2, or 3 and, every plant. Each licensee should review thetherefore 10 CFR 50.55a does not require the list and determine those items applicable to itstesting of these components to be performed facility. In response to the specific question,under the provisions of the ASME Code. items 11c, d, and e do not apply to BWRs. Emergency Diesel Generator air start, coolingwater, and fuel oil transfer systems, however, Current Considerations for Position 11are considered safety related. As such,Appendices A and B to Part 50 require that

Current Considerations

Refer to Sections 2.2 and 3.4.

Question Group 55

Question

Refer to Section 2.2.

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OTHER QUESTIONS SUBMITTED DURINGGENERIC LETTER 89-04 MEETINGS

Schedule for Implementing theGeneric Letter

Question Group 56

Questions

The scope of the Generic Letter is broad andrequires more than the allotted 6 months forresponse. What guidance can be given forextension of the response date?

How much is expected to be done at the endof 6 months?

What is the schedule requirement forimplementing additional or revised testingarising from the activities related to thegeneric letter? Keep in mind that the resultsof reviews and evaluations must be availableprior to revising and implementing the relatedprocedures.

Do the requirements to conform to the statedpositions of the generic letter within 6 monthsof the date of the letter mean that allprocedures have to be revised and approvedwithin this 6 month period, or is it acceptableto have procedures in the process of beingrevised within the 6 month period?

Due to outage schedules and constraints, arethere any provisions for not completing allequipment modifications within 18 months ofthe date of confirmatory letter, or the firstscheduled refueling outage following the con-firmation letter?

How are extensions of the October 3, 1989deadline viewed; what factors are consideredon such requests?

Do utilities have to contact their ProjectManagers to schedule immediately a meetingto resolve any requested relief requestsoutside the generic letter (prior to required testfrequency) to obtain approval and avoidviolation after submittal, or will there be agrace period?

Response

With regard to plants not listed in Table 1 or 2of Generic Letter 89-04, the intent has beenthat, by the end of six months, (1) the ISTprogram would be revised to incorporate allthe requirements of the generic letter, (2) theprocedures would be written andimplemented, (3) the confirmation letter andany necessary additional relief requests wouldbe submitted to the NRC, and (4) a schedulewould be provided for any plant modificationsnecessary to comply with the requirements. Ithas been additionally intended that any neces-sary equipment modifications be completedwithin 18 months of the date of theconfirmation letter or the first scheduledrefueling outage following the confirmation,whichever occurs later.

We have received several comments statingthat this schedule may not be achievable. Forexample, one licensee noted that acceptancecriteria need to be developed beforeprocedures can be prepared and implemented. Following preparation of the procedures,several weeks were said to be needed toprovide the necessary training to plantpersonnel on various shifts. Another licenseeindicated that the resources necessary toimplement the generic letter had to bedetermined to justify to management the needfor contractor assistance. Even wherelicensee management accepts the justificationfor contractor assistance, it was said that few

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highly qualified contractors in the area of Question Group 57inservice testing are available. With respect toequipment modifications, one licenseehypothesized a situation where a refuelingoutage began soon after the confirmationletter and the next refueling outage would be amonth or two beyond the 18-month limit.

Several reasons that the NRC staff does notconsider sufficient to justify not meeting theschedule in the generic letter were also givenby meeting attendees. These insufficientreasons include (1) the lack of activity relativeto Generic Letter 89-04 until the NRCmeetings took place and (2) the lack of adesignated individual responsible for IST atthe plant when the generic letter was issued. If any particular plant anticipates a problem inmeeting the schedule, this should have beendiscussed with the NRC Project Manager. Indetermining the necessary scheduleextensions, licensees should have limited therequest for schedule relief to the smallest setof revisions to the IST program andprocedures, and modifications to equipment. The information submitted to the NRC by thelicensee to justify a delay in meeting theschedule established in Generic Letter 89-04should have contained at least (1) adescription of the actions to be completed byOctober 3, 1989, including an interim scheduleof accomplishments by system andcomponent, (2) a description of the action forwhich an extension in the schedule is beingrequested with the specific proposedschedules for the program, procedures, andany necessary equipment modifications, and(3) a discussion of the specific reasons for theneed to extend the schedule, including thehierarchy of the proposed schedule extensionsas established by their importance anddependence on the completion of otheractions.

Questions

Does the NRC expect the licensee to take anyspecific action prior to receipt of the SER?

Is it the intent to have all implementingprocedures of changes required byAttachment 1 be completed within 6 months? Does this apply to Table 1 and Table 2 plants?

Response

The positions in Generic Letter 89-04 addressboth program and procedural issues. Positions4, 5, and 8 are related to procedures andwould not be covered by a review of the ISTprogram. The remainder of these positions arerelated to both the IST program and theprocedures. For Table 1 plants, we believethat it would be reasonable for the genericletter provisions to be implemented within sixmonths of issuance of the SER. The preciseschedule, however, will be specified in theSER. The schedule for Table 1 plants is keyedto the SER because the licensee needs anopportunity to review the SER before havingto commit to an implementation schedule. Nevertheless, the staff encourages Table 1plants to begin verifying that plant proceduresare consistent with the generic letter beforereceipt of their SER. Table 2 licensees shouldverify that plant procedures are consistentwith the generic letter positions within sixmonths of issuance of Generic Letter 89-04.

Confirmation Letter

Question Group 58

Questions

With our confirmation letter will be a coupleof relief requests. How will they be handled?

NUREG-1482#���

Can we assume relief is granted? Do we have Table 1 or 2 (i.e., plants that will be submittingto wait for your SER? a confirmation letter), any requests outside the

What is the level of information expected in before April 3, 1989 are approved by thethe response to the generic letter? How issuance of the Generic Letter. If a reliefdetailed must it be? request is submitted after April 3 or a relief

Is "relief" required for items per Generic the requested relief may not be implementedLetter 89-04 which differ from the ASME until receipt of staff approval. The date byCode? which these relief request approvals are

Response letter so that their review may be prioritized.

A confirmation letter from a particularlicensee may contain several forms ofinformation, depending on the IST program. The confirmation letter should address theextent to which the licensee's program andprocedures meet the positions attached toGeneric Letter 89-04. It is anticipated thatmost licensees will have to modify their ISTprograms as a result of the generic letter. Therevised program should accompany theconfirmation letter. In cases where a genericletter position that approves an alternative tothe ASME Code is being followed, a reliefrequest is not required, but the deviation fromthe Code should be documented in the ISTprogram along with its method of approval(i.e., through the relevant generic letterposition). As a suggestion, licensees mayreserve the use of the term "relief request" forthose cases where specific staff review andapproval are needed before implementation.

If a licensee cannot meet one of the genericletter positions, an alternate test method maybe performed, providing the provisions ofParagraph B of the generic letter are met. This Paragraph B approach for generic letterpositions does not require a relief request butthe justification should be retained in the ISTprogram. In that the generic letter does notsupersede the regulations in any way, theoption still exists to submit requests for relieffrom the Code for program-related positions inthe generic letter. For plants not listed on

scope of the generic letter that were submitted

request submitted before April 3 is modified,

needed should be specified in the confirmation

Verification of Generic LetterImplementation

Question Group 59

Questions

When and how is guidance going to beprovided to the Regional offices on inspectionand enforcement of the issues stated in theGeneric Letter?

Regarding the approval of the IST Programscope and related relief requests, it appearsthat NRC is not planning to perform detailedreview and is merely stating that theirresponsibility re. 10 CFR 50.55a is satisfied bythe generic letter supplemented by plant siteinspections. This eliminates the pre-approvaldiscussions done previously; however littleguidance is provided to give licensees'sconfidence that the subjective opinions of thevarious inspectors can be anticipated beforethe fact. It would help if there were somemechanism whereby a utility could receive anofficial opinion/ determination with respect toprogram scope and relief request queries in atimely manner.

With respect to inspections, will there be aninspection module developed, or is this to bean "ad hoc" type of inspection?

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To what extent is the NRC planning to make NRC review before their implementation,their guidance uniform policy for all licensees may direct questions concerninginspections? It is very important that uniform interpretation of requirements on the ISTpolicy be applied at all facilities, regardless of program and procedures to the NRC staffthe composition of inspecting teams. through their Project Manager.

Many alternatives that are given seem vague Question Group 60and subject to interpretation. Who decidesadequacy and what are the ramification ofdifferences between licensees and the NRC?

What guidance will Region/NRR auditors usein accessing IST Programs for Table 1 or 2plants? Will they use the SER or the genericletter?

Response

The NRC staff has been performing activitiesto provide assurance that application of thegeneric letter by the inspectors will beconsistent. For example, a meeting to discussthe generic letter was held in Rockville,Maryland, in April 1989, and each NRCRegion office was represented. A temporaryinstruction (TI) will be written by NRC/NRR,providing guidance to the regional inspectorson prioritized inspection activities for IST andthe Generic Letter 89-04. It is intended thatthe TI will be completed in six to eightmonths. Periodic NRR/Region counterpartmeetings will be held to ensure consistency onthe IST subject matter. Additionally, theinspection teams are expected to be made upof NRC/NRR, NRC Region, and contractorpersonnel, thereby providing for consistentcommunication. These inspections will assistthe staff in verifying the adequacy of the ISTprogram rather than verifying adequacy by thetraditional staff review. It is intended that theinspectors will rely on the generic letter, thetemporary instruction, and the particular SERfor Table 1 and 2 plants. These inspectionswill not be performed on an ad hoc basis. Although only relief requests will r eceive

Questions

If the SER does not constitute NRCconcurrence that the generic letterrequirements (at least those that are routinelyaddressed in the program submittal) are met,then how will issuance of SERs to Table 1 orTable 2 plants constitute NRC approval of theIST program?

Will all SERs issued in the near future, orrecently issued, incorporate all the issues inthe generic letter?

Response

It is recognized that the positions in GenericLetter 89-04 go beyond the areas covered bypast SERs on inservice testing. Positions 4, 5,and 8 deal with procedural matters that are notreflected in the IST programs and SERs. Therefore, it cannot be expected that an SERwould constitute concurrence that all of thegeneric letter positions have been met. TheSERs for Table 1 and 2 plants explicitlycontain approval only for relief requests. These SERs can be considered as providingIST program approval only in that the practicehas been to perform a thorough review andidentify problem areas that need resolution.

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Updates and Revisions of the ISTProgram

Question Group 61

Questions

If relief requests exist that do what one, orany, of the positions state, should theserequests be retracted with theconfirmation/resubmittal?

Do "changes to the program" includeadministrative changes such as referencingdifferent procedures, or just intent ofprogram?

In instances when a licensee modifies theirIST program beyond that currently submittedto the NRC, [as discussed in] Paragraph D ofthe generic letter, and reviews themodification against the positions found inAttachment 1, is it required that the ISTprogram modifications be submitted to theNRC?

Our plant is on Table 1. We have revised theprogram to identify Generic Letter 89-04 as areference and made some minor changesconsistent with the letter. Do we need toresubmit the program?

Are all future revisions to the IST programrequired to be submitted to the Commission? Section D of the generic letter is silent on thissubject.

Does the generic letter mean that programsubmittals are no longer required? Under whatcircumstances are submittals still required?

Should we provide changes to the NRC assoon as made even if numerous "trivial" or"typo" changes are being issued? What aboutthe "complete and accurate" requirement in10 CFR 50.9?

Should updated plans document specific reliefrequests that were approved on a prior date?

Since programs are revised frequently and in apiece-meal fashion, does the NRC expect eachchange to be submitted as soon as it's made, oris once per year, once per two years, etc.adequate?

Response

The NRC staff should have the current ISTprogram being implemented at each plant evenif this means that a licensee sends multiplesubmittals to the NRC each year. The mostup-to-date version of an IST program will notbe used for the purpose of the staff performingcomplete program reviews as has been done inthe past. Rather, it is needed to prepare forIST inspections and to assist in the review ofrelief requests. The staff would prefer to havea complete program rather than individualchanged pages. The identification in theprogram of the mechanism for approval ofspecific relief requests would be particularlyhelpful. That is, the program should indicatewhether the approval is (1) through a positionin Generic Letter 89-04, (2) by virtue of therelief request being outside the scope of thepositions in the Generic Letter and submittedbefore April 3, l989, (3) through themechanism described in Paragraph B in thegeneric letter, or (4) obtained using a reliefrequest that will need staff approval by aspecific date. Currently-approved reliefrequests that follow a generic letter positionshould not be retracted but the source ofapproval (i.e., the generic letter) should beidentified in the IST program. Non-technicaland minor typographical changes may be helduntil the licensee has collected several suchchanges. This is considered to meet the intentof 10 CFR 50.9 for complete and accurateinformation. For plants not listed in Table 1 or2, revisions to the IST program should be sentwhen the confirmation letter is submitted.

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Current Considerations IST program is complete and all components

The program documents submitted to the NRCare used to prepare for IST inspections and toreview relief requests. The program documentneed not be submitted more often thannecessary to reflect major changes, but it isexpected that licensees make changes to thedocument periodically, and once per cycle, oronce every other cycle, a complete, up-to- Questionsdate, copy should be submitted to the NRC. The IST program document that is used by theNRC for situations that arise at facilitiesshould be reasonably up to date. If thelicensee keeps the IST program document upto date, it would not be a substantialadministrative cost to copy it once every twoto three years and submit it to the NRC so thatthe copy used by the staff reflects changes inthe pump and valve lists. Unless a licenseemakes changes to the IST program, there is noneed to submit a copy more often.

Question Group 62

Questions

If valves are added to or removed from the usually provides information on the reason thesystem, does the change to the program relief request was denied andrequire resubmittal? Can components be recommendations on appropriate actions fordeleted without prior NRC approval? the licensee. The last sentence of Section D is

Response should be followed.

Neither the Commission regulations in10 CFR 50.55a(g), in general, nor GenericLetter 89-04, in particular, require the licenseeQuestionsto obtain NRC approval on each test on everycomponent in the IST program. As long as theprogram is consistent with the regulations, theASME Code, and the Generic Letter, relief isnot required. To amplify, deletions from oradditions to the IST program do notnecessarily require NRC approval. Theburden is on the licensee to verify that their

that require IST are included and tested to theextent practical. If a particular component isdeleted from the IST program, documentationof the reason in an appropriate place isrecommended.

Question Group 63

Please clarify the intent of the last sentence of[Section D]: "The modified program shouldcomply with the disposition of relief requestsin any applicable SER based on a previouslysubmitted IST program." The sentence quotedabove seems to apply to Table 1 or Table 2plants only. Also, the sentence seems to allowthe use of an extension of a previously grantedrelief request.

Response

Section D of the Generic Letter 89-04 appliesto all plants. Previously approved reliefrequests remain valid. However, if a reliefrequest has been denied in an SER, the SER

indicating that these recommended actions

Question Group 64

It is clear that if an NRC position is coveredby Attachment 1, then the licensee must eithercomply with or follow the alternate provisionscontained in Section B of the generic letter. But for program changes not covered byAttachment 1, [Section D] states that theprovisions of 10 CFR 50.55a(g) should be

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followed. This infers that a relief must be For future relief requests outside the scope ofsubmitted. Further, in accordance with the Attachment 1, what is the perceived ability ofplant Technical Specifications, relief must be the NRC regarding turnaround time? granted prior to implementation.

Response

It is correct that, where an IST program priority basis. Therefore, the licensee shouldchange is proposed that is outside the scope of specify the date by which the relief is needed,the positions in the Generic Letter and does and where possible, should provide additionalnot meet the Section XI requirements, the information to assist in this review, such aslicensee must submit a relief request to the "this relief request is identical to relief requestNRC for review. The program change may number X in the Unit 1 IST program." Thenot be implemented prior to staff approval. staff recognizes that, on occasion, there will

Question Group 65 will make every available effort to be

Questions

For plants with SERs, can changes to NRCreviewed and approved programs be madewithout additional submittals to the NRC? What if changes are in accordance with the If revised relief request submittals are notgeneric letter? considered approved, then do we continue

Response

As described in the response to Question 61,licensees need to send any changes to their The approved relief request is controlling untilIST program to the NRC. If these changes are the licensee receives approval of a revisedin conformance with Generic Letter 89-04, relief request. As we have indicated above, ifNRC review and approval are not necessary. plant operations and ASME CodeThe IST programs submitted to the NRC as a requirements dictate relief request approval byresult of program changes should indicate the a certain date, the licensee should indicate thatreasons for the changes and the relief requests, date in the submittal containing the reliefif any, that require staff review. request.

Relief Requests Current Considerations

Question Group 66

Questions

If a relief request issued for one unit has beenapproved, can, or will the turnaround time forapproval of the same relief request on asecond unit (for a two unit plant) be reduced?

Response

New relief requests will be evaluated on a

be a need for rapid NRC response. The staff

responsive to such needs.

Question Group 67

Questions

working to the presently approved request?

Response

For discussion on updates to the IST programfor the 120-month revision, see Section 3.3.3.

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Question Group 68 appropriate.

Question

Does a relief request that is grandfathered butno longer required still need approval?

Response Generic Letter. Previously approved relief

By grandfathered relief request, we assumethat the question is referring to a relief requestnot covered by the positions in Generic Letter89-04 but submitted before April 3, 1989. Withdrawal of relief requests, regardless ofthe prior approval status, is permitted withoutNRC review, presuming the IST programremains consistent with the regulations, theASME Code, or Generic Letter 89-04.

Question Group 69

Questions

Is a continuous feedback system required toprovide a mechanism to reverify that reliefrequests are still valid based on ongoingmaintenance and plant modification activities?

Response

The licensee is expected to have a feedbacksystem that will maintain the IST program as aliving document that will be updated to beconsistent with changes in plant configuration. If a particular relief request is no longerrequired because of changes in hardware,system design, or new technology, the licenseeis expected to revise the program to withdrawthe relief request. Conversely, if a system modification results in the addition of acomponent to the IST program, the feedbacksystem should ensure that the Code require-ments or Generic Letter 89-04 provisions aremet, or that a relief request is submitted, as

Question Group 70

Questions

Relief request requirements are changed in the

requests are now being challenged because theNRC uses a different reviewer. This appearsto be a backfit issue.

If relief was granted by the NRC for an itemduring the first interval, is the same reliefgranted during the second interval eventhough the relief is not in compliance with GL89-04?

In the 1st 10 Year submittal, an SER approveda relief request which is not consistent withthe alternative positions in Generic Letter 89-04. Does the generic letter void previouslyapproved alternatives/relief requests (via anSER) or may these alternatives/relief requestsnot consistent with Generic Letter 89-04 stillbe considered valid and so documented in theIST program?

When will it be known what the staff'sposition is on SER approved relief requeststhat contradict Generic Letter 89-04 dictatedtesting?

Response

We assume that the questions are not referringto interim reliefs but rather relief requests onwhich the NRC staff prepares an SER. Assuming that the reviewed information wascomplete, accurate, and remains up-to-date,an approved relief request may be currentlyfollowed even if it conflicts with the GenericLetter. These types of situations will bereviewed in preparation for inspections. Safety significant differences between the

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approved relief request and the Generic Letter Question Group 72will be discussed in an effort to obtain licenseeagreement to adopt the Generic Letterposition. Where agreement cannot bereached, the staff may consider initiation ofbackfit procedures. Relief requests aresubject to review by the NRC staff at the ten-year update for consistency with current NRCregulatory positions, including those containedin Generic Letter 89-04. Reliefs that areinconsistent with the generic letter wouldlikely not be approved for a succeeding ten-year interval.

Question Group 71

Questions

What is the long term status of the "relief"system?

Response

The section of the Commission's regulationspertaining to the relief request system is Current Considerations 10 CFR 50.55a. This regulation is not, andcannot be, superseded by Generic Letter 89- Although the documents need not be in the04. A revision to this regulation is under format of a relief request, the position wouldconsideration. With respect to the "relief" typically be clearly referenced for eachsystem as described in the regulation, the staff applicable component. If the format is a reliefmay, at some time in the future, issue request, the licensee would typically state thatadditional guidance to provide a pre-approval it is considered approved by the GL 89-04mechanism much as the generic letter does in position. (See Section 2.5.3).certain of its positions.

Current Considerations

Though the NRC did not "pre-approve" reliefrequests through the guidelines, severalsections in the guidelines allow the licensee touse certain OM-6 and OM-10 requirementspursuant to 10 CFR 50.55a(f)(4)(iv). (SeeSection 1).

Questions

To conform to generic letter positions, whatdoes "document in the program" mean? Should relief requests be generated with theunderstanding that the generic letter grantsthem? Or does a statement included in theprogram describing how the deviationconforms to the generic letter suffice?

Response

The IST program should include the deviationfrom the ASME Code that the licensee intendsto take, and the basis for the change just as aprogram would normally contain. Thereshould be sufficient information in theprogram to demonstrate that Generic Letter89-04 is applicable to the situation in questionand that the testing being performed conformsto the generic letter.

Question Group 73

Questions

Is the following statement correct? A reliefrequest submitted prior to April 3, l989 but notdiscussed in any SER and is not a subject ofgeneric letter attachment 1 is approved for usewithout any further utility reviews.

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Response Question Group 75

Relief requests that were on the docket beforeQuestionsApril 3, l989, for plants that are not in Table 1or 2 in Generic Letter 89-04 and are topicsthat were not discussed in Attachment 1 areapproved by this generic letter. Any reliefrequests outside of the Generic Letterpositions that are submitted after April 3, l989,will require staff review and approval beforeimplementation. The response to Question 74explains the basis for this approach. Otherstatements regarding utility's required actionsfor the review of implementing proceduresadditionally apply.

Question Group 74

Question

What is the NRC's basis for stating that would apply to all units specified in the SER. approval is by virtue of the generic letter for The SER for one unit may not be used as apreviously submitted relief requests when such basis for implementing the request before staffreliefs could be outside the scope of the approval. See also the response to Questionpositions in the generic letter and have not 66.undergone NRC review?

Response

From the general knowledge of the reliefrequests, the NRC staff selected the technicalissues considered the most significant to beaddressed by Generic Letter 89-04. The NRCstaff checked a sampling of the current ISTprograms to provide confidence that thoseissues not addressed in the Generic Letterwere not highly safety significant. Additionalissues that would require the NRC staff toperform a detailed regulatory analysis may beaddressed in future generic guidance.

Regarding a multi-site, if one unit has anapproved SER which grants relief on itemswhich do not meet all the criteria of thegeneric letter, can the approved SER provide abasis for the other unit to go ahead andimplement the relief request prior to NRC re-review (assuming design differences do notexist between the two units)?

Response

When relief is granted in an SER for oneparticular unit on a multiple unit site, thatrelief applies only to the one unit even if theother unit is essentially identical. If an SER iswritten for two (or more) units, the relief

Question Group 76

Questions

If an SER that is received by a plant on Table1 after the generic letter was issued denies arelief, and another plant that is not getting anSER has the same relief request grandfathered(approved), is this fair?

Response

Such situations will be considered by the NRCstaff when preparing for plant inspections. Safety significant differences between theapproved relief request and Generic Letter 89-04 will be discussed at that time to try toobtain licensee agreement to follow thegeneric letter. If agreement cannot be

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reached, the staff will consider the need to Responseinitiate backfit procedures.

Question Group 77

Questions complying with the relief. A revised program

Does the first sentence of [the ISTPROGRAM APPROVAL] section apply toTable 1 and Table 2 plants? The last sentenceinfers it does not.

Response

The first sentence of the "IST PROGRAMAPPROVAL" section of Generic Letter 89-04states that "[t]his generic letter approvescurrently submitted IST program reliefrequests for licensees who have not receivedan SER provided that they (1) review theirmost recently submitted IST programs andimplementation procedures against thepositions delineated in Attachment 1 and (2)within 6 months of the date of this letterconfirm in writing their conformance with thestated positions." This sentence applies onlyto plants not listed in Table 1 or 2.

Question Group 78

Questions

In the approval process, when an SERconditionally gives relief and requires furtherplan changes, is an SER supplement provided,or is relief approved by letter, or is the reliefgranted based on conformance to the SERstipulations?

Diablo Canyon's SER grants several reliefrequests with conditions. We are revisingreliefs to meet these conditions. Will we needNRC approval of revised reliefs prior toimplementation?

If the conditional approval specificallyidentifies what must be done to obtain relief,then conformance with the condition is

should be sent to the NRC stating that theconditions have been met. In that case, afollow-up SER would not be issued. Wherethe relief request is denied and the staff asksfor more information (e.g., additional analysisor basis), then a specific request must be madeto the staff for its review and approval beforeimplementation by the licensee.

Recent and Upcoming SERs

Question Group 79

Questions

For a Table 1 plant, can changes be made tothe IST program in accordance with thegeneric letter, even though the SER has notbeen received?

Response

Any licensee may revise its IST program toconform to Generic Letter 89-04. Thelicensee should provide changes to the ISTprogram to the NRC as discussed in theresponses to Questions 61 and 65.

Question Group 80

Questions

Will the implementation schedule forprocedure changes and hardware changes bespecified in the SER? Will this schedule besimilar to the generic letter; e.g., will thelicensee have six months to effect procedurechanges and 18 months/next refueling outageto make hardware changes?

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Response unapproved relief requests are required before

The implementation schedule for procedureand hardware changes will be contained in theSER. The NRC staff expects the schedules tobe similar to those in the Generic Letter 89-04. See also the response to Question 57.

Question Group 81

Questions

Before the SER is issued or for the first sixmonths thereafter, is it permissible for thelicensee to use its current IST program assubmitted to the NRC?

Response

Licensees should use the current version oftheir IST program. The generic letter, ineffect, provides interim approval of theexisting program for Table 1 licensees until theSER is issued.

Question Group 82

Questions

If a plant with an SER on its IST program hasa 10 year review up coming, how should thatbe handled? Resubmittal?

Response

A plant with an SER that is preparing arevision for the 10-year update should revisethe program to be in conformance with theprovisions of Generic Letter 89-04. Thelicensee does need to submit the programupdate to the NRC. The program shouldindicate which relief requests require NRCreview and approval and which relief requestsare already approved through the genericletter. Staff review and approval of the

the licensee implements the new program.

Alternatives to Positions in theGeneric Letter

Question Group 83

Questions

Are the new criteria always to be used even ifit is not applicable? Can it be partiallyimplemented if the licensee feels the reliefrequest is sufficiently justified by specific inhouse experience?

Response

Certain positions in the Generic Letter 89-04are not fully applicable to all plants. Forexample, the components listed in positions 3and 11 are not applicable to all plants. Further, Position 7 is applicable only toBWRs. Alternatives to the positions of thegeneric letter, or partial implementation as thisquestion suggests, should be justified inaccordance with Paragraph B of the letter. Specific in-house experience is only one of thesources of information that should be utilizedwhen evaluating alternative testing, and is nota substitute for the criteria in Paragraph B ofthe generic letter.

Question Group 84

Questions

Will any deviations from the requirements inthe Generic Letter be reviewed and an SERissued for those relief requests?

Is a relief request required when only 2 or 3 ofthe 4 items identified in Generic Letter ItemB, page 3, can be met?

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Generic Letter 89-04 states in Paragraph B, situation, a licensee may develop anthat when licensees are unable to comply with alternative testing method provided anthe positions of Attachment 1, evaluation of evaluation is performed that addresses fouralternate testing should address [four criteria]. specific criteria. The alternate test would notIs it mandatory for each instance to address all be acceptable unless the data associated with4 of the above items? In some instances or those criteria are sufficient to justify itssituations, the above items may not apply, or adequacy for detecting degradation andonly a portion may apply. When evaluating ensuring continued operability. Where thean alternate test to one of the Positions of four criteria are satisfied, the alternate test isAttachment 1 of Generic Letter 89-04, may considered approved by the generic letter andthe alternate test be implemented without may be implemented. The specificprior NRC approval providing an evaluation is justification is expected to be documented inperformed and documented and retained in the IST program submitted to the NRC, butthe IST Program? Does the documented need not be documented in the form of a reliefalternative test evaluation in the IST program request. This documentation will be subject tohave to be formally submitted to the NRC as review for completeness, accuracy, andan IST program revision, and if so, in what applicability during NRC inspections.time frame? On Page 2 of Ted Sullivan's review, he If at some time, the circumstances changeindicated that the NRC will not issue SERs in such that the justification obtained throughAttachment 1 items and justified alternatives. Paragraph B is no longer valid, then theAre the justified alternatives the 4 points on licensee must submit a relief request for staffpast component history? Can I use these 4 review before continuing the alternate test. alternatives to justify a deviation from the Paragraph B may also be used when futureAttachment 1 positions? If so, are these then revisions to the IST program relating to theapproved by the generic letter? After issuing a generic letter positions are prepared. If allconfirmatory letter, can I go through the four criteria cannot be met, then a reliefabove process to get "automatic" or pre- request must be submitted to the NRC and theapproval of Attachment 1 exceptions in the alternate test method cannot be implementedfuture? Can the 4 points be used for non until staff approval is received. For technicalAttachment 1 items following a similar issues outside the scope of the positions in theprocess? generic letter, the alternative provisions of

For relief requests not covered by this generic cases, a relief request must be submitted forletter, is (in accordance with Technical NRC approval before implementation. Specification 4.0.5) specific written approvalrequired prior to implementation? Current Considerations

Response Refer to Section 6 for additional information.

Assuming that Section XI will not be followed,Paragraph B of the Generic Letter 89-04provides guidance for the situation in which a Questionslicensee is unable to comply with one of thepositions of the generic letter because ofdesign considerations or personnel hazard (asopposed to inconvenience). In such a

Paragraph B may not be applied and, in these

Question Group 85

Since 10 CFR 50.55a(g) is a top tierdocument, is it still permissible to use itsprovisions of the relief request process when

NUREG-1482 #���

the requirements of the Code/generic letter be followed and comments will be solicited.cannot be met? Must these relief requests beapproved prior to implementation inaccordance with plant Technical Specification4.0.5? If a required test cannot be done,should the utility use the exigency provision?

Response

The provisions of 10 CFR 50.55a(g) remainavailable for the licensee's use for submittingrelief requests and obtaining approvals. Inaccordance with the Technical Specifications,approval of relief requests is required beforeimplementation. Relief requests shouldindicate the date by which approval is needed. Generic Letter 89-04 is providing anothermethod of receiving approval of deviationsfrom the ASME Code requirements. Thelicensee may prepare a case to justifypostponement of a particular test on the basisof exigency. At this point, we are unaware ofany aspect of Generic Letter 89-04 that wouldqualify for the exigency provision.

Current Considerations

Refer to Section 6 for additional information.

Question Group 86

Questions

Was the generic letter issued as opposed tochanging the regulation? Prior to regulationchanges, will comments be solicited from thelicensees?

Response

Generic Letter 89-04 is not considered analternative to the regulation but is a vehicle toobtain preapproved relief from certain ASMECode requirements. If the regulation ischanged, the normal rulemaking process will

Requests for Additional Information

Question Group 87

Questions

How do plants which have received requestsfor additional information (RAI) from theNRC but are not on the list of plants to receivean SER get RAI items resolved that are notaddressed in the Generic Letter? Does the Generic Letter or the RAI takeprecedence and which one must be compliedwith?

We received 86 questions (RAI from NRC) ofwhich some were general in terms. A coupledealt with justification wording in which thequestioner recommended a more detailedjustification, although the alternate methodwould remain the same. Would we have tomake these recommended changes andresubmit, or can we leave them alone? Ifrevision is more of an administrative wordingissue, then are they considered to require anSER?

What do I do about an RAI that I receivedprior to the generic letter and issues in the RAIare outside Attachment 1?

Response

There are a small number of plants that havereceived RAIs and that have not had an ISTreview meeting to discuss the RAI. Utilities inthis category are plants not on either Table 1or 2 and are expected to respond to GenericLetter 89-04 with a confirmation letter. Utilities that have received RAIs do not needto respond explicitly to the RAIs, but shoulduse them to assist in responding to the generic

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letter. The RAIs provide an indication of Question Group 90possibly weak or questionable aspects of anIST program. For those cases where the intentof an NRC question is unclear, licensees mayobtain clarification through the NRC ProjectManager.

Question Group 88

Questions

Some questions in a recent RAI are in conflict Category A valves such as the RCSwith previously approved relief requests. accumulator/core flood discharge checkWhich one must be complied with? valves which are monitored continuously for

Response

Previously approved relief requests remainvalid despite what might appear to be a The staff has no plan to issue a supplement toconflicting position in an RAI. This statement Generic Letter 89-04. Another generic letterassumes that the previously approved relief on IST may be issued in the future, but wouldwas granted on the basis of accurate and cover new topics or expand on the currentcomplete information available to the NRC scope of components covered by the ISTstaff at that time. program required by the ASME Code. The

Modification of the Generic Letter

Question Group 89

Questions

Is a NUREG to be issued on this GenericLetter to clarify underlying issues?

Response

There is no current plan to prepare a NUREGdocument to clarify any underlying issues withGeneric Letter 89-04. These minutes will besent to all licensees and attendees whoprovided their address.

Questions

Will Generic Letter 89-04 be updated fromtime to time to provide additional positions onIST programs in areas such as the following? The ASME Section XI Code does not requireleak testing for valves where leakage iscontinuously monitored, however, for PWRplants the NRC often requires leak testing for

seat leakage.

Response

Code does require that valves whose leak tightintegrity is important for performance of theirsafety function be individually leak ratetested. From the staff's experience, mostcontinuously monitored leakage detectionsystems do not verify the leaktight integrity ofeach valve in the flow path and the staff doesnot consider these systems to meet the Coderequirements.

Current Considerations

The Code requirements allow that the licenseeneed not leak test valves which functionduring of plant operation in a manner thatdemonstrates functionally adequate seattightness; however, the valve record shallprovide the basis for the conclusion thatoperational observations constitutesatisfactory demonstration.

NUREG-1482 #���

Backfit Concerns

Question Group 91

Questions

The Generic Letter states that "In cases whereconformance with the stated positions wouldresult in equipment modifications, the licenseeshould provide in his conformation letter aschedule for completing the requiredmodifications." The Generic Letter goes on tostate acceptable schedules for completion ofthese mods. Are these modifications subjectto the provisions of 10 CFR 50.109backfitting?

Please confirm that the NRC's opinion andpresent position is that the generic letter is notconsidered a backfit for all utilities.

Does the staff intend to do a backfit analysisregarding this position? We currently haveapproved relief requests for the first Ten YearInterval in which the staff has found our lackof instrumentation acceptable. This applies toother positions as well.

Do the modifications that are needed toconform with the stated positions require abackfit? If modifications are necessary tocomply with the stated positions, are reliefrequests necessary if it is deemed impracticalto make the modifications? If not throughrelief, how do we deal with these issues? What if no maintenance history is available tosubstantiate relief?

Defend or explain your basis for saying thegeneric letter does not require a backfit. Questions

Response

Generic Letter 89-04 was presented to theNRC's Committee to Review GenericRequirements (CRGR) as a backfit issue, andcertain positions were identified as changes topast staff positions. As discussed with theCRGR, the staff determined that thosepositions in the generic letter that representedchanges from previous staff positions werenecessary in order to bring licensees intocompliance with the Commission's regulations. Therefore, according to 10 CFR 50.109(a)(4)(i), a backfit analysis was not required tojustify issuance of the generic letter. If thepositions in the generic letter cannot be met,the option discussed in Paragraph B may beavailable. Further, if the licensee will not befollowing the generic letter positions,Paragraph B of the letter, and the ASMECode, the licensee must submit to the NRCstaff a request for relief from the ASME Code.

Where a licensee is following a provision of itsoperating license or a particular exemptionfrom the ASME Code that was granted by theNRC staff, a backfit analysis would need to beperformed by the NRC staff before requiringany change to that licensee practice. Withrespect to the staff review of previouslyapproved relief requests at the ten-year updateof the IST program, however, a backfitanalysis would not be necessary. See theresponse to Question 70.

Use of OM-6 and 10

Question Group 92

When addressing cold shutdowns, OM-10 usesstatements like "sufficient duration" and "shallcontinue." When trying to implement these

NUREG-1482#���

statements, operations personnel frequentlyask what is the NRC's definition of a cold Current Considerations shutdown of sufficient duration. Is coldshutdown testing expected to be back to back On September 8, 1992, the revised rule tooktests or can 1 or 2 days breaks be acceptable effect, as discussed in several sections of the(i.e. shall continue is not easily defined)? guidelines. The NRC did not require plants to

In 1987 and early 1988, the NRC rejected a 10 CFR 50.55a).general relief request to use OM-6 criteria forflow and delta pressure for pumps. Can wenow revise our program to use the criteria ofOM-6 and OM-10? If the answer is yes, dowe need a relief request?

What is the time frame for the10 CFR 50.55a(g) change? Is the NRC willingto accept the currently approved OM-6/OM-10? Will any of the guidance provided in thegeneric letter change with the implementationof Part 6 and Part 10 of OM?

Once OM-6 and OM-10 are approved, will itbe required to implement them immediately(within 6 months) or will they be implementedat the next program update?

Response

Rulemaking to reference ASME standardsOM-6 and 10 in the regulations is underway atthis time. It can be said, however, that, insome recent relief request evaluations, the useof the pump allowable range limits identifiedin OM-6 for flow rate and differential pressurehas not been found acceptable to the staff. The staff has not completed its assessment ofthe inter-relationship of Generic Letter 89-04and OM-6 and 10. When appropriate refer-ences to OM-6 and 10 are incorporated in theregulations, these standards may be used bythe licensee as the regulations permit the useof more recent referenced standards. Weanticipate that rulemaking to reference thesestandards will be issued for public comment inthe near future.

update on an accelerated schedule. (See

Solenoid-Operated Valves

Question Group 93

Questions

To perform position indication testing onsolenoid operated valves, is a light checkacceptable or must the position verification beperformed by running the system or injectingair, etc. to prove valve position? Is a remoteposition verification required for SOVs withno positive means available?

Response

Verification of remote position indication byIWV-3300 is required to ensure that theindication accurately reflects actual valveposition. This could take the form of adifferential pressure test, flow ratemeasurement, or other change in someparameter that positively shows that the valveis in the indicated position. An indirectverification, using techniques such asradiography, may also be acceptable. Current Considerations

Refer to Sections 4.2.5, 4.2.6, and 4.2.8 foradditional information.

NUREG-1482 #���

General Questions

Question Group 94

Questions

Please clarify what is meant by "one part of abroad effort" in the Background section of theGeneric Letter.

Response

Generic Letter 89-04 is part of a largerprogram to improve IST throughout theindustry and to provide additional informationand clarification on the subject to all affectedparties. The joint ASME/NRC Symposium onIST held in Washington, D. C., in August 1989is also part of this effort. Additional genericregulatory guidance may be prepared on otherIST aspects. For a discussion of the "broadeffort" that NRC is pursuing, refer to thesummary of the presentation by Tad Marshprovided in these meeting minutes.

Question Group 95

Questions

How do the Generic Letter 89-04requirements differ from the ASMErequirements?

Response

Generic Letter 89-04 is intended to providefundamental information on the NRC'sinterpretation of certain TechnicalSpecifications and ASME Code requirements,and to identify certain alternative testing thatthe NRC staff finds acceptable. The genericletter also goes beyond the ASME Code inthat it covers procedural issues in addition toprogrammatic issues.The generic letter may contain Code

interpretations that differ from those of certainlicensees. The one area that we are aware ofin the generic letter that is different from theCode is contained in Position 8 on the startingpoint for the time period in TechnicalSpecification action statements. This positionis consistent with other TechnicalSpecification starting points. This position isalso articulated in the bases for certain of theStandard Technical Specifications.

Question Group 96

Questions

In a refueling outage that is greater than 3months, how is the cold shutdown frequencyhandled? Can we perform the cold shutdownprocedure once during the outage or do weperform the cold shutdown procedure every 3months during the outage?

Response

When a component is required to be in serviceduring the outage, the testing is expected to beperformed quarterly during the outage. Whena component is not required to be operableduring an outage, the testing need not be per-formed quarterly. In accordance with IWV-3416 of the ASME Code, however, thosevalves must be tested within 30 days beforereturn of the system to operable status. Further, as required by IWP-3400(a), pumpsmust be tested within one week after the plantis returned to normal operation.

Current Considerations

Refer to Section 3.1 for additionalinformation.

NUREG-1482#���

Question Group 97 acceptable to allow relief?

Questions

Is radiography on check valves an acceptablemethod for determining valve position?

Response

Radiography may be utilized if it indicates theposition of the valve disk.

Question Group 98

Questions

Most plants have been given relief frommeasuring pump bearing temperatures perIWP-4310. Is it the policy of the NRC thatthis will continue to be an item of "generic"relief?

Response

It is true that some plants have been givenrelief from measuring pump bearingtemperatures on the basis of the impracticalityof measuring temperature for specific pumpdesigns. This issue has not been treated as anitem of "generic relief" because each reliefrequest has been individually evaluated. Forthe foreseeable future, NRC will continue toevaluate these relief requests on a case-by-case basis.

Current Considerations

Refer to Section 5.1.2.

Question Group 99

Questions

Where pump parameter measuring instrumentsdo not meet the specific requirements of theCode but do satisfy the fundamental technicalrequirements for testing, would it be

Response

It would be difficult to answer this questionwithout more specific information. Therehave been cases where relief requests in thisarea have been approved. In those cases,however, the basis for relief has been that theinstrumentation has been adequate to meet thefundamental objective of detectingdegradation. In relief requests of this type, thelicensees should address the reason that theASME Code requirements are not currentlybeing met and the basis for concluding that thefundamental objectives of IST are beingaccomplished.

Current Considerations

Refer to Section 5.5.

Question Group 100

Questions

The schedule for exercising manual valvesshould be extended to something less thanonce each quarter. Is this feasible?

Response

We are not aware of a basis for exercisingmanual valves at a frequency different fromother valves. Because this subject is notspecifically related to Generic Letter 89-04, itwas not addressed at any length during themeeting. If the licensees are aware of reasonswhy the frequency should be changed, werecommend that this subject be explored withthe ASME OM Working Group on Valves.

Current Considerations

The licensees for certain plants disregardmanual valves in planning the IST programs;however, manual valves that have a safety

NUREG-1482 #���

function that requires repositioning are Responserequired to be stroked at the Code-specifiedfrequency. To date, no changes have beenmade by the OM Committee. See Section4.4.6.

Question Group 101

Question

It has been said that some plants haveexcellent IST organizations. Who are they? Questions

Response

Dresden is one example of a facility with a Chapter 14 of the Final Safety Analysisgood IST organization. Report (FSAR)?

Question Group 102 Response

Question We assume that the question is directed to the

How do we handle cold shutdownjustifications in the future?

Response

Cold shutdown justifications were previouslyreviewed by NRR for adequacy. In the future,they will be reviewed during IST inspections. The cold shutdown justifications are expectedto be described in the IST program thelicensee provides to the NRC staff.

Current Considerations

Refer to Section 3.1.1.

Question Group 103

Question

After this meeting, what is the process forgetting further questions answered regardingthe generic letter?

These meeting minutes will be distributed,which should answer most of the industry'squestions. If after reading the meetingminutes you still have questions, you maycontact the cognizant personnel through theNRC Project Manager.

Question Group 104

Does "needed to mitigate the consequences ofan accident" mean an accident as described in

chapter of the FSAR describing accidentanalyses performed by the licensee. Thoseanalyses are intended to provide confidencethat the public health and safety will beprotected in the event of certain accidents andanticipated transients at a nuclear power plant. The term "accident" is also used in differentsections of the Commission's regulations. Forexample, Appendix B to 10 CFR Part 50establishes quality assurance requirements forthe design, construction, and operation of"structures, systems, and components thatprevent or mitigate the consequences ofpostulated accidents that could cause unduerisk to the health and safety of the public." Part 100 describes structures, systems, andcomponents that must be designed to remainfunctional during a "safe shutdownearthquake" as those necessary to ensure:

(1) the integrity of the reactorcoolant pressure boundary, (2) thecapability to shut down the reactorand maintain it in a safe shutdown

NUREG-1482#���

condition, or (3) the capability to the licensee, that is the impracticality ofprevent or mitigate the consequences making the modifications, as part of anof accidents which could result in assessment of the requests for relief from thepotential offsite exposures compar- ASME Code requirements. The legal staff hasable to the guideline exposures of stated that there is nothing in the regulationsthis part. that relieves licensees from making all

As can be seen, the term "accident" is used by with changes to IST requirements throughout athe Commission to describe a broad range of plant's life in later editions of Section XI. possible adverse events at a nuclear power Some hardware modifications can be required. plant. Therefore, although most of the acci- The difficult issue to resolve is how much maydents of concern to IST are addressed in the be required. For example, major equipment oraccident analyses chapter, licensees should be piping modifications may be beyond theaware that there may be other accident limitations of practicality in meetinganalyses in the FSAR that need to be subsequent editions of the Code. We,considered. however, regard modifications such as the

Question Group 105

Questions

This question is in reference to10 CFR 50.55a(g)(4): "...to the extent For plants that do not have operating licenses,practical within the limitations of design, 10 CFR 50.55 requires that you apply thegeometry, and materials of construction of the codes that are in effect 12 months prior tocomponents." In reviewing this wording, plant startup. Where does the 6 monthalong with the statements of consideration, do conformance letter stand for constructionyou think this rule was intended to impose plants in this situation?plant modifications as a result of meetingsubsequent editions and addenda? That is, Responseonce the staff evaluates a licensee'sdetermination of impracticality, will the NRCimpose plant modifications as alternaterequirements?

Response

The NRC staff in the Mechanical Engineering will be completed and an SER issued. TheBranch of NRR has had lengthy discussions reviews of the Comanche Peak and Watts Barwith the NRC Office of the General Counsel IST programs, however, may not be completedon this matter. The current interpretation of in the same time frame as the reviews forthe rule is that it is not intended to require a plants listed in Table 1. To obtain theblanket imposition of all plant modifications scheduled completion dates for the ISTthat would be necessary to comply with program reviews, the Comanche Peak andsubsequent editions and addenda. The rule Watts Bar organizations should contact theirdoes require an evaluation of the impact on respective NRC Project Managers.

hardware modifications to the plant to comply

installation of instrumentation to be practicalas used in 10 CFR 50.55a(g)(4).

Question Group 106

Questions

There are only two plants expected to receiveoperating licenses for which the staff's reviewof the IST program has not been completed. These plants are Comanche Peak and WattsBar. These two plants will be treatedessentially as Table 1 plants in that a review

NUREG-1482 #���

Question Group 107 be exercised on a periodic basis, Category

Questions

Currently, we only test the ICS pump suctioncheck valves ICS 3A(B) to verify they open aspart of the ICS pump test. Originally, the onlysafety function recognized was for the valvesto open to provide a water source, the RWST,to the ICS pumps. During an independentreview of the IST program, it was determinedthat these valves may also have a safetyfunction to close when the pumps are takingsuction from the RHR system. These valves,if they failed open, could provide anotherflowpath (to the RWST) besides the normalflowpath to containment. This flowpathwould also allow potentially contaminatedwater from the containment sump into theRWST (NOT DESIRABLE). As part of ourcompany's in-house safety system functionalinspection, it was determined that if thesecheck valves failed open, adequate flow to thecontainment would still be achieved. We arealso converting the manual valves upstream ofICS 3A(B) into motor operated valves in orderto prevent sump water from getting into theRWST. Do these check valves need to beleak tested?

Should Category A be applied to valves otherthan containment isolation valves (e.g., valveswhich isolate HVAC damper air accumulators:checks/SOVs)?

Response

The NRC staff has a generic concern with thecurrent practice of categorization of checkvalves. The ASME Code assigns all checkvalves as Category C. If seat leakage of acheck valve is limited to a specific amount,the Code also requires that valve to beassigned to Category A. Whereas Category C

check valves are required by the Code only to

A/C check valves must be leak tested inaddition to being exercised. The NRC staffhas found that, in many instances, checkvalves are not being assigned to Category A/Cdespite the fact that credit is taken by thelicensee for the check valve providing anessentially leak tight function. Thecategorization of a check valve is notdependent solely on the function performedby the valve, such as whether it is acontainment isolation valve. Whendetermining the proper categorization of acheck valve, a licensee should take allapplicable aspects into account. For example,the licensee should determine (1) whether theflow requirements for connected systems canbe achieved with the maximum possibleleakage through the check valve, (2) the effectof any reduced system flows resulting fromthe leakage on the performance of othersystems and components, (3) theconsequences of the loss of water from thesystem, (4) the effect that backflow throughthe valve may have on piping andcomponents, such as the effect of hightemperature and thermal stresses, and (5) theradiological exposure to plant personnel andthe public caused by the leak. If any of theabove considerations indicate that Category Ctesting may not be adequate, licensees shouldassign the check valve to Category A/C andshould comply with the associated leak testingrequirements.

Question Group 108

Questions

What is the NRC's opinion, per Generic Letter89-04, of non-quantifiable demonstrations ofperformance? For example, a solenoid valvehas no position indication that can beobserved or timed, but bearing temperatures

NUREG-1482#���

show no overheating. Question Group 110

Response

The NRC staff is discouraging the use ofqualitative criteria as an alternative to theCode- required component testing. Licenseesshould strive to develop a quantitative methodof determining the ability of a component toperform its required functions. Thisrecommendation is based on the goal of IST todetect degradation prior to failure of thecomponent. For specific examples, see theresponse to Question 1. With respect to thespecific question, more details would benecessary before arriving at the acceptabilityof the suggested method.

Question Group 109

Questions

Should LaSalle County Station be on Table 2 is integrated with other components in aof Generic Letter 89-04? If not, why? Zion system, it may be difficult to perform anStation underwent the same review 2 months individual test of that component. In specificafter LaSalle and they appear on Table 2. cases for which individual testing is not

Response by the licensee. In developing an alternate

Although the LaSalle nuclear power plantreceived an SER about a year ago, asignificant revision to its IST program wassubsequently submitted for NRC review. TheNRC staff determined that a review of the ISTprogram could not be completed in thenecessary time frame. In the context ofGeneric Letter 89-04, LaSalle, therefore, hasbeen classified as a plant that does not possessa current SER and will not be receiving an QuestionsSER. As a result, LaSalle is expected torespond to the generic letter in accordancewith the implementation provisions for plantsnot listed in Table 1 or 2.

Questions

What additional NRC guidelines can beprovided on testing skid-mounted pumps andvalves (i.e., diesel generator systems: lube oilpumps/valves, internal engine cooling; RCICsystems — condensate vacuum pumps withonly one source of power, etc.)? Most ofthese pumps and valves do not have thenecessary test instrumentation to supportASME Section XI testing and do not fallwithin the scope statements of IWP and IWV. Will modifications need to be performed?

Response

The purpose of inservice testing is to provideassurance of the operability of componentsand to detect degradation in theirperformance. Where a particular component

feasible, an alternate test should be proposed

test, the licensee should attempt to developquantitative criteria to evaluate the operabilityand condition of the component.

Current Considerations

Refer to Section 3.4.

Question Group 111

Is temporary flow instrumentation (i.e.,portable flow meter) permitted in lieu of amodification to install permanent flowinstrumentation? If so, is relief required?

NUREG-1482 #���

Response Commission's regulations can be interpreted to

The staff does not interpret the ASME Codeas excluding the use of portable flow rateinstrumentation, such as ultrasonic. We haveseen difficulty, however, in meeting the Code-specified accuracy requirements with theseinstruments.

Question Group 112 The O&M Committees are processing several

Questions

Is trending a requirement for pumps? Is it arequirement for valves? The Code and theregulations do not address this, nor does thegeneric letter.

Response

We define "trending" as the analysis of testdata to detect degradation of the testedcomponent and to enable preventivemaintenance to be performed beforesignificant challenges to componentoperability occur. The ASME Code containsfew requirements for trending of test data. For example, the ASME Code in IWV-3417(a) provides for more frequent stroke-time testing of power-operated valves wherean increase in stroke time is seen from aprevious test. The NRC staff allows areference value to be used for this comparisonin Position 6 of Generic Letter 89-04. InIWV-3427(b), the Code provides for morefrequent testing, and possibly maintenance,where the leak rate of a large valve increasesbeyond a specified amount from one test toanother. In Position 10 of the generic letter,the NRC staff explains its view that thisprovision of the Code may not be worthwhileand may be suspended. Although the ASMECode is weak in the area of trending, the NRCstaff remains of the view that trending is avaluable tool in the IST program. The

require efforts in this area. More explicitguidance for trending may be developed in thefuture. In the meantime, we recommend thatlicensees analyze IST data to take advantageof the benefits of trending.

Current Considerations

revision that address trending for pumps andvalves. The NRC continues to believe thattrending is a useful tool. With the movementtoward performance based testing (e.g., local-leak rate testing, check valves), data will bemore important in the near future for uses thatare not currently implemented. In using ISTdata, trending of every component andmeasured parameter may not be useful, butthe data should be maintained for trendingwhen a use is defined.

NUREG-1482#���

APPENDIX B

VALVE TABLES

POINT BEACH NUCLEAR PLANT lNSERVICE TESTING PROGRAM1t4SERVICE TESTING PRGGRAM Revision 4

March 30, 1993APPENDIX EVALVE PROGRAM TABLEuNrr2

sYsrEu: C@inmcnt Spf8yDRAWINO NO.: M-1 10E03S, Shd 3

VALVE cORD FUNCllON CLASS CAT SIZE TYPE Am ms REQMT FREQ REMARKS

Swm60C Clo Cs Pump I-P14B 2 B 6 GA MO c BT-O QRDiscb PtT QR

SJUJ6@D Clo Cs Pump I-P14B 2 B 6 GA MO c . BT-o QRDkh PIT QR

SI-00662A 111 CS Pump I-P14A 2 A/c 6 C K SA c Cv-o QRDi8ch SLT- I RR VRR-23, 29

sIUM2B Cll CS Pump I-P14B 2 Nc 6 CK SA c Cv-o QRDid SLT-I RR VRR-23 ,29

SMOM20 Hll Tmin “A” Tat 2 A 6 (3A MA c SLT- I RR Pmuivehohii VRR-23

SIUmaH 011 Tmin “B” Tea 2 A 6 GA M A c SLT-1 RR Pmsivehokhl VRR-23

!WU1864A Hll CS PUIIQ T- Rmckc 2 A .7s GL MA c SLT- 1 RR PwiveVRR-23

SIUN64B Cll CS PUIIIP TaI k+rc2 A .7s (3L M A c SLT-! RR PM9iVcVRR-23

SIUM66A 112 CS Nozzle A Hdr 2 A 6 GA M A O SLT-I RRIsohlion

P8ssiveVRR-23

SMXWWB C12 cs Nozzle B Hdr 2 A 6 GA MAO SLT-1 RR Pu8ivehohlion VRR-23

Page 16 ,of 52

Q u a d Citi88 N’uclear Power S t a t i o n , units 1 a n d 2

l~blc 1.0-7UNIT 1 VALVE LISTIN6

ORAUIN6 : M046~WIN6 TITLE : H16HPRESSUE CWLANT INJECTIOR PIPIK6

RELIEFREOIJEST

1S1 FUNCTION SIZE 60DY MU- POS]- TEST TEST ~ fflD TECNXICALVALVE NuaER %R CLASS CATE_Y (INCN) STYLE ATOR TION T Y P E FUQ SHUTDM P O S I T I O N

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ----- ------ ----- ---- -------- . . . . . . . . .2301-003 +0 A-7 2 6 10. OOO m m c BTO ns

PIT Y2FWCTIO# : I(PCI STEM SWPLY/6L=lW VALVE, PRE-NEAii TW “iIPP’LY LINE

2301-004 -MO C-9 1 A 10. OOO a m o AT-01 RR6TC CS CS-23A010 CS CS-23APIT Y2

FUNCTION : HPCI STEAM SUPPLY PROW THE REACTOR VESSEL TO THE TW61NE

2301-00S +0 0-10 1 A 10.000 6A no o 11-01 R R6TC CS CS-23A610 CS CS-23APIT Y2

FUNCTI~ : HPCI STEM SWPLY FRO THE REACTOR VESSEL 10 TNE TW61NE

2301-007 -AD E-6 2 c 14.000 CN Ao SYS CTO CS CS-OOAPIT Y2

FuWTIm : HPCI INJECTIW LINE TO FEEWATER 6ACKFLW PREVENTI~

2301-006 -MO E-6 2 6 14.000 a MO c BTO M3PIT Y2

FUNCTION : HPCI INJECTMI LINE TO FEEWATER ISOLATION

2301-006 -W E-5 2 6 14.000 M Ho o 6T0 M3PIT Y2

F U N C T I O N : I(PCI I N J E C T I O N LIRE TO FEEDUATER ISOLATI@ -

2301-010 -MO E-5 2 6 12.000 a No c 6TC NsPIT Y2

FUIKIIOR : HPCl FLLL FLW TEST RETLNI TO ~UNSATE STORM TANK

2301-014 -I@ C-6 2 0 4.0006Lmc 6TC M36T0 N3PIT Y2

FWCTIOII : WC! NIAIIHIRf FLW RECIRCUATl~ LINE ISOLATION

2301-020 E-1 2nmcmoa : C=I T o JU%?TDRJ?TM &Lw%v2R%oN

RV-OOF

2301-023 +V B-3 2 c 1.s00 w .FIMCTIOR : I@Cl 6DOSTER SUCTION LINE%ERPRhE &&TI#

2301-026 0-1o i A/c 1.000 WC 3A SYS AT-02 RRCTC RR RV-OW

FUICTIOU : MIII STM TO HPCI OP/P HI S10S 2222SS FLW 2X VLV

2301-027 0-1o i m 1.WO RFc 3A SYS AT-02 RRCTC RR RV-006

FUGTION : MN STN TO WC! OP/P LO SIU EXCESS FLW CN VLV

Revision

NUREG- 1482

4 VALVES1 - 6 2

B-2

I

1 %aver Why Power Sta t ion Un i t 9 Issue 2 ~Revtsion 10 ‘

INSERVICE TESTING (lS~ PROGRAM FOR PUMPS ANO VALVES P a g e 99 of 194 \

— — — — — —

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B-3 NUREG-1482

.— ----- ..— -— ----- . ..-. -. —- ..-— —. .-. .—. . -INSERVICE VMVE TESTING PLAN

TAME 4- CHEMICAL and VIMIME CONTROLPAGE 9ff12

Valve-!!!W@C

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M2-0255(G-3)

M - 0 2 5 3 - A CK/SA

M!B - 5 )-0255

(G-3)

M-(3253-A CK/SA(B-5)

N2-0255(G-3)

M1-0253-A CK/SA#-5~5

(G-3)

WO$;3-A CK/SA

M2-0255(E-2)

3

3

3

3

3

co&L!!wi

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Cate-!lQC!L

c

c

c

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c

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c

A 0

c

A 0

c

A 0

c

Test Parameters/Sd@uleF a i l P o s i t i o nSafe IndicatorLeak

~

N/A

N/A

t4/A

N/A

N/A

NfA

N}A

N/A

N/A

LTJ/TS

Exert isem

cv/Q(8)

cv/cs(2)

RR V5

CV/Q(8)

Cvlcs(2)

RR V5

W:

Cvfcs~~2J5

Cv/o(8)

cv/cs(2)

RR V5

CV/Q

cv/cs(2)

~

N/A

N/A

N/A

N/A

N/A

N/A

h/A

N / A

N/A

N/A

&

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

Remarks

8orat ion F bpath12

Reactor Coolant PressureMundary

Etorat ion F lcxtpath12

Reactor Coo lant Pressure8oundary

8orat ion F hpath12

Reactor Cmlant Pressureaoundary

8orat ion F lcxtpath

Reactor Coolant Pressure8oundary

8orat ion F lot@ath

Conta innent Isolat ion

Rw. 2April 30, 1993

LnIL

ASME SECTION Xl VALVES UNIT 2

2CC-73-I 2CC 21 R@ BRG WfR SUPPLY CHK NF-3924S-1 39 c ACT-OPEN E Q

2CC-73-2 2CC 22 RCP BRQ WTR SUPPLY CHK NF-39246-1 39 c ACT-OPEN E Q

CV3 12S3 2CC 21 Excs LTOWN NT EXCH ouTLET NF-39246-1 39 B ACT-CLOSE E Q

MV32122 2CC COW COOUNQ WTR SUPPLY HEADER NF-39246-1 39 B ACT-CLOSE SP-2163 E R

MV32123 2CC COMP COOLING WTR SUPPLY HEADER NF-3S246-1 39 B ACT-CLOSE BP-2163 E R

MV32124 2CC 21 REACT CLNTPW4P= CLOWRSUPPLY NF-3S246-1 39 B PAS-PEN w 2Y

MV32126 2CC 21 REACT CLNT W BRQ CLG WTR RETURN NF-39246-1 30 B PAS-OPEN w 2Y

MV32126 2CC 22 REACT CLNT PWP BRQ CLG WR SUPPLY HP-38246-1 3s B PAS-PEN w 2Y

MV32127 2CC 22 REACT CLNTPUMPBRQ CLGWTRREIWN NF-3S246-1 39 B PAS-OPEN w 2Y

MV32128 2CC 21 RSDL HT EXGR COW CLNT INLT W NF-39246-1 3s B ACT-BOTH 6P-2165 “ E Q

MV32129 2CC 22 RBDL HT EXGR COW CLNT INLT MV NF-3S246-1 3s B ACT-BOTH SP-2155 E Q

MV32130 2CC 21 EXCESS LETDOWN HT EXCH SUPPLY NF-3S246-1 3s B ACT-CLOSE E a

MV32211 2CC 21 COMPCLGPMP3LJCTMV NF-3@2464 3s B ACT-BOTH SP-2165 E Q

MV32212 2CC 22 COMP CLO PUP SUCT W NF-39246-1 39 B ACT-BOTH SP-2165 E a

MV322SS 2CC 21122 RCP COW Cl@ INLT ISOL W B NF-39246-1 39 B ACT-BOTW SP-2163 E R

MV32269 2Cc 21122 RcPcoMPcLG lNLTtsoLMv A HP-39246-1 39 B ACT-SOTH BP-2163 E R

2CL-1 2-1 2CL 21 CONTAINMENT FAN CQILS-BUPPLY NF-3921 7-3 36 c ACT-OPEN E Q

2CL-I 2-2 2CL 23 CONTAINMENT FAN CONSSWPLY NF-3S217-3 36 c ACT-OPEN E Q

2CL-1 2-3 2CL 22 CONTAINMENT FAN COILS-SUPPLY NF-39217-3 36 c ACT-OPEN E o

2CL-124 2CL 24 CONTAINMENT FAN COILS-SUPPLY NF-3S217-3 36 c ACT-OPEN E a

2CL-43-1 2CL 21 CLG WTR PUMP DISCH NF-39216 36 c ACT-CLOSE SP-11 06B E a

P I 1S1 2 . 3 - 63d 10 You Progrmn

b 2 s12ama

—

NUREG-1482$��

APPENDIX C

RELIEF REQUESTS

I ILLINOIS POWER COMPANYClinton Power Station

I

I ASME Section XI Relief Request

RELIEF REQUEST 2014 (Revision 3) IThese testable check valves

COMPONENT INFORMATION (lE12-F041A/B/C, 1E21-FO06, and1E22-FO05) provide isolationfrom the reactor coolant system

and the emergency core cooling systems (Residual Heat Removal, LowPressure Core Spray, High Pressure Core Spray). These valves areASME Section III Code Class 1, Section XI Category A/C valves.Valves 1E12-F041 A,B, and C are 129$ diameter and valves 1E21-FO06and 1E22-FO05 are 10IJ diameter. All of these valves are non-slamcheck valves. One of these valves (1E12-F041A), which is typicalof the group, is circled on the attached drawing.

The ASME Code, Section XI,CODE REQUIREMENTS Subsection IWV-3520 requires

that these valves be exercisedevery three (3) months unless

such operation is not practical during plant operation. In thissituation, the valves may be part-stroke exercised during plantoperation and full-stroke exercised during cold shutdown.

Exercising these valves on aRELIEF REQtJEST/JUSTIFICATION three month frequency using the

emergency core cooling systempumps to inject water into the

reactor is not in the interest of plant safety, because this coolerwater would create an undesirable power transient. In addition,neither the Low Pressure Core Spray nor Residual Heat Removal pumpsare capable of opening their injection valves against full reactorpressure. Mechanically exercising these valves during reactoroperation is not practical because they are located inside thedrywell and access isbrestricted due to radiation conditions.

Mechanically exercising these valves on a cold shutdown frequencyas allowed by the ASME Code is not practical because the airoperator is not designed to perform a full stroke test. AlthouGhthe air operator can be removed to perform the full stroke test,this is a significant maintenance activity and could interfere withwork which is necessary to restore the plant to service. Thiswould create an unreasonable hardship for Illinois Power Company.

Using pump pressure to exercise these valves during cold shutdownis also not in the interest of plant safety. Although temperaturecould be matched fairly closely between the injection source(emergency core cooling systems) and the reactor, a minor thermalmismatch between these temperatures creates an undesirable effecton the fatigue life of the reactor nozzles.

In addition, the injection lines associated with the residual heatremoval system nozzles are not equipped with internal spargers.General Electric Service Information Letter 401 identifies problemsin injecting water through this flow path and the potential damageto nuclear instrumentation or fuel assemblies which could occur ifthis flow path were used for other than emergency conditions.

Illinois Power Company will fullALTERNATE TESTING PROPOSED stroke exercise the valves

during refueling by measuringthe torque required to lift the

disc and then move the disc through a full stroke.

c-1 NUREG- 1482

-i

A0 0to

—

I

1

.

D

B muamD + K~

b + nlwJmc

DPt-

9

—

Page 1 of 3RELIEF REQUEST PR-12

Third Ten-Year Interval 1ST Program Revision 3

~vstem: Service Water

Components: Service water pumps PSWO-lA/B/C/D

Comr)onent Function: Cooling for safety-related coolers following designaccident; ultimate heat sink.

code Requirements: IWP-411O and IWP-4120 for flowrate instrumentationaccuracy and full-scale range.

Descr iDtion of Relief:

basis

Previously, the service water pump testing for pumps PSWO-lA, -lB, -lC, and -lD, was conducted at a flow rate approximately one-half accident flow rate inorder to utilize flow instrumentation installed to measure service water flowthrough containment recirculation fan coolers. In response to arecommendation made by NRC during the team inspection of the service watersystem, November/December 1991, a new test methodology is proposed in PR-12.This effectively eliminates the need for Relief Request PR-7, and it iswithdrawn upon NRC approval of PR-12. The new test method is expected to beimplemented in the tests scheduled for November 1992.

The new test method will also provide full flow exercising of the servicewater pump discharge check valves 4601, 4602, 4603, and 4604. This willeliminate the need for employing a disassembly and inspection program forthese four valves discussed in Relief Request VR-17, and it is withdrawn uponNRC approval of PR-12. The change also permits reclassification of twelvemanual butterfly valves which function as the inlet and outlet valves for thefour containment recirculation fan coolers and the two reactor compartmentcoolers from “Category A - Active” to “Category A - Passive.” The appropriatechanges to the 1ST Program for these valves will be made. These changes donot effect existing or new relief requests.

Bas is for Relief:

The present system configuration and iristrumentation does not providepermanently installed flow indication at the SW [service water] pump dischargepiping to provide a positive means of determining full flow during pump tests.Employing a clamp-on ultrasonic flowmeter to measure full SW pump dischargeflow is not currently addressed in ASME Section XI, Subsection IWP (Code).

The Code requires an instrument accuracy of 2% of full scale. The clamp-onultrasonic flowmeter possesses an instrument accuracy of 3% of actual flow.Although the percentage error (3% of the actual flow as compared with 2% of

c-3 NUREG-1482

Page 2 of 3

1 scale) is stated as a ‘arger numerical value, the actual absolute valueinstrument inaccuracy at the reference flow rate of 5,600 gpm (approximatepump design (flow ratel) is actually less for the clamp-on ultrasonic

the reading from a 1 - 10,000 gpm analog gauge isscale). The accuracy of the reading from the

floivmeter. ~he-accuracy if5,600 ~200gpm (2% of fullclamp-on ultrasonic flowmeter is 5,600 ~ 168 gpm (3% of actual flow). Thusthe actual maximum instrument error of the flow reading, as read on the clamp-on ultrasonic flowmeter, is less than the error as read on the analog gauge atthe specified flow rate of 5,600 gpm.

The full-scale range (calibrated) of the clamp-on ultrasonic flowmeter is 40ft./see. This corresponds to a flow rate of approximately 17,000 gpm (for 14inch pipe), which exceeds three times the reference value of 5,600 gpm.

Relief is requested to utilize a digital flowrate instrument for inservicetesting of the service water pumps. Relief is required because the accuracyof the measurement will not be ~ 2% over the calibrated range as required byOM-6, Table 1, Note (l). The accuracy will be *3% over the calibrated range(percent of reading) based on the piping configuration and the location forplacement of the instrument. However, the accuracy achieved is more accuratethan would be achieved with analog instrumentation which is required to be t2% of full scale (no more than three time reference value).

The digital clamp-on ultrasonic flowmeter yields a more accurate flow readingat the specified SW pump test flow rate of 5,600 gpm than an analog instrumentand the range of the clamp-on ultrasonic flowmeter meets the requirement ofASME/ANSI OMa-1988, Part 6, Paragraph 4.6.l.2(b), i.e. reference flow rate <70% of calibrated range. Repeatability of the digital readings will beassured by permanently mounting the instrument. With a ~ 3% of readingaccuracy, the digital reading will be in the range of 5432 gpm to 5712 gpm.An analog instrument with at 2% accuracy and a range of three time thereference would provide a reading in the range of ~ 336 gpm (5264 gpm to 5936gpm). In order to meet the accuracy requirements of OM-6 for digitalinstrumentation, modifications to the piping would be required in order toplace the clamp-on flowmeter in a location five pipe diameters from an elbow.Similar modifications would be required to install permanent flow measurementanalog instrumentation which would even then not provide a reading as accurateas will be achieved with the clamp-on flowmeter. Compliance with OM-6 wouldbe a hardship without a compensating increase in the level of quality andsafety, with the hardship being the modifications that would be required, withthe accuracy of the reading not being increased.

NUREG-1482 c-4

Page 3 of 3

This substantial improvement in test method provides for the measurement of asufficiently accurate and repeatable value for SW pump flow rate. Byemploying this test method and obtaining the pump’s corresponding differentialpressure, the hydraulic performance of the SW pump can be more accuratelyassessed. Repeatability of flow rate measurement will be ensured through the,permanent installation of clamp-on ultrasonic flowmeter instrumentation viathe [XXX] Station minor modification process.

Alternative Testinq

SU pump flow testing will utilize a permanently installed clamp-on ultrasonicflowmeter to allow rate measurement at a reference flow equivalent to thedesign point of the SW pumps.

c-5 NUREG-1482

Page 1 of 2

RELIEF REQUEST NO. V2

SYSTEM

VALVE NUMBERS

CATEGORY

CLASS

FUNCTION

Component Cooling Water

lCC-1079/1080 lCC-1081/10822CC-1091/1092 2CC-1093/1094

A/C, C

3

These check valves form the boundary between the non-safetyInstrument Air or Nitrogen supply systems and the safety-gradeaccumulator and receiver tanks. The tanks provide an emergencyair or nitrogen supply to certain safety-related components.The check valves are required to close upon failure of the airor nitrogen supply system in order to contain the compressedgas in the tanks.

TEST REQUIREMENT OM Part 10, para 4.3.2, “Exercising Tests for CheckValves”

BASIS FOR RELIEF Each valve listed is one of two check valves in series atthe inlet to a safety-grade accumulator or receiver tank.In each case, only one check valve is required in order tomeet the safety class interface criteria of ANSI N18.2a-1975. However, two check valves are provided for addedreliability, not for redundancy. The safety-relatedcomponents served by the accumulator and receiver tanksare redundant to other similar components which have theirown dedicated safety-grade air supplies. As long as oneof the check valves in the pair is capable of closure,then the safety analysis assumptions for the check valvesare met. Some of the check valve pairs do not haveprovisions for testing each valve individually. However,the closure capability of each pair of check valves can beverified.

NUREG-1482 C-6

l%ge 2 of 2

SUBSTITUTE TEST Each pair of series check valves will be exercise testedat the required frequency by some positive means to verifythe closure capability of at least one of the valves. Noadditional exercise testing will be performed unless thereis an indication that the closure capability of the pairof valves is questionable. In that case, both valves willbe declared inoperable and not returned to service untilthey are either repaired or replaced.

DRAWINGS: M-2236, SAR Figure 9.2.6-4

REFERENCES: ANSI N18.2a-1975

c-7 NUREG-1482

Page 1 of 2

RELIEF REWE$T V R-13

Yalve NUmbers: 1DG5182A,B1DG5183A,B1DG5184A,B1DG5185A,B

2DG5182A,B2DG5183A,B2DG5184A,B2DG5185A,B

er of Items.. 16

ME code Cat euorv: B&c

A$ME CO e Secd tion XI Requirements:

These valves are not within the scope ofASME Code, Section XI,Subsection IWV requirements. However, the requirements for stroke timingand trending of the valves associated with the Diesel Air Start Systemare being included as augmented components for inservice testing. Thesevalves associated with the Diesel Air Start System shall be exercised tothe position required to fulfill their function during plant operationper IWV-3412 and IWV-3522. Additionally, the stroke testing of poweroperated valves shall be measured to the nearest second and such stroketimes trended to document continued valve operational readiness per IWV-3413 (b) and IWV-3417.

The monthly Diesel Generator testing program, outlined in XXXX StationTechnical Specifications and implemented by station operating procedures,exceeds the intent of the quarterly valve testing program which would berequired by ASME Code, Section XI. Additionally, the stroke timing ofsolenoid operated valves associated with the Diesel Air Start System isimpractical due to the fast actuation of these valves.

Alternatlw Test. ins:

The performance ofXXX Station’s Diesel Generator operability monthlysurveillance will verify the operational readiness of the valvesassociated with the Diesel Air Start System. This surveillance testingwill require the recording of the air pressures contained in both trains

NUREG-1482 C-8

Page 2 of 2

RELIEF REOUEST VR-13(continued)

A & B of the Diesel Generator Air Start Receiver Tanks both before andimmediately after diesel generator start. By the comparison of thesevalves between trains, the satisfactory operation of the power operatedand self-actuated check valves associated with the Diesel Air StartSystem can be adequately demonstrated. On an alternating basis, aportion of the air start system will be isolated and repressurized priorto diesel start. This will allow verification that the air start systemcheck valves in the unisolated portion stroke open.

c-9 NUREG-1482

REUEF REOUEST NUMBER GR-4

m Various

Vdvm Various

Cate~. A,B

c l - Various

Function: Various

Impraotloal Teat Requlremeti. WV-3413; Power Operated Valves CorrectiveAction, WV-341 7; Corrective Action

Baais for Roll@ Generic Letter 89-04 Position 6 recognizes that measuring changesin stroke times from a reference value as opposed to measuringchanges from the previous test is a better way to detect valvedegradation. Generic Letter 89-04 Position 5 and OMa- 1988, Part10 provide NRC approved methodology for establishing a stroketime referenoe value, an acceptable stroke time band, and a limitingstroke time value. The alternative testing is in accordance with thismethodology.

Alternative Toating: The power operated valve testing will be petformed inaccordance with OMa-1 988, Part 10, paragraphs 4.2.1.4,4.2.1.8, and 4.2.1.9. The acceptable band and Limiting StrokeTime (LST) will be determined as follows (RV time in sac):

pgf&mRQ ~p&Y#u!L&GaictdLa0.85RV - 1.15RV 1.3RV

2 s RV <10 0.75RV - 1.25RV 1.5RV

Other Rv>lo 0.75RV - 1.25RV 1.5RV2 s RV s 10 0.50RV - 1.50RV 2.ORV

Atl RV<2 ~2 2

In addition, if a more restrictive value of stroke time exists inthe Technioal Specifications or the Updated Safety AnalysisRepott, it will be used as the LST instead of the valuecalculated above.

Approval: Relief granted with provisions in SER dated September 24, 1992.

NUREG-1482 c-lo

Page 3.6 13Revision-

RELIEF REQUEST NO. ~

SYsMm Standby Service Water

-

Code Class P & I D Dwg. Number

SW-P-1A 3 M524, SH 1

SW-P~lB 3 M524, SH 2

HPCS-P-2 3 M524, SH 1

Section XI Code R-uirsawnts For U Relief 1S Remestedt. .

IWP-31OO requires that the system resistance be varieduntil either the measured differential pressure ormeasured flow rate equals the corresponding referencevalue. The quantities of Table IWP-31OO-1 are thenmeasured or observed and compared to the correspondingreference value.

1. Service Water systems are designed such that the totalpump flow cannot be adjusted to one finite value forthe purpose of testing without adversely affecting thesystem flow balance and Technical Specificationoperability requirements. Thus these pumps must betested in a manner that the service water loop remainsproperly flow balanced during and after the testing andeach supplied load remains fully operable per TechnicalSpecifications to maintain the required level of plantsafety during power operation.

2. The service water system loops are not designed with afull flow test line with a single throttle valve. Thusthe flow cannot be throttled to a fixed reference valueevery time. Total pump flow rate can only be measuredusing the total system flow indication installed on thecommon return header. There are no valves in any ofthe loops, either on the common supply or return lines,available for the purpose of throttling total systemflow. Only the flows of the served components can beindividually throttled. Each main loop of servicewater supplies 17-18 safety related loads, all piped inparallel with each other. The HPCS-P-2 pump loopsupplies four loads, each in parallel. Each pump iscompletely independent from the others (no loads arecommon between the pumps). Each load is throttled to aFSAR required flow range which must be satisfied for

c-l] NUREG- 1482

Page 3 . 6 - 1 4ReVision~

Roliof Request ~ (Continued)

the load to be operable. AJ1 loads are aligned inparallel, and all receive service water flow when theassociated service water pump is running, regardless ofwhether the served component itself is in service.During power operation, all loops of service water arerequired to be operable per Technical Specifications.A loop of service water cannot be taken out of servicefor testing without entering an Action Statement for aLimiting Condition for Operation (LCO). Individualcomponent flows outside of the FSAR mandated flowranges also induce their own Technical Specificationaction statements that in turn can induce full plantshutdown in as little as two hours, depending on theload in question.

.-. Each loop of service water is flow balanced beforeexiting each annual refueling outage to ensure that allloads are adequately supplied. A flow range isspecified for each load to balance all the flowsagainst each other. Once prGperly flow balanced, verylittle flow adjustment can be made for any oneparticular load without adversely impacting theoperability of the remaining loads (increasing flow forone load reduces flow for all the others). Each timethe system is flow baIanced, proper individualcomponen~ flows are produced, but this in turn does notnecessarily result in one specific value for totalflow. Because each load has an acceptable flow range,overall system full flow (the sum of the individualloads) also has a range. Total system flow canconceivably be in the ranges of 9247 - 10,079 GPM forSW-P-1A pump, 9212 - 10,043 GPM for SW-P-lB pump, and1050 - 1158 GPM for HPCS-P-2 pump. Consequently, thedesire to quarterly adjust service water loop flow toone specific flow value for the performance ofinservice testing conflicts with system design andcomponent operability requirements (i.e. flow balance)as required by Technical Specifications.

Alternate T-tins to be perfo~ed..

As discussed above in the basis for relief section, it isextremely difficult or impossible to return to a specificvalue of flow rate or differential pressure for testing ofthese pumps. Multiple reference points could be establishedaccording to the Code, but it would be impossible to obtainreference values at every possible point, even over a smallrange. An alternate to testing requirements of IWP-31OO isto base the acceptance criteria on a reference curve. Flowrate and discharge pressure are measured during inservicetesting in the as found condition and compared to anestablished reference curve. Discharge pressure instead of

NUREG-1482 C-12 ““-

Page 3.6-15Revi=ion~

Relief Request w-Q (Continued)

differential pressure is used to determine pump operationalreadiness as allowed by Relief Request RP-3 (Relief grantedper SER/TER Reference 2.3.1, dated May 7, 1991). Thefollowing elements are used in developing and implementingthe reference pump curves.

1.

2.

3.

4.

5.

6.

A reference pump curve (flow rate vs dischargepressure) has been established for SW-P-lA and SW-P-lBfrom data taken on these pumps when they were known tobe operating acceptably. These pump curves representpump performance almost identical to preoperationaltest data. The methodology employed for establishing areference pump curve is similar to that for performinga comprehensive test being proposed by the OM CodeCommittee.

Pump curves are based on seven or more test pointsbeyond the flat portion of the curve (at flow rategreater than 4800 gpm). Rated capacity of these pumpsis 12,000 gpm. Three or more test data points were atflow rate greater than 9,000 gpm. The pumps are beingtested at full design flow rate.

To reduce the uncertainty associated with the pumpcurves and the adequacy of the acceptance criteria,special test gauges (*0.5% full scale accuracy) wereinstalled to take test data in addition to plantinstalled gauges and Transient Data Acquisition System(TDAS) . All instruments used either met or exceededthe Code required accuracy.

For HPCS-P-2 pump, the reference pump curve is based onthe manufacturer’s pump curve which was validatedduring the preoperational testing.

Review of the pump hydraulic data trend plots indicatesclose correlation with the established pump referencecurves, thus further validating the accuracy andadequacy of the pump curves to assess pumps operationalreadiness.

The reference pump curves are based on flow rate vsdischarge pressure. Acceptance criteria curves arebased on differential pressure limits given in TableIWP-31OO-2. Setting the Code Acceptance Criteria ondischarge pressure using differential limits isslightly more conservative for these pump installationswith suction lift (Relief Request RP-3, SER/TERReference 2.3.1, dated May 7, 1991). See the attachedsample SW-P-1A pump Acceptance Criteria sheet. Area1-2-3-4 is the acceptable range for pump performance.Areas outside 1-2-3-4 but within 5-6-7-8 define theAlert Range, and the areas outside 5-6-7-8 define the

C-13 NUREG- 1482

Page 3.6-16Revision~

Rdiaf R@qu@st ~ (Continued)

required Action Range. These acceptance criterialimits do not conflict with Technical Specifications orFinal Safety Analysis Report operability criteria.

7. Only a smell portion of the ● stablished reference curveis being used to accommodate flow rate variance due toflow balancing of various systsm loads.

8. Raview of vibration data trend plots indicates that thechange in vibration readings over the narrow range ofpump curves being used is insignificant and thus onlyone fixed reference value has been assigned for eachvibration location.

9. After any maintenance or repair that may affect theexisting reference pump curve, a new reference pumpcurve shall be determined or the existing pump curverevalidated by an inservice test. New reference pumpcurve shall be established based on at least 5 pointsbeyond the flat portion of the pump curve.

*

Design of WNP-2 Service Water System and the TechnicalSpecifications requirements make it impractical toadjust system flow to a fixed reference value forinservice testing without adversely affecting thesystem flow balance and Technical Specificationoperability requirements. Proposed alternate teetingusing a reference pump curve for each pump providesadequate assurance and accuracy in monitoring pumpcondition to assess pump operational readiness andshall adequately detect pump degradation. Alternatetesting will have no adverse impact on plant and publicsafety.

NUREG-1482 C-14

Page 3.6-17Revision~

I

Relief Request H (Continued)

SW-P-1A ACCEPTANCE CRITERIA

. s22s

- 1\ACTIOF ‘ RANG: !

215 .\

210 \

REF. CURVE

m- 2

\\ 8

\ 4

m \\

195

1ssACTIOh RANGI : ‘ 3

m\

‘ 7

17s9.a40‘

IIJ*I Ill lli~j I Ill,430’I l! I Ill I I l! I I I

4,$0’”! 501” JI.o$”flXl”f d“,9 0, 0

FLOW - GPMALERT RANGE - Am.a Outside 1-2-3-4 ACITON RANGE - Aera Outside 5-6-7-8

APPENDIX D

SAFETY EVALUATION

UNITED STATESN U C L E A R R E G U L A T O R Y C O M M I S S I O N

WASHINGTON, D.C. -

“ ***** -

WETY EWUALXQN By THE OFFICE OF Nu~

TED TO THE INSERVICE TESTING PROGRAH R~STS FOR U

PUBLIC SERVICE CONPANY. ET AL.

PALO VERDE NUCLEAR WWTINGS TATION. WITS 1. 2. ~

KET NOS. 50-528. 50-529. AND 50-53Q

10. INTRODUCTION

Sect ion 50 .55a of T i t le 10 of the Code of Federa l Regulat ions,10 CFR 50 .55a , requi res that inservice testing (1ST) of certain AWE Class 1,2, and 3 pumps and valves be performed in accordance with Section XI of theASHE Boiler and Pressure Vessel Code and applicable Addenda, except wherea l ternat ives are author ized or rellef is granted by the Coaanission p u r s u a n t t oW(a)(3)(i), ( a ) ( 3 ) ( i i ) , o r ( f ) ( 6 ) ( i ) o f S e c t i o n 5 0 . 5 5 a . I n o r d e r t o o b t a i nauthor izat ion or re l ie f , the l icensee must demonstrate that (1 ) the proposedal ternat ives provide an acceptable leve l o f qual i ty and safety , (2 ) compl iancewould resul t in hardship or unusual d i f f icu l ty wi thout a compensat ing increasein the level of qual i ty and safety , or (3 ) conformance is impract ica l for i tsf a c i l i t y .

Sect Ion 50 .55a author izes the Coasnission to approve a l ternat ives or grantrelief from the ASHE Code requirements upon making the necessary findings.The NRC staf f ’s f indings wi th respect to the re l ie f that has been requestedand alternatives proposed as part of the l icensee’s 1ST program are conta inedIn th is Safety Evaluat ion.

S e c t i o n 5 0 . 5 5 a ( f ) ( 6 ) ( l ) r e q u i r e s t h e Coasaission t o e v a l u a t ed e t e r m i n a t i o n s o f i m p r a c t i c a l i t y a n d a u t h o r i z e s t h e Connission to grant relief● nd impose such alternative requlrrnnts as It determines Is authorized by lawand will not endanger llfe or property or the co-n defense ● nd secur i ty andis otherwise tn the public Interest, glvlng due considerat ion to the burdenupon the l icensee that could result if the requirements were imposed on thefacillty.

8y le t ter dated September , 1992, Ar izona Publlc Service Company ( thel icensee) requested approval o f a rev ised re l ie f request for the four safetyi n j e c t i o n t a n k d i s c h a r g e c h e c k v a l v e s V215, V225, V235, and V245; and the fours a f e t y i n j e c t i o n llne d i s c h a r g e c h e c k v a l v e s V217, V227, V237, and V247.

T h e c h e c k v a l v e s whfch are the subject of th is re l ie f request provide

D-1 NUREG-1482

-2-

protect ion for the safety in ject ion tanks and the high and l o w p r e s s u r e s a f e t yin ject ion l ines f rom the h igher pressure reactor coolant system dur ing normaloperat ion . In the event of ● loss-of -coolant accident , the va lves open toa l low water to be del ivered to the reactor vessel f rom the safety in ject iontanks and the safe ty in ject ion systemto cool the core .

The test requirement for these valves under Section XI of the ASHE Code thatis re levant to the re l ie f requests is to fu l l -s t roke exerc ise the va lves every3 months, or part-stroke exercise every 3 months ● nd perform a full-stroketest dur ing cold shutdown, or per form a fu l l -s t roke test dur ing cold shutdownif the valves cannot be part-stroked every three months.

The licensee was granted relief from these requirements in an NRC letter datedNovember 15, 1988. The test ing method approved in that le t ter is to part-st roke exerc ise the safe ty in ject ion tank check va lves in Hode 3 (hot s tandby)af ter each re fue l ing outage when the safety in ject ion tank pressure is above600 psig and to disassemble one valve of each type each refueling outage toverify freedom of disc movement. I f i t is found that the d isassembled valve ’sf u l l - s t r o k e c a p a b i l i t y i s q u e s t i o n a b l e , t h e n a l l 3 o t h e r v a l v e s o f t h a t t y p ewould have to be disassembled and inspected.

In i ts le t ter of September 8 , 1992, APS proposes an a l ternate test ing methodwhich would consist o f a fu l l -s t roke exerc ise of a l l 8 va lves dur ing eachrefue l ing outage. This would be accomplished by opening the safety injectiontank iso lat ion va lve wi th pressure in the safety in ject ion tank and wi th thereactor vessel head removed. This evolution would open a pair of the checkvalves, one of each type. This would be repeated for the other 3 pa i rs unt i la l l 8 a r e t e s t e d . The licensee would monitor the level and pressure drop inthe safety in ject ion tank to determine whether or not fu l l opening of thevalves was achieved.

The.licensee has conducted two tests using the proposed revised method.Acoustic data from both tests provided additional assurance that each “?lveactua l ly s t roked to the fu l l open posi t ion dur ing the test .

The NRC staff has reviewed the proposed alternate test method and finds itacceptable , subject to two condi t ions d iscussed be low. The proposed testmethod requires each valve to be tested in the manner in which it performs itssafety funct ion, and Is therefore a more rea l is t ic and improved test . I ti n v o l v e s f u l l s t r o k i n g , as o p p o s e d t o t h e c u r r e n t p a r t i a l s t r o k i n g . I t a l s odoes not re lyon va lve d isassembly , which act iv i ty o f fers the oppor tuni ty forreassembly errors. An added benefit of the revised method is the reducedpersonnel radiation exposure since the valves no longer have to bedisassembled.

The NRC staff therefore finds the revised test method to be acceptable,prov ided that (1 ) the va lves are par t ia l -s t roke tested each cold shutdown i fthey have not been tested within the past 3 months, and (2) one valve of eachtype is confirmed to have opened fully by a non- int rus ive method (e .g . ,acoust ics) each re fue l ing outage on a rota t ing schedule such that a l l va lvesa r e c o n f i r m e d i n t h i s manner in a ser ies of four re fue l ing.

NUREG-1482 D-2

-3-

The NRC staf f concurs wi th the l icensee’s cont inued determinat ion thatc o m p l i a n c e w i t h t h e c o d e requir-nts is impract ica l in th is case. Full-st roke ● xercising of these valves is not practical in any plant mode otherthan refueling shutdown when the reactor vessel head is removed. Part-stroketesting every 3 months is not practical since a plant shutdown would ber e q u i r e d t o perfom the test . I t is , however , pract ica l to conduct ● part-stroke test at each c o l d s h u t d o w n . Dur ing cold shutdown, the safety in ject ioncheck va lves can be part-stroked by the normal flow delivered to the reactorc o o l a n t system via the shutdown cool ing system. The safety in ject ion tankdischarge check valves can be tested in the same aanner as they are current lybe ing tested by par t -s t roke exerc is ing intlode 3 (hot standby) when the safetyin ject ion tank pressure is above 600psig. The licensee has already confirmedin two separate tests that fu l l opening of the va lves can be establ ished byacoust ics .

As noted in the re l ie f request , these va lves a lso per form a safety funct ion byclosing to prevent over pressurization of S1 pip ing f rom RCS pressure .S imi lar to the requi red va lve open exerc is ing requi rements , these va lves mustbe verified to be closed every three months or during cold shutdown if theclosure verification of these valves cannot be performed every three months.Since these valves will be part-stroke exercised at cold shutdowns and sincethe Technica l Speci f icat ions require leak test ing of these va lves af ter theyare d is turbed, the c losure ver i f icat ion wi l l be per formed at co ld shutdownthrough the leak test ing. The licensee should efther perform the closurever i f icat ion every three months or prepare a co ld shutdown just i f icat ion i fthis testing is not practical ● nd revise the 1ST program to ref lect th ist e s t i n g , a s a p p r o p r i a t e .

3.0 !XWIWQN

The revised valve Relief Requests Nos. 33 and 34 transmitted by APS letterdated September 8, 1992 are acceptable for implementation, provided that thecheck valves are part-stroked each cold shutdown, and provided further thatone valve of each type is confirmed to have opened fully by a non-intrusivemethod (e.g., acoustics) each refueling outage on a rotating schedule sucht h a t a l l v a l v e s a r e c o n f i r m e d i n t h i s manner i n a s e r i e s o f f o u r r e f u e l i n g .

TheNRC s t a f f h a s d e t e r m i n e d t h a t g r a n t i n g ofthfs re l ie f pursuant to IOCFR5 0 . 5 5 a ( f ) ( 6 ) ( i ) i s a u t h o r i z e d b y law and w i l l n o t e n d a n g e r l i f e o r p r o p e r t y o rthe conanon defense and secur i ty and is o therwise in the publ ic in terest . I nmaking th is determinat ion, the NRC staf f has considered the a l ternate test ingbeing implemented and the impract ica l i ty of per forming the required test ingconsidering the burden if the requirements were imposed.

Date: October 23, 1992

D - 3 NUREG-1482

APPENDIX E

BASES DOCUMENT

1ST DESIGN BASIS DOCUNBNT

VALVE(S): CS-16, CS-17

DRAWING: NF-39237, NF-39824

DESCRIPTION: 11,12 Containment Spray Pump Suction Check

CODE CLASS: 2

VALVE CATEGORY: C, Active

NORMAL POSITION: Closed

SAFETY POSITION: Open or closed

SAFETY FUNCTION(S): Valve is open to provide RWST water andflow to the CS pumps. Valve is closed to prevent backflow ofcontainment sump water to the RWST upon a passive failure ofthe RNR to Cs Mov.

NORMAL FUNCTION (S) :

TEST TYPE: Partial stroke open quarterly per SP109O and OM-10 paragraph 4.3.2.1 and 4.3.2.2(b) and (e) with the fullstroke open at refueling per SP1372. Obturator travel to theclosed position is test quarterly per SP1354 and OM-10paragraph 4.3.2.1 and 4.3.2.2(a).

COMMENTS: Se. Deferral CS1 and CS2.Non-intrusive testing is performed to assure the valve isfull open using the head of the RWST as the driving force.Should testing with the RWST head be unsuccessful the valveis disassembled and inspected.

REFERENCE:B18 Containment Spray System Description

E-1 NUREG-1482

@

POINT BEACH I’iWCLEAR PLANT BACKGROUND DOCUNIE.NTINSERVICE TESTING PROGRAM APPENDIX ATHIRD INTERVAL Revision 1

March 30, 1993MAIN AND REHEAT STEAM SYSTEM

I-MS-02017C-S, 1-MS-02017D-S, 1-MS-02018C-S, and I-MS-02018D-S (M-201 , Sh 1)2-MS-02017C-S, 2-MS-02017D-S, 2-MS-02018C-S, and 2-MS-02018D-S (M-2201, Sh 1)MSIV Pneumatic Operator Exhaust Valves

These valves opdshift to provide an exhaust path for air from the underside of the MSIVoperating cylinder when an MSIV closing signal is received. Although these valves axe notclassified as Class 1, 2, or 3, they are included in the Program for completeness.

Test Requirement: BT-O

1-MS-02017A-S, I-MS-02017B-S, 1-MS-02018A-S, and 1-MS-02018B-S (M-201 , Sh 1)2-MS-02017A-S, 2-MS-02017B-S, 2-MS-02018A-S, and 2-MS-02018B-S (M-2201 , Sh 1)MSIV Pneumatic Operator Supply Valves

These valves closdshift to secure supply air to the underside of the MSIV opexating cylinderwhen an MSIV closing s@al k received. Although these valves are not classifkd as Class1, 2, or 3, they are included in the Program for completeness.

Test Requirement: BT-C

1-MS-02019 and 1-MS-02020 (M-201 , Sh 1)2-MS-02019 and 2-MS-02020 (M-2201 , Sh 1)

~ AFW Steam Supply Stop/Check Valves

These normally-closed valves open to provide flowpaths for steam from each of the steamgenerators to the respective AIW Pump turbine. They close to provide isolation betweenthe steam genemtors in the event of a steam line break upstream of the MSIV,S. (FSAR10.2.2)

Test Requirement: CV-O BT-O BT-C PIT

NUREG-1482 E-2

APPENDIX F

DESIGN BASES REVIEW PROCESS DESCRIPTIONFOR COMPLIANCE

WITH GENERIC LETTER 91-18 GUIDANCE

e ~EdbenDOMUS Grove, Ilbnm 60S1S

August 17, 1994

U.S. Nuclear Regulatory ComxniaeionDocument Control DeekWashington D.C. 2055S

Attention: Mr. William T. Rued

Subject: Ineervice Testing Progmn Plan for Puxnpe and Valvee~ scope update

Byron station Unite 1 end 2(NPF-37W, NRC Docket Noe. 50-454MS)

Braidwood Station him 1 and 2(NPF-7V77; NRC Docket N= SO-46W467)

Dear Mr. Ruaeell:

IMngtworecent regiodinap-hudt i-m T-iq(~m6-(MaY, 1963 at Braidwood and JUMXY, lm:~ar) ● w*- ~ ~ P~ecope was identified. Byron and BAdwood committad * jointly reviewtheecopeofthe ISTpmgramuid develop aecopingbdedocummL Tbieecopiageffbrtwae being pdbrmedinacedmce with the ecoping guiddinee found inASXkfWANSI OM-1966, Parta 6 and 10. The uee of OM-6 and OM-10 will enablethis -- W be ueed f6r Byron’s tan-year (eecond interval) pm@’am U@@M.

Oroapl - Unitlead Commoa Cold ShutkwRAdw.

Gmup2 - unit 2 CoAd shuammfdag.

(haps - Naamal Quertdytat

F-1 NUREG-1482

Mr. Rued -2- Auguet 17, 1994

Both eitee intend to teet Groupe 1 and 2 valvee during the appropriate upcomingoutagee. Group 3 vahme will be teetad at normally echeduled quarterly intervaia.For Byron Station, all new valvee will receive initial teeting by the completion ofthe upcoming Unit 2 refieling outage (cunwnt completion date of #16@5).SmiliaAy, Braidwood plane on completing all initial valve teeting by the end ofthe upcoming Unit 1 refieling outage (current completion date ie 1W5).

The following detaile the site s-c implementation phx

owlu94 Submit IST Program revision including ●dditional ecope.

0w2m4 - IIAm “Begin implementation of quarterly ~ (Group 3) andof valva identihd ea RefiMling Gutq#Cold Shutdownfbr unit 1 (Group 1)

02/95 -ou16@5 Bagia implemeaation of ~ vahme identid u~ Gut@Cold shutdown fbr unit 2 (Group 2).~ tuting (-p 3) implementation Continuee.

04/wM All ndy identified valvea have been initially teat+ endam beiag - per kquency r@quiremen*.

● Pleaae note that thie implamantation echedule ~ teeting of the Groupava,lvab-toulm. ‘x’hietimehmoie ~ becauee of the~-heus&~ofkpl&2+ud~tiUdtl&2~wM-Adddti*atiti*e.

NUREG-1482 F-2.: -?

APPENDIX G

COMMENTS AND RESPONSES ON DRAFT NUREG-1482

NUREG-1482)��

Draft NUREG-1482 was published November the section in the draft NUREG-series report.1993. Federal Register, Volume 58, Number Comments related to the same issue have been240, pages 65738 and 65739, December 16, consolidated. Many comments have been1993, published proposed Supplement 1 to paraphrased. The responses to the commentsGeneric Letter (GL) 89-04, "Guidance on have been incorporated into the final NUREG-Developing Acceptable Inservice Testing series report where appropriate. ChangesPrograms," which referenced the draft between the draft NUREG-1482 and the finalNUREG-1482. Public comments were NUREG-1482 are generally discussed in thesolicited on both documents. A public comments and responses; however, the staffmeeting was held on February 2 and 3, 1994, also made changes to address other issuesand the public comment period closed March raised in the intervening period through10, 1994. This attachment includes most of inspection activities, OM Committee meetings,the comments and a response to each. The and the NRC/ASME Third Symposium oncomments have been arranged according to Testing Valves and Pumps, held July 1994.

NUREG-1482 )��

COMMENTS ON SECTION 1, “INTRODUCTION”

Comment 1-1 conformance was not adequately documented

Is it the intent that licensees can use the statedrecommendations in the NUREG-series reportregardless of their current code-of-record aslong as the use is documented in the IST Does the NUREG-series report provide theprogram submittal to the NRC? The draft "Commission approval" as needed perreport indicates that documenting use of the 10 CFR 50.55a(f)(4)(iv) for using laternew guidance in the IST program is sufficient editions of the Code? Is this a pre-approvalfor certain circumstances. However, in the document? If so, when can we start using thepast some licensees have been directed to report for pre-approvals?submit plant specific relief requests for itemspreapproved by GL 89-04. Response 1-2

Response 1-1

Yes. When using the guidance of the Supplement 1, which will give theNUREG-series report, certain "Commission approval" as required byrecommendations can be implemented without 10 CFR 50.55a(f)(4)(iv). The approval isrequesting further approval from the NRC. It effective when the final generic letteris acceptable to document the use of such supplement is issued.recommendations in the IST program(discussed further in Response 1-7). GL 89- Comment 1-304 directs licensees to document the use ofPositions 1, 2, 6, 7, 9, and 10 in the ISTprogram, but does not direct that thedocumentation must be in the form of a reliefrequest. GL 89-04 granted approval to followthe alternative testing delineated in Positions1, 2, 6, 7, 9, and 10 if the provisions of GL 89-04 are followed, pursuant to 10 CFR 50.55a(g)[now (f)]. Most licensees have documentedthe use of these positions in relief requests forconvenience; however, documentation in theprogram is acceptable in another format aslong as it is clear that the provisions of thereferenced positions are documented anddiscussed in adequate detail to indicateconformance with such provisions. Perhapsthe reason certain licensees may have beendirected, presumably by NRC inspectors, tosubmit relief requests was that the

in the program.

Comment 1-2

The NRC will state the endorsement of theNUREG-series report in Generic Letter 89-04,

Does the NRC anticipate the approval of latereditions of the Code into 10 CFR 50.55abefore the end of 1994?

Response 1-3

Even if a proposed rulemaking is issued beforethe end of 1994, it is unlikely that the finalrule would be effective before the end of1994. The later edition of the code forinservice testing (IST) would be theOperations and Maintenance Code.

Comment 1-4

Throughout the document, "the Code" isreferenced when it is apparent that referenceto either Section XI, OM-6 and OM-10, or

NUREG-1482)��

ASME/ANSI Operation and Maintenance Response 1-6Standards, 1988 Addenda (OMa-1988) isintended. This is confusing and, in somecases, misleading. All references to Coderequirements should carefully refer to theproper document.

Response 1-4

The document is written for the latest editionincorporated into Paragraph (b) of10 CFR 50.55a, which is as noted in Section 1. To the extent practical, the document reflectsthe applicable section, subsection, orparagraph of the appropriate documents.

Comment 1-5

In invoking certain requirements of OM-1, 6, the licensee is complying with the code.and 10, without an approved relief request, asallowed by 10 CFR 50.55a(f)(4)(iv) for Response 1-7licensees that have not updated to theappropriate editions of the Code that endorsesthese standards, do these standards have to beimplemented in their entirety or can selectsections be implemented?

Response 1-5

Licensees may update to the 1989 Edition of This approval is generic through the NUREG-the Code in its entirety. This edition series report as endorsed by GL 89-04,references OM-1, OM-6, and OM-10 as the Supplement 1. Only a reference is required. rules for IST. Portions of OM-6 and OM-10 The entire recommendation need not beare listed for approval by the NUREG-series restated in the IST program.report, as endorsed by GL 89-04, Supplement1, in Section 1. Use of the later edition of the Comment 1-8Code, or portions listed in Section 1, is to bedocumented in the IST program. TheNUREG-series report gave approval for suchuse in accordance with10 CFR 50.55a(f)(4)(iv).

Comment 1-6

When does the NRC expect to incorporate the restrictive than 10 CFR 50.55a or the ASMEOM Code into 10 CFR 50.55a? Code, would then become a defacto

NRC is considering the OM Code in thepreparation of a proposed rule expected to bepublished in the Federal Register by October1995.

Comment 1-7

The draft guidelines state several times that,although the requirements are as stated in theASME OM Standards and the licensee iscomplying with the Code, "if a licenseechooses to implement this guidance, thissection [of the guidelines] must be explicitlyreferenced in the IST program.” A licenseeshould not have to state in the IST programthe methods of ensuring Code compliance, if

The approval to use the later edition (orportions of the later edition) of the codeapplies for licensees not already using OM-6and OM-10. For licensees using earliereditions, a reference to the guidelines sectionis necessary to ensure that the requisiteapproval pursuant to 10 CFR 50.55a (f)(4)(iv).

It appears from the second paragraph of thissection that the staff will use the NUREGguidance as a basis for granting relief even if arelief request was not written using theNUREG. If this is the intent, then a backfitanalysis should be required since thisadditional guidance, which may be more

regulatory requirement.

NUREG-1482 )��

Response 1-8

The guidance discussing the use of theNUREG-series report for granting relief orapproving alternatives is for requestsconforming to the guidance. NRC willreference the applicable section in the reportand not repeat the entire evaluation. Therecommendations in the report for requestingalternatives include issues for which anacceptable alternative is stated. Licenseesmay continue to propose other alternativesthat will be evaluated individually and may ormay not be approved as requested. The reportrecommendations, other than when discussingregulatory requirements, are not themselvesrequirements.

NUREG-1482)��

COMMENTS ON SECTION 2,“DEVELOPING AND IMPLEMENTING AN INSERVICE TESTING PROGRAM”

Section 2.1, “Compliance Considerations” Response 2.1-2

Comment 2.1-1 The IST program consists of various

In the second paragraph, it is stated that alicensee must receive the Commission'sapproval prior to performing testing per latereditions of the Code. Is it assumed that this isintended to mean "before substituting the laterrequirements" since simply performing anadditional test should not be the NRC'sconcern unless an unreviewed safety questionexists?

Response 2.1-1 IST program if the valve is realigned under

The discussion in Section 2.1 relates tocompliance with the regulatory requirements. The sentence you refer to followed a sentencethat states that "IST may meet therequirements of subsequent editions." Thediscussion did not consider testing outside thatrequired for IST; however, the sentence wasdeleted to eliminate confusion.

Comment 2.1-2

The section states that changes to the scope,test methods, or acceptance criteria aresubject to the requirements of Section 50.59. Section 50.59 does not specifically addressprogrammatic documents or anydocumentation other than those that couldresult in an unreviewed safety question. Adetailed safety analysis (per § 50.59) of ISTprogram elements (other than plantprocedures) is typically not performed at mostplant sites and, if required, would result in acomplex and difficult process.

documents, many of which are administrative,that may not be covered by a 10 CFR 50.59review process. However, a determinationpursuant to 10 CFR 50.59 may be part of theprocess if components are deleted from theprogram, if acceptance criteria are changed, ofif a test method is modified.

Comment 2.1-3

A valve must be tested in accordance with the

10 CFR 50.59 during plant operation and istemporarily made active when it waspreviously passive (not inservice tested). However, what actions should be taken if thealignment will be restored to passive statusduring the next refueling outage and the valvecannot be tested during power operatingconditions? Adding testing requirements tothe IST program and then deleting them seemsto be an administrative hardship.

Response 2.1-3

If testing cannot be performed, it may bedifficult to establish a basis for considering thevalve capable of performing the "new" activesafety function. The procedure change, therelated evaluation for 10 CFR 50.59, and a"temporary change" to the IST program wouldbe adequate for documenting the newalignment without creating an administrativehardship beyond that required to ensure theacceptability of making the change. Thissituation is the responsibility of the plantoperating review committee in determining theacceptability on a case-by-case basis. A

NUREG-1482 )��

situation such as this may be treated as a Response 2.1-5nonconforming condition, and guidance inSection 7 may apply.

Comment 2.1-4

Section 2.1 discusses Regulatory Guide (RG) and modifications listed in paragraph (b), and1.147 and lists four code cases. Are these subject to Commission approval. By yourCode Cases listed because they are the only interpretation of the regulation, the phraseones that apply to IST? Please clarify the requiring Commission approval would not beNUREG. Also, please add a discussion needed. It became evident during the publicindicating that code cases that have been meeting held to discuss the NUREG-seriesincorporated into a licensee's program but are report that several licensees had interpretedno longer listed in RG 1.147 (because they the regulation similar to Entergy. Inhave been incorporated into ASME Codes) discussing successive inspection intervals,may continue to be implemented by licensees. Subsection IWA-2413 of the 1989 Edition of

Response 2.1-4

The code cases listed in Section 2.1 are thoseincluded in RG 1.147 that relate to IST. CodeCase N-427 discusses the use of supersededcode cases. If a code case was listed in anearlier revision of RG 1.147, the use would beacceptable for the applicable editions of thecode, unless specifically revoked by theregulatory guide.

Comment 2.1-5

In Section 2.1, it is stated that a licensee mustobtain NRC approval to use portions of latereditions and addenda of the ASME Code andreceive that approval prior to performing orconducting specific tests. The wording of thisrequirement should be consistent with thewording of 10 CFR 50.55a. If formal approvalis required prior to implementation, theregulation should so state. Entergy, in thepast, has performed testing to later editionsand addenda which were approved by theCommission and contained in10 CFR 50.55a(b) by notification of theintended use of an already approvedregulation.

Paragraph (f)(4)(iv) of 10 CFR 50.55a statesthat IST may meet the requirements of latereditions or addenda incorporated by referencein 10 CFR 50.55a(b), subject to the limitations

Section XI allows the use of later editions (orportions thereof if all related requirements aremet) approved by the regulatory body. If theuse of later editions and addenda isdocumented in the IST program, it isunnecessary to attempt to request furtherapproval at this time; however, it may beprudent to submit a letter to the NRC statingsuch application of later editions or addendaof the Code. Future rulemaking efforts willclarify the use of later editions and addenda ofthe ASME Code.

Comment 2.1-6

The guidance states that the NRC mayauthorize alternatives to the ASME Codetesting requirements submitted as reliefrequests. 10 CFR 50.55a(a)(3) does notspecify that an alternative be requested as arelief request. It is recommended to delete thelast four words of the sentence to beconsistent with 10 CFR 50.55a.

Response 2.1-6

The guidance reflects actual practice. It doesnot state that alternatives have to be submittedas "relief requests," but rather that we may

NUREG-1482)��

grant relief or authorize an alternative EPRI, NRC, and industry members tosubmitted as a relief request under either establish a risk-based testing methodology. paragraph (a)(3)(i), (a)(3)(ii), or (f)(6)(i) of Such a methodology will establish a basis for10 CFR 50.55a. Only recently has the NRC reducing or deleting testing. If NRC receivedreceived requests from licensees that a request to delete or reduce testing based ondifferentiate between "relief" and "proposed risk, the staff would most likely delay reviewalternatives." Licensees may continue to use until confirming that such a methodology isa relief request format, and when no specific acceptable. paragraph was referenced, the NRC reviewerwould use the approach used in the licensee'sSection 2.2, “Criteria for Selecting Pumpsjustification for the request. Similarinformation to a relief request is needed, inmost cases, to describe and justify analternative. If a licensee elects to request analternative in a letter or in some format otherthan as a relief request, the request will bereviewed. A phrase has been added to clarifythat another format is acceptable.

Comment 2.1-7

The reasons stated for NRC approval ofalternatives appear overly narrow. The NRCshould also approve alternatives when alicensee has shown that a reduction or deletionof testing will still provide an acceptable levelof quality and safety. Additionally, proposedalternatives should not need to comply withany ASME Code edition if the alternative willnot reduce the level of quality and safety.

Response 2.1-7

Approval under 10 CFR 50.55a(a)(3)(i) isbased on an alternative providing anacceptable level of quality and safety. Thealternative would monitor equipment in amanner that gives equivalent results as wouldbe achieved by monitoring in accordance withCode requirements. Licensees may proposealternative methods to the extent that theybelieve provide an acceptable level of qualityand safety. However, the staff does notgenerally approve alternatives that do notmeet the level that would be achieved by theCode testing. The NRC is working with anindustry group with participation of ASME,

and Valves for the IST Program”

Comment 2.2-1

When describing the scope for pump andvalve testing, ASME Section XI, OM-6, OM-10, and OM-1 do not use terms such as safety-related or safety function. The exact wordingused varies slightly between each document,but in the scope statement, they all use wordssimilar to a specific function in shutting downa reactor to the cold shutdown condition or inmitigating the consequences of an accident. When referring to scope, why does the firstparagraph of Section 2.2 use terms such as"safety function" and "all safety-related?" Itwould appear that terms similar to "safeshutdown" or "accident mitigation" wouldmore accurately reflect the scope statementsof the Codes.

Response 2.2-1

Section 2.2 has been modified to reflect theterminology used in 10 CFR 50.55a and theCode.

Comment 2.2-2

Regarding "safe" versus "cold" shutdown, willthe Commission be responsive to reliefrequests for restricting the programapplicability only to those systems andcomponents required for "safe" shutdownversus "cold" shutdown?"

NUREG-1482 )��

Response 2.2-2 increase in scope without a compensating

The application depends entirely on thelicensing basis of the plant. Relief requests forplants licensed for cold shutdown as the safeshutdown of the plant would not beacceptable. A relief request is not required forplants licensed with hot shutdown or hotstandby as the safe shutdown condition;however, it is recommended that the IST If NRC expanded the scope ofprogram document state the special condition 10 CFR 50.55a, it would do so only afterfor the plant in an introductory section. doing a backfit analysis in accord with

Comment 2.2-3 the criteria for justifying a backfit, it would

The scope of later editions of the Code (OM-6and OM-10) include testing of componentsthat are required for "maintaining the coldshutdown condition." What guidelines aregiven on how long cold shutdown must bemaintained? As the required period ofmaintaining the cold shutdown conditionincreases, more and more support systems notdesigned to mitigate the consequences of an Do deviations from the Code for noncodeaccident (design basis accidents in Chapter 15 components require a "relief request," or is aof the SAR) come into use. documented basis for the testing sufficient?

Response 2.2-3 Response 2.2-5

The period of interest would coincide with the Deviations from the Code for noncodesafety analysis for the plant. For example, if components need not be written as "reliefthe safety analysis is based on the capability to requests," but it is recommended that they bemaintain cold shutdown for 30 days, IST documented clearly in the IST program. If it iswould apply to the pumps and valves within not clear that the deviations relate to noncodethe scope of 10 CFR 50.55a that are used to components, it might be assumed that themeet this capability. requirements of 10 CFR 50.55a are not being

Comment 2.2-4 format to document such deviations, while

Section 2.2 states that the NRC will considerexpanding the scope of 10 CFR 50.55a toinclude all safety-related pumps and valves infuture rulemaking. The scope of10 CFR 50.55a should not be changed from itscurrent scope because it would result in an

increase in the level of safety. For example,the rulemaking would require testing of pumpsand valves that were not originally designed toaccommodate testing in accordance withSection XI/OM.

Response 2.2-4

10 CFR 50.109. If the expansion did not meet

not be implemented in the regulation. ASMEcreated a special task group to review thescope and testing requirements from a riskperspective. Changes to the scope of theCode may result in future changes to thescope of 10 CFR 50.55a.

Comment 2.2-5

met. Some licensees use the relief request

other licensees use notes, footnotes, or shortdescriptions in the program document.

Comment 2.2-6

Clarify which of the following represents thescope of the IST program: (1) ASME Boiler

NUREG-1482)��

and Pressure Vessel Code (BPVC), Section mitigation of design basis accidents in ChapterXI, Class 1/2/3 components; (2) Regulatory 15 of a facility's Safety Analysis Report?Guide 1.26 Quality Group A/B/C; or (3) OMParts 6 and 10 scope statement. If pumps or Response 2.2-7valves are not ASME Code Class 1/2/3, thenare they outside the scope of the IST program? What about an ASME BPVC Section III plantversus an ANSI B31.1 plant? FSARidentification of the code class? FSARcommitment to place component in ISTprogram?

Response 2.2-6

The scope of the IST program is defined in components used for safe shutdown and10 CFR 50.55a, Paragraphs (f)(1), (f)(2), and maintaining safe shutdown. Devices that give(f)(3). For components that fall within the overpressure protection are included in thescope defined in these paragraphs, the scope Code beginning with the 1986 Edition. Seeof the IST program is further narrowed by the Appendix A for similar discussion forscope of the ASME BPVC, Section XI, Question 104 from the GL 89-04 meetings. Subsections IWP and IWV, and, whenapplicable, OM-6 and OM-10. If the scope of Comment 2.2-8IWP/IWV or OM-6/OM-10 appears to bebroader or narower than the scope of10 CFR 50.55a, the more narrow scopeapplies. If the FSAR indicates that a systemor component is Code Class 1, 2, or 3, thesystem or component is within the scope of10 CFR 50.55a. If the FSAR states that asystem or component is designed, fabricated,and maintained as code class at the option ofthe owner as permitted by Paragraph IWA-1320(e), then the application of therequirements in Section XI are also optional. If a licensee committed to include acomponent in the IST program, the componentis within the scope of the program but may beremoved under 10 CFR 50.59 if the criteriaare met. If the TS require a component to betested under the IST program, the componentis within the scope.

Comment 2.2-7

What is an "accident" as used in the code? Isit the intent of 10 CFR 50.55a to includecomponents other than those included in the

When discussing safety functions to "mitigatethe consequences of an accident," the code isreferring to design bases accidents or otherexpected events stated in the plant's safetyanalysis report. The scope of the IST programis defined in 10 CFR 50.55a(f) and furthernarrowed by the scope defined in IWP/IWVwhich, in addition to mitigating theconsequences of an accident, cover

What kind of documentation would berequired for deleting entire systems from theIST program such as reactor core isolationcooling (RCIC) or standby liquid control(SLC)? Both of these systems have beenproven to be outside our IST program scope asidentified during a recent design basesdocumentation (DBD) review.

Response 2.2-8

The documentation would need to include, asa minimum, the changes made to the safetyanalysis report under 10 CFR 50.59 (ifnecessary) and the evaluation of the change tothe IST program that stated the basis (orreferenced the basis in the DBDdocumentation). Most IST programs forBWRs include SLC, as it is one of the systemsrequired for safe shutdown, to maintain safeshutdown, and to mitigate the consequences ofan accident. The TS for many BWRs includea surveillance for the RCIC and SLC pumpsand valves and may need to be changed.

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Comment 2.2-9 cover systems such as instrument and service

Our facility currently conducts componenttesting for emergency diesel generator (EDG)support systems (fuel storage and transport,lube oil, cooling water, starting air, andcombustion air/exhaust), as required by10 CFR 50, Appendices A and B, under theIST program. In so doing, administrativeoverhead is minimized since this testing can beconducted as part of an established,mandatory program. We currently classifythese systems as Code Class 3, which appearsconsistent with NUREG-0800, "StandardReview Plan," Sections 3.2.2 and 9.5.X. Inthe response to Question Question 54, it isstated that EDG air start systems are typicallynot code class systems. It has beenconvenient for us to consider these systemsClass 3 for COMPONENT testing underIWV/IWP; however, it has been difficult (and,due to the media and service conditions, ofvery little value) to attemptrepairs/replacements and pressure testingunder the rules of Section XI for thesesystems. Could we consider these systems asCode Class 3 for IST only (i.e., not ISI), orreclassify these systems as non-code class andcontinue performing component testing withinthe IST program? This also applies to certainsafety-related pump lube systems.

Response 2.2-9

Licensees for plants licensed under thestandard review plan (SRP) may haveclassified certain systems as Code Class 3 thatwould not be so classified in earlier plants. The licensees may have classified the systemsin this manner expecting that the systemswould be required to be code class; however,the SRP recommends rather than requires thatthese systems be classified as Quality Group C(corresponds to Code Class 3 in RG 1.26).

Regulatory Guide 1.26 states that it does not

air, diesel engine and its generators andauxiliary support systems, diesel fuel,emergency and normal ventilation, fuelhandling, and radioactive waste managementsystems. However, the guide states that thesesystems should be designed, fabricated,erected, and tested to quality standardscommensurate with the safety function to beperformed.

The licensee is responsible for determining ifthe classification of Code Class 3 is requiredor if it is optional under IWA-1320(b) or (c). IWA-1320(b) states that optional constructionof a component within a system boundary to aclassification higher than the minimum classestablished in the component designspecification shall not affect the overallsystem classification by which the applicablerules are determined. IWA-1320(c) states thatwhere all components within the systemboundary or isolable portions of the systemboundary are classified to a higher class thanrequired by the group classification criteria,the rules of IWB, IWC, and IWD may beapplied to the higher classification. See ISTA1.3.2, "Classifications," of the OM Code forsimilar information on components within thescope of the OM Code. If the codeclassification is changed pursuant to10 CFR 50.59, the pumps and valves mayremain in the IST program as augmentedcomponents (denoted as noncode), as noted inPosition 11 of GL 89-04. Additional guidanceon the scope of the IST program may beprovided in another document.

Comment 2.2-10

Section 2.2 should include a discussion ofvalves which may be required to close toprevent exceeding the 10 CFR 100 off-siterelease limits. It should be pointed out that

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each valve that closes automatically as a result on a plant-by-plant basis identify theof radiation readings should be examined to components important-to-safety which are notsee whether the failure of the valve to close code classed. Secondly, history, currentcould lead to exceeding the 10 CFR 100 testing and preventative/predictivelimits. It should also be pointed out that if the maintenance schedules could be reviewed forfluid involved is a liquid which will not flash adequacy and revised as appropriate. Again,to steam, the likelihood of exceeding the this approach is in line with implementing the10 CFR 100 limits is remote. maintenance rule. The intent would be to

Response 2.2-10 practices providing assurance of availability.

The "Current Considerations for Position 3" inAppendix A address back flow of checkvalves. A reference to IN 91-56 has beenadded to Section 2.2. The NRC is evaluatingthe need for additional guidance in this area.

Comment 2.2-11 Members of the OM Committee at the time

The draft NUREG-1482 acknowledges thatthe scope of the OM Standards and Code hasbeen expanded to include all safety-relatedpumps and valves in the IST program. Until10 CFR 50.55a is changed, the scope of theIST program will continue to include thosecomponents within the code classes. However, the NRC stated that they wouldconsider expanding the scope of the ISTprogram to include all safety-related pumpsand valves. The current scope of code classesis adequate. Safety-related valves and pumpsoutside the code class boundaries areaddressed by other measures such as theplant-specific technical specifications,maintenance rule, and the industry post-maintenance testing programs. Including allsafety-related components in the IST programincreases the regulatory burden without acorresponding increase in overall safety. Mandatory imposition of ASME ISTrequirements on non-code classed componentsconstitutes a backfit. Many of thecomponents were not designed with thenecessary provisions to perform testing (flowinstruments, gages, etc.), modification wouldbe necessary to perform tests in compliancewith code requirements. The industry could Section 2.2 states that components necessary

provide documented justification of these

The other extreme could require a similarreview, generate reliefs, and probablyultimately result in unnecessary plantmodifications.

Response 2.2-11

the scope statement was developed havestated that the committee did not intend toincrease the scope of OM-6 and OM-10beyond the scope of the 1986 Edition ofSection XI. Originally, the scope statementwas written to apply to ASME Code Class 1,2, and 3 components. The scope statementwas written to include these componentsbecause many plants were licensed beforeCode Classes 2 and 3 were included in theconstruction code. The scope was intended tobe consistent with 10 CFR 50.55a. Therefore,it would be inappropriate to assume that thescope of OM-6 and OM-10 is broader than10 CFR 50.55a. The components outside thescope of 10 CFR 50.55a may be included inthe scope of 10 CFR 50.65, "Requirements forMonitoring the Effectiveness of Maintenanceat Nuclear Power Plants" (the "MaintenanceRule"). If codes and standards are developedfor components other than ASME CodeClasses 1, 2, and 3, the NRC would determineif changes to the regulation would be needed. Any such changes would be subject to theprovisions of 10 CFR 50.109, "Backfitting."

Comment 2.2-12

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to achieve and maintain cold shutdown may Response 2.4.2-1not be within the scope of IST for plantswhich were licensed to operate with a "safe"shutdown condition of hot standby or hotshutdown. However, 10 CFR 50.46(b)(5)required that the calculated core temperatureshall be maintained at an acceptable low valueand decay heat shall be removed for theextended period of time required by the long-lived radioactivity remaining in the core. Is atemperature greater than boiling an acceptablylow temperature post-LOCA? Also, many ofthe systems or components used to bring aplant to cold shutdown are the same ones usedfor long-term decay heat removal. Even if aplant is licensed for hot shutdown, are thesystems and components required by10 CFR 50 to remove decay heat and maintaincore temperature required to be tested andinspected per the Codes? Please clarify.

Response 2.2-12

The requirements for 10 CFR 50.46(b)(5) forlong-term post-LOCA cooling would beestablished by the ECCS calculated coolingperformance established to meet therequirements for 10 CFR 50.46. Therequirements of 10 CFR 50.46 will be met aslong as the temperature is decreasing. TheECCS pumps and valves are within the scopeof 10 CFR 50.55a. Guidance in the NUREG-series report does not supersede anyregulatory requirements. Certain requirementsof 10 CFR Part 50, such as Section 50.46,were backfit on earlier licensed plants. SECY-92-223 gives information on theresolution of such issues. Section 2.4.2, “Valves”

Comment 2.4.2-1

Under system description, replace "pump"with "valve."

The change is made as noted.

Comment 2.4.2-2

Section 2.4.2 has a paragraph headed"Active/Passive." The examples in AppendixB to this NUREG do not list this informationfor the valves. Even though "Active/Passive"is not included in Appendix B, it is not neededbecause it is inferred from the testing required.

Response 2.4.2-2

The examples in Appendix B are from actualIST submittals and do not include all of theitems recommended in Section 2.4.2. It wouldbe helpful to include "Active/Passive." Toooften, inferences create confusion whileclarity eliminates confusion.

Comment 2.4.2-3

In a case where testing of excess flow checkvalves is controlled by a technicalspecification surveillance requirement, maythe approximately 100 valves be addressedgenerically, or must each valve be listed in thevalve table of the IST program?

Response 2.4.2-3

It may be more appropriate to list each valve,particularly if the valves are shown ondifferent drawings and if some of the valvesare leak tested while others are not. If valvesare grouped together on the valve table, thenumber of valves (and the valve numbers)must be clearly indicated.

Comment 2.4.2-4

Table 2.3 appears to provide an acceptableexample pump table format. Could a similar

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acceptable example valve table format be Section 2.4.3, “Piping and Instrumentprovided?

Response 2.4.2-4

Appendix B includes several sample valvetables with various differences and of variousformats. Various formats would be acceptableas long as the appropriate information ispresented. If valves are sorted by system, across-reference by valve number is helpful.

Comment 2.4.2-5

IWV-2100 defines a passive valve as one are not justified. However, if relief requestswhich is not required to change position to are submitted, submitting the pertinentaccomplish a specific function. Can a valve drawings to the NRC to assist their review isever be removed from its safety position and warranted when NRC concurrence is required.still be considered passive? If so, how often?

Response 2.4.2-5

Though this question may better be addressed contractors who review relief requestsby the OM Committee, it would seem maintain a set of SARs for each plant. Theappropriate that the position of the valve may IST reviewers do not receive a copy of thebe changed while the valve is out of service inservice inspection program plan. Drawingswithout requiring IST if the valve is are helpful in reviewing relief requests,temporarily removed from service, or if the whether submitted as part of the program or asplant is in a mode that does not require the an attachment to any relief request orvalve to be in its "passive" position. However, proposed alternatives. However, the staff willif a valve has to reposition to fulfill a safety limit requests unless necessary so as not tofunction, and if the valve is normally in the place a burden on licensees. opposite position or may be routinelyrepositioned during power operations, it is an Section 2.4.4, “Bases Document”active valve and is subject to IST. If it isrepositioned to create a new valve alignment(e.g., as corrective action for a condition ofanother valve in the line), the licensee wouldconsider IST in determining whether the newalignment is acceptable.

Diagrams”

Comment 2.4.3-1

The staff recommends that drawings beincluded in the program submittal. Thisrecommendation places an unnecessaryburden on the licensee to supply drawings inthe IST program plan. Drawings are availablein updated FSAR submittals. In addition,Section XI boundary drawings are available inthe inservice inspection program plan. Redundant drawings in the IST program plan

Response 2.4.3-1

Neither the technical staff at the NRC nor the

Comment 2.4.4-1

The last sentence of Section 2.4.4 could bemisinterpreted to mean that the basesdocument would be included as a licensingbases document. Is it the intent that the basesdocument be a licensing bases document, orsimply be used to assist in the performance ofa 10 CFR 50.59 evaluation search forapplicable licensing bases documents?

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Response 2.4.4-1 IST program?

The recommendation was not intended toimply that the bases document itself must be alicensing bases document. The statement has Yes. It is important that the NRC have abeen clarified. complete program document for reviews of

Section 2.4.5, “Deferring Valve Testing to specifications, and event assessments.Cold Shutdown or Refueling Outages”

Comment 2.4.5-1

What is "impractical?" What could beconsidered when determining impracticality? Economic considerations? If the only test thatcan be performed for verifying closure is anLLRT [local leak-rate test], is that alonesufficient to establish impracticality asdiscussed in Section 4.1.3?

Response 2.4.5-1

Impractical conditions could result in a plantshutdown, which would cause unnecessarychallenges to safety systems, undue stress oncomponents, and additional cycling ofequipment, and may reduce the lifeexpectancy of the plant systems andcomponents. An impracticality may be alimitation of design, geometry, or material ofconstruction of components (e.g., no test taps,pumps cannot overcome pressure, no availableflow path). Radiation exposure and personnelsafety may constitute an impractical conditionin certain plant modes. Testing that couldcause a plant trip or require a power reductionwould be impractical. Section 4.1.3 givesguidance on setting up leak test equipment.

Comment 2.4.5-2

Is there a need or preference on the part of theNRC for licensees to include cold shutdownjustifications and refueling outagejustifications in the 120-month submittal of the

Response 2.4.5-2

relief requests, reviews of changes to technical

Section 2.5.1, “Justifications for Relief”

Comment 2.5.1-1

Examples are given for justifying relief. Oneof the examples specified is ALARA. CanALARA alone be used to justify coldshutdown or refueling outage testingfrequencies without a relief request, providedall the requirements of Paragraphs 4.2.1, 4.3.2,and 6.2 of OM-10 are met for deferring testingand documenting the deferral in the ISTprogram? Does NRC have any predeterminedacceptable limits for radiation exposure for theperformance of a single test which will allowchanging test frequency from quarterly to coldshutdown or refueling outages?

Response 2.5.1-1

ALARA relates to controlling exposure duringan activity, not specifically to eliminatingactivities; however, it may be a basis fordeferring an impractical test when exposurelimits to perform testing (or possibly to accessa valve for repair in the event it could failduring a test) are prohibitive. The testingcould be deferred to cold shutdown orrefueling outages when the exposure limitswould no longer be prohibitive. ALARA ispart of an overall program required by10 CFR 20.1101, including activities such asIST. NRC has not established "predeterminedacceptable limits" for deferring an ISTactivity.

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Comment 2.5.1-2 Request, and (3) Check Valves in Series Relief

We believe that the following items areexamples for determining impracticability ofexercising a valve during plant operation: (1)risk of a plant trip, (2) risk of damage to a in an inservice testing program for asystem or component, (3) excessive personnelhazard, (4) risk of test-induced componenthazard, (5) effect on plant safety, (6) difficultyof test, (7) cost of test, and (8) failure ofcomponent in a non-conservative directionwould cause total loss of system function(non-redundant). However, the typicalburden of performing non-intrusive testtechniques, by itself, does not constituteimpracticability.

Response 2.5.1-2

The list appears to address impracticalconditions, except that the difficulty and costof testing do not, alone, constituteimpracticalities.

Section 2.5.3, “Content and Format ofRelief Requests”

Comment 2.5.3-1

Since none of the relief request examples wereprovided with a title, exactly what type of title Comment T2.1-2does the NRC have in mind for requests?

Response 2.5.3-1

Sample titles follow: (1) Relief Request valves, as these valves are required to beNumber 1, (2) Safety Injection Pumps Relief operable in order for the pump to function.

Request. A unique number is also useful foridentification purposes.

Table 2.1, “Typical systems and components

pressurized-water reactor”

Comment T2.1-1

Although the table has some merit, it would bemuch more valuable if the staff would provideguidance with respect to more complex issuessuch as the requirement for maintainingredundancy, passive failure protection, etc.

Response T2.1-1

The guidance does not address issues outsidethe scope of inservice testing. The itemsmentioned apply to IST in determining thescope of the program, determining whatcomponents would remain in service duringtesting, and considering when removingequipment from service for testing; however,these items are needed for the safe operationof the plant and are not specific to IST. Suchguidance is beyond the scope of thisdocument.

Table 2.1, in several places, refers to "pumpand discharge check valves." This statementshould be modified to include suction check

Response T2.1-2

A reference to pump suction valves has beenadded.

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COMMENTS ON SECTION 3,“GENERAL SUPPLEMENTAL GUIDANCE

ON INSERVICE TESTING”

Section 3.1, “Inservice Test Frequencies Comment 3.1.1-2and Extensions for Valve Testing”

Comment 3.1-1

This section should state that it refersspecifically to valve exercising and not totesting in general.

Response 3.1-1

The title of the section has been changed tostate that it applies to valve testing.

Section 3.1.1, “Deferring Valve Testing toEach Cold Shutdown or Refueling Outage”

Comment 3.1.1-1

With incorporation of the 1989 Edition of theASME Code into 10 CFR 50.55a, is a reliefrequest required to defer testing of valves on arefueling outage frequency?

Response 3.1.1-1

Supplement 1 to GL 89-04 gives approval touse Section 3.1.1 of NUREG-1482 forimplementing the paragraphs of OM-10 ondeferring testing of valves to refuelingoutages. Although the supplement does notinvalidate existing relief requests, the licenseemay write test deferrals rather than reliefrequests, with a statement that Section 3.1.1 ofthe NUREG-series report is being used. Asingle reference to Section 3.1.1 may beincluded in the IST program document ratherthan referencing it in each test deferral.

When considering deferring valve testing tocold shutdowns or refueling outages, somevalves could be tested quarterly, but thetesting involves a hardship; i.e., a limitingcondition for operation of 3 to 4 hours inlength, the repositioning of a breaker from"off" to "on," and necessity of manualoperator actions to restore the system shouldan accident occur while the test is in progress. Performing a test quarterly for such situationscan put the plant at a greater risk than thebenefit achieved with a quarterly test. Is this asufficient reason to defer a test to coldshutdown?

Response 3.1.1-2

Section 3.1.2 gives guidance on some of thesesituations. Otherwise, it would be appropriateto weigh the safety effect against the benefitsof testing as a basis for deferring testing fromquarterly to cold shutdowns or refuelingoutages. A method is described inNUREG/CR-5775.

Comment 3.1.1-3

Section 3.1.1.2 discusses testing valves duringpower ascension from a refueling outage. What does the phrase "except for valveswhich must be tested during power ascensionfor which technical specification requirementsfor the valves or the system determine whenthe valves are required to be operable" meanand where did it come from as it is not part ofOM-10?

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Response 3.1.1-3 long as the plant remains in that mode. The

The phrase is the subject of Section 3.1.1.2 ofthe report. OM-10 requires that valves testedon a refueling outage frequency be testedbefore returning the plant to operation. Several licensees have stated that certain Section 3.1.1.3 allows refueling outage testingvalves cannot be tested until power ascension for valves requiring containment to be de-begins. This section was included to give inerted. When happens if a forced outageguidance for such valves and to state that the with containment de-inerting occurs? Shouldoperability of technical specifications would these valves be tested during cold shutdowncontrol the time for testing such valves. It is even through refueling outage justification isintended that such valves will be stated as included in the IST program and allowed bytested on a refueling outage frequency, even Section 3.1.1.3?though the plant may return to "operation"before the testing is completed. Although Response 3.1.1-5valves tested during power ascension fromcold shutdowns that are not refueling outageswould be tested similarly, the requirement inOM-10 differs for valves tested on a coldshutdown frequency.

Comment 3.1.1-4

When performing testing during cold activities could be considered in making ashutdown periods, there should be a priority or decision. The requirements of Paragraphtime limit for testing valves that are 4.3.2.5 of OM-10 or IWV-3416 of Section XIspecifically required to be operable (with a for valves in systems out of service may applysafety function) under cold shutdown for extended outages of several months (seeconditions. Also, the requirement to continue Section 3.1.3). Guidance on minimizingto test these valves at a quarterly frequency shutdown risk that may affect such a decisionshould be discussed and clarified. may also apply for extended outages.

Response 3.1.1-4 Comment 3.1.1-6

While the comment is well intended, neither Are licensees expected to invest in checkOM-10 nor IWV seems to require that testing valve nonintrusive equipment for the specificbe performed before operating a system used purpose of testing valves quarterly in lieu ofonly during cold shutdown, or that testing during cold shutdowns or refueling outages?continue at a quarterly frequency for valvestested only during cold shutdown. These Response 3.1.1-6standards appear to require (1) that valvestested quarterly continue to be testedquarterly, even when the plant is shut down,unless the system is out of service, and (2) thatvalves and pumps in systems in service duringshutdown conditions be tested quarterly as

OM Committee may clarify the intent throughthe inquiry process.

Comment 3.1.1-5

The staff determined that few outages requirede-inerting and that maintaining a separateschedule for valve testing was not warranted. When an extended cold shutdown necessitatesde-inerting the containment, testing is at thediscretion of the licensee. The length of theshutdown and the extent of other outage

No.

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Comment 3.1.1-7 referenced. It is to be referenced by licensees

Referring to Item (1) of the guidance from the1976 NRC letters to licensees, does this meanthat cycling non-redundant valves in aremaining operable train may be deferred tothe next cold shutdown when one train is outof service, since their failure would cause aloss of total system function, even if testing isspecified in the technical specificationsurveillance?

Response 3.1.1-7

In the licensing process, NRC weighed thepossible safety consequences and benefits ofperforming a test required for a technicalspecification surveillance even when one trainis out of service. The guidance in the Testing”NUREG-series report and in the 1976 lettersdoes not supersede technical specificationrequirements.

Comment 3.1.1-8

For implementing cold shutdown testingrequirements of OM-10, Paragraphs 4.2.1.2(g)and 4.3.2.2(g), why does the section have tobe referenced in the IST program if a licenseealready uses OM-10? It is not clear whatadditional requirements are imposed by OM-10, Paragraph 6.2, for not completing all coldshutdown valve exercising. What is theNRC's position on the effort that a plant mustexpend to complete all cold shutdown valveexercising during short outage? Is anydocumentation required for the valves thatwere not tested during the short outage but arebeyond the required 92-day frequency?

Response 3.1.1-8

If a licensee has already updated the ISTprogram to the requirements of OM-10,Section 3.1.1.1 does not need to be

using earlier editions of the Code to implementthe referenced portion of OM-10. The staffdeleted the reference in this section toParagraph 6.2, which does not impose anyrelated requirements and was incorrectlyreferenced. The NRC does not have aposition on the efforts a licensee expends inperforming cold shutdown valve testing;however, it is expected that a "good faith"reasonable effort would be expended. TheCode does not require documentation forvalves not tested during a cold shutdownoutage other than as would be required formaintaining the IST schedule.

Section 3.1.2, “Entry into a LimitingCondition for Operation to Perform

Comment 3.1.2-1

It is unclear why the relief request examplewould be acceptable. Based on the example,it appears that pump testing could also bedeferred. For example, some plants do notwant to inject auxiliary feedwater into steamgenerators during power operations so theymanipulate valves (manual, motor-operated,or air-operated valves) in test lines to providea flow path. If a relief would be granted forvalve stroking, would it also be granted forpump testing under similar circumstances?

Response 3.1.2-1

Pumps are generally tested quarterly onminimum recirculation test lines if the normalflow path is not available, as in your examplefor injection auxiliary feedwater into thesteam generators. Position 9 of GL 89-04discusses testing on minimum flow with nomeasurement of flow and recommends that amore substantial flow test be performed duringoutages using installed flow elements. The

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new "comprehensive pump test" requirementsComment 3.1.2-3in the OM Code will also address pump testingat normal flow rates. Licensees havesubmitted relief requests and test deferrals forcheck valves in pump discharge lines becausethe full accident flow cannot be obtainedduring quarterly testing. The example inSection 3.1.2 has been modified slightly torepresent the condition more accurately, toensure that your concern is addressed, and toensure that licensees understand that a reliefrequest is not necessary for deferring pumptesting in accord with Position 9.

Comment 3.1.2-2

This section states that "IST which results in asystem being completely removed fromservice may not be acceptable." However, thesubsequent example of a relief requestevaluation references TS 3.0.3. Thisspecification establishes the shutdown actionrequirements that must be implemented whena limiting condition for operation is not metand the condition is not specifically addressedby the associated action requirements. TS3.0.3 allows one hour to prepare for an orderlyshutdown before changing the plant operation.

Response 3.1.2-2

Entry into TS 3.0.3 may not be the sole basisfor requesting relief or an alternative. However, if testing cannot be complete withinone hour, or if a total system function isremoved and cannot be restored within onehour, this additional information would giveadditional justification. The example, whichhas been deleted, was from an actual reliefrequest. Simply stating that the test requiresentry into TS 3.0.3 does not preclude testing;however, entry into TS 3.0.3 would be thebasis for deferral and would be supplementedby the reason (e.g., "results in entry into TS3.0.3 because all ECCS systems becomeinoperable during this valve alignment").

In Section 3.1.2, does "multiple LCO" refer toonly a single LCO on two separate systems ordoes it also refer to two or more LCO actionson the same system?

Response 3.1.2-3

The sentence including the reference to"multiple LCO" has been deleted because itwas not necessary. The preceding sentencestated the major point of the discussion.

Comment 3.1.2-4

Draft NUREG-1482 takes the position thatlicensee should perform required quarterlytesting, even if entry into a limiting conditionfor operation (LCO) is required. Reliefrequests to defer testing must containjustification in addition to the entry into theLCO. This is a rather inflexible position, andmay unduly restrict prudent or cost-effectivescheduling.

Response 3.1.2-4

NUREG-1482 does not take a position onentry into an LCO to perform surveillancetesting. It merely references the position inNRC Generic Letter 87-09. LCO weredeveloped with surveillance testing in mind. While entry into an LCO may be part of anadequate justification for relief, the reliefrequest (or test deferral) must discuss theconditions that result from the testing or fromentering the LCO. GL 87-09 includes furtherguidance on allowable outage times forequipment. NRC is flexible in requiringlicensees to follow the test frequencyrequirements of the Code. If there issufficient justification for deferring testing, theCode allows such deferral. The licensee needsto ensure that the justification includes morethan a simple statement that entry into anLCO is necessary for testing. Brief sample

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statements follow: (1) testing must be Response 3.1.3-2deferred to cold shutdown because the plantwould enter TS 3.0.3 if the licensee did testingthat removes all ECCS from service andplaces the plant in an unanalyzed conditionand (2) testing must be deferred to coldshutdown outages because the plant wouldenter an LCO for the system when the valve isstroked to the fully closed position, and, if thevalve fails to reopen automatically, it cannotbe accessed during power operations formanual repositioning.

Section 3.1.3, “Scheduling of InserviceTests”

Comment 3.1.3-1

If plant-specific technical specifications,rather than standard technical specifications,reference a 50-percent grace period ratherthan a 25-percent grace period for testingfrequencies, how should the IST tests betreated?

Response 3.1.3-1

The inservice tests would be subject to thesame extension that the technicalspecifications allow for other surveillance testsunless specifically exempted; however, theextension would not apply to safety and reliefvalve testing performed at five- and ten-yearintervals unless the technical specification sostates.

Comment 3.1.3-2

The statement that the Code requires testingthroughout extended shutdown periods foroperable equipment applies only to OMdocuments, not previous versions of SectionXI.

Refer to the discussion in the basis for therecommendation in Section 3.1.3.

Comment 3.1.3-3

Does equipment removed from service withno maintenance need to be tested afterreturning to service?

Response 3.1.3-3

The equipment would not need post-maintenance testing but may need tests forother reasons.

Section 3.2, “Start of the Time Period inTechnical Specification Action Statements”

Comment 3.2-1

In the discussion on TS action statements andoperability declarations, should NRC GenericLetter (GL) 91-18 be referenced as a basis fordetermining operability?

Response 3.2-1

See the GL 91-18 discussion in Section 7 ofNUREG-1482.

Comment 3.2-2

If we are testing a pump and it fails, and weare quite sure the problem is with the gauge,do we have to declare the pump inoperableimmediately, or can we replace the gauge firstif we have not yet completed the test?

Response 3.2-2

The response to Question 46 in Appendix Aand Paragraph 6.1 of OM-6 and IWP-3230(d)allow that a gauge may be recalibrated (or

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replaced) and the test rerun (or completed). If low frequencies (1 - 5 Hz). May we halt theyou are not certain that the gauge is the test and repeat it using a new accelerometer? problem, it is recommended that the test be May we process the existing datacompleted as soon as possible with the electronically to obtain a true overall vibrationrecalibrated or replaced gauge to confirm the reading before making an initial operabilityresults. Additional guidance is given in GL determination?91-18.

Comment 3.2-3

What does the statement "the period the (IWP-3230(d) and Paragraph 6.1 of OM-6)component could be considered operable allow that instruments may be recalibrated andbased on the preliminary analysis is limited in a test rerun. Neither the code requirementsthe event the component is later determined to nor Position 8 limit the instruments covered bybe incapable of continued operability" mean? the provisions. Therefore, an accelerometer

Response 3.2-3 instruments rather than "recalibrating" meets

When a preliminary analysis is done to assessoperability, a more detailed analysis may benecessary if additional expertise is needed toreview the condition of a component. Themore detailed engineering analysis must beperformed in a timely manner followingdeclaring a component operable based on a by 10 CFR 50.55a(f)(4)(ii)”preliminary analysis. The more detailedanalysis may result in determining that thecomponent is incapable of performing itssafety function. Making this assessmentquickly will limit the time a component isconsidered operable (based on the preliminaryanalysis). In many cases, the preliminaryanalysis will be sufficient for long-termassessment or the more detailed analysis willconfirm the preliminary analysis. Fewsituations will likely require a more detailedanalysis and few will likely result in declaringthe component inoperable.

Comment 3.2-4

Position 8 of GL 89-04 states that a test maybe halted because of a gauge malfunction. Does this guidance apply to any instrumentsuch as a bad accelerometer)? We have seenindications of high vibration that were actuallyindications of poor instrument responses at

Response 3.2-4

Corrective action provisions in the code

meets the scope of the provisions. Replacing

the intent of the provisions (see Response 3.2-2). Licensees have a responsibility to ensurethat if instruments are replaced rather thanrecalibrated, the correct instrument number islogged in the test report.

Section 3.3, “120-Month Updates Required

Comment 3.3-1

Is the NRC considering deleting the10 CFR 50.55a requirement to perform a 10-year program update? Such a deletion wouldallow the IST plan to change as needed ratherthan "dump all new procedures on theoperators" once every ten years.

Response 3.3-1

The NRC is considering a change to the 10-year update requirement which will require achange to the regulations.

Comment 3.3-2

If a relief request was recently approved bythe NRC after GL 89-04 was issued, would itagain need to be approved when a new ten-year update is being implemented if the

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request implemented during the interim period from

a. meets the guidelines of GL 89-04 and evaluation (see Section 6). Other alternativesNUREG 1482? proposed may not be implemented until

b. meets the intent of GL 89-04 andNUREG 1482 with some exceptions? Comment 3.3-4

c. gives alternative testing technique?

d. seeks exemptions from certain Coderequirements?

Response 3.3-2

a. Further-approval is not required. Certain percent to ISI as is the case with the generaldocumentation requirements apply.. section (IWA) of ASME Section XI of the

b. NRC approval is required.

c. NRC approval is required unless thealternative meets "other test methods"stated in the Code.

d. NRC approval is required.

Comment 3.3-3

Section 10 CFR 50.55a does not give guidance possible to use these as guidance where noon when updated programs should be previous guidance exists.submitted. What is an acceptable periodbefore the start of the next interval? Comment 3.3-5

Response 3.3-3

Common practice is to submit a revised the satisfaction of the Commission" not laterprogram within 6 to 9 months before the than 12 months after the expiration of anbeginning of the interval. Some licensees interval. This appears to say that Commissionsubmit the programs on the day the interval approval is required to be obtained within 12begins. The regulations require months of the end of an interval. This isimplementation at the beginning of the beyond the control of licensees and does notinterval. Relief requests due to state when relief requests are required to beimpracticalities and alternatives approved in submitted. Revision to clarify this issueaccord with GL 89-04 or GL 89-04, should be made. A submittal requirement forSupplement 1 (NUREG-1482), may be some period before the interval should be

submittal to receipt of an NRC safety

approved by NRC.

Is there any way in which a plant nowsubmitting a 10-year interval updated ISTprogram can use the ASME OM Code? TheASME OM Code appears to be superior to theASME B&PV Code for IST because thegeneral section (ISTA) of the OM Codeapplies specifically to IST rather than 90

B&PV Code.

Response 3.3-4

IST programs may not be developed using theOM Code until it is endorsed in10 CFR 50.55a by rulemaking, though therequirements of the 1990 Edition of the OMCode are the same as OM-6 and OM-10 fortesting pumps and valves. If there are specificprovisions in ISTA that address IST, it may be

Paragraph (f)(5)(iv) of 10 CFR 50.55a statesthat relief requests must be "demonstrated to

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considered to allow time for NRC review and Comment 3.3.1-2disposition.

Response 3.3-5

Section 3.3 and Section 6.3 have been revised request approval of the extension. The reasonto include a recommendation that the relief for requesting an extension for up to one yearrequests be submitted before the interval start is not specified in the regulations or the ASMEdate. Code. Additionally, neither the ASME Code

Section 3.3.1, “Extension of Interval” approval, or even notification to the NRC, for

Comment 3.3.1-1

Section 3.3.1 gives an example of a licenseeextending an interval from December 14,1994, to September 16, 1995, in accordancewith the Code. Since the interval wasincreased by 9 months, we assume that thesubsequent interval must start betweenSeptember 16, 2004 (i.e., September 16, 2005minus 12 months) and December 16, 2005(i.e., September 16, 2005 plus 3 months). Isthis correct?

Response 3.3.1-1

Yes. The ASME Code allows intervals to beextended or decreased up to one yearcumulative and also allows intervals to beextended for outages greater than 6 months. In response to an inquiry (ASME Section XIFile Number IN93-002), the ASME Boiler andPressure Vessel Committee stated that SectionXI, IWA-2430(d), allows the inspectioninterval to be extended or decreased for Can guidance be given for licensees who wishreasons other than to enable an inspection to to use the same Code edition for multiplecoincide with a plant outage. This would units, but do not wish to place the units onapply to IST intervals as well. In concurrent intervals?Interpretation XI-1-86-54, the committeestated that the 1-year extension need not be Response 3.3.2-2applied only during the last one-third of theinterval and that the extensions may beapplied serially for both out-of-service andplant outage conditions.

The first paragraph of Section 3.3.1 states thatintervals may be extended only because of anextended outage and that the licensee must

nor 10 CFR 50.55a requires a request for

an interval extension of up to one year.

Response 3.3.1-2

The discussion has been changed to removethe issue of requesting approval of anextension. Only an extension that exceeds theone year allowed by the Code need beapproved by the NRC. An inquirer recentlyasked whether Section XI, IWA-2430(d)allows the inspection interval to be extendedor decreased for reasons other than to enablean inspection to coincide with a plant outage. The Section XI Committee respondedaffirmatively (ASME Section XI IN93-002). Notifying the NRC of the extension is acourtesy, rather than a requirement, to assistthe staff in planning reviews and inmaintaining a list of the interval dates.

Section 3.3.2, “Concurrent Intervals”

Comment 3.3.2-1

The guidance for the first situation describedin the recommendation and in the examplewould result in multiple updates over the 120-month interval.

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Comment 3.3.2-2 20 months. In 1976, NRC issued licensees

Is a relief request necessary if concurrentdates are desired for plants with differentcommercial operating dates if the utility doesnot want to update the IST programs for bothunits on each plant with a 120-monthanniversary.

Response 3.3.2-2

The regulations require a request for analternative.

Comment 3.3.2-3

It is unlikely that any licensee would use suchan interval schedule for concurrent intervalssince the schedule increases the total numberof program updates required for each unit.

Response 3.3.2-3

Though an interval schedule for concurrentintervals is unlikely, changes in code editionsmay make it beneficial for a licensee to revisethe programs more often than required.

Section 3.3.3, “Implementation of UpdatedPrograms”

Comment 3.3.3-1

Does this section imply that any new reliefrequests for a program updated for newintervals can be implemented without priorNRC review or approval for the first 12months of the interval?

Response 3.3.3-1

When the rule was issued, the interval (period)for updating inservice inspection (ISI)programs was 40 months and the interval forupdating inservice testing (IST) programs was

guidance in which it recognized that reliefrequests would be submitted for review andapproval and suggested that licensees submitthe programs as early as possible before thebeginning of a new interval. The revisedprograms were to comply with therequirements of editions of the code andaddenda in effect no more than 6 monthsbefore the start of each 40-month or 20-monthperiod. However, the ISI intervals establishedfor examination schedules in accordance withSection XI were based on 120 months. Therule included the provision for demonstrating

to the satisfaction of the Commissionnot later than 12 months after theexpiration of the initial 120-monthperiod of operation from the start offacility commercial operation andeach subsequent 120-month periodof operation during which theexamination or test is determined tobe impractical.

The 12-month provision remained when therule was changed November 1979 to increasethe length of the intervals for both ISI and ISTprograms to 120 months. The phrase "to thesatisfaction of the Commission" implies thatthe relief request has been submitted and hasbeen found acceptable by the NRC staff. Future rule changes may clarify theappropriate time period for submitting andimplementing relief requests for updatedprograms. Refer to Sections 6 and 7 for morediscussion on relief requests.

Comment 3.3.3-2

Explain the significance and any requirementfor complying with the sections of the codesthat refer to new reference values whenimplementing a "new" program to the currentversion of the Code (IWP-3112 of Section XI,

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Paragraph 4.5 of OM-6, and Paragraph 3.5 ofResponse 3.3.3-4OM-10).

Response 3.3.3-2

New reference values would be necessary for state that the licensee must demonstrate to theparameters not currently measured. New satisfaction of the Commission not later than"reference values" for currently monitored 12 months after each 120-month intervalparameters may not be necessary if previous where a pump or valve test requirement in thereference values were acceptable. The code code or addenda is impractical and is notdoes not require new reference values to be included in the revised inservice test program. established because a later edition is used. See Section 6 for guidance on impractical

Comment 3.3.3-3

When a licensee updates a program at the120-month interval, is the program to be Our next 10-year interval begins in Novemberimplemented before a safety evaluation is 1995. We would like to begin graduallyreceived? implementing the IST procedure revisions to

Response 3.3.3-3 rather than waiting and using all new

The regulations require the updated programto be implemented for inservice testing doneafter the interval start date. Although thelicensee may need time to fully implement theupdated program, the regulations require thatthe new program be implemented even in theperiod before the NRC issuees a safety Several licensees have asked this question.evaluation for the relief requests submitted for The licensee can use Code Cases N-465 andthe new interval program. The staff gives N-473; however, the best action is to informguidance for implementing relief requests the NRC that you are beginning yourbefore NRC approval elsewhere in NUREG- implementation early to have the revised1482. procedures in place by the interval start date,

Comment 3.3.3-4 will be submitting your program (including any

If the regulations do not allow a licensee tocontinue with the previous program 120-month program until the NRC has reviewedthe relief requests for the new interval, howcan relief requests be submitted within 12 and Component Subassemblies”months following the new interval start date?

The regulations require a program to beupdated to the later edition of the ASME Codeeach 120-month interval. The regulations

code requirements.

Comment 3.3.3-5

incorporate the new edition and addenda,

procedures on one date. What is theregulatory process to accomplish such animplementation (i.e., relief request, code caseN-465, N-473, etc.)?

Response 3.3.3-5

or before testing during the new interval, and

relief requests) by a certain date. NUREG-1482 includes other guidance on implementingalternative requirements.

Section 3.4, “Skid-Mounted Components

Comment 3.4-1

When are the OM codes and standardsexpected to address the scope of skid-

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mounted components and component safety signal.subassemblies to be included in IST programs? Will the code address skid-mounted Comment 3.5-2components for major components beyondthose listed in the first subparagraph ofSection 3.4?

Response 3.4-1

In the June 1994 OM Committee meetings,committees at various levels were consideringproposals for both skid-mounted pumps andvalves. It is expected that the publishedposition will be included in the 1995 Addendato the OM Code. The scope addressescomponents mounted on the skid and thosenot mounted on the skid but functioning muchthe same as skid-mounted components (e.g.,check valves in the service water system thatsupply cooling water to a pump) where testingthe major component can be consideredadequate to test the function of the pumps orvalves.

Section 3.5, “Testing in the As-FoundCondition”

Comment 3.5-1 means?

In the past, several licensee have been cited Response 3.5-3for Code violation for pre-exercising valvesbefore taking stroke time measurements. Does this section imply that these citationswere invalid and such pre-exercising isacceptable, although not necessarilycondoned?Response 3.5-1

It is beyond the scope of this document to maintenance could have affected the valve'sevaluate previous violations. While the Code performance. Similarly, the "as-found" testingdoes not appear to prohibit pre-exercising of recommendation applies to pumps as well. valves for stroke time measurements, testing Most inservice testing is performed in ain the as-found condition gives a better manner that represents the condition of aindication of the ability of a valve to operate standby component if it were actuated in thein the event it is actuated in response to a event of an accident. The recommendation

Does Appendix J require the licensee to leaktest containment isolation valves in the as-found condition?

Response 3.5-2

Paragraph III.C.1 of Appendix J to10 CFR Part 50, for example, states that"Each valve to be tested shall be closed bynormal operation and without any preliminaryexercising or adjustments (e.g., no tighteningof valve after closure by valve motor)." NUREG-1482 does not establish policy forAppendix J testing.

Comment 3.5-3

What is meant by "as-found" condition? Allreferences in the report are to stroking bynormal means. What if a valve is scheduledfor maintenance? Is an "as-found" test onethat is done before the maintenance or afterthe maintenance with stroking by normal

The "as-found" condition is the condition of avalve without pre-stroking or maintenance. Section XI does not require stroke-time testingor check valve stroking before maintenance;however, degradation mechanisms may not befound if no "as-found" testing is performed. Post-maintenance testing is required when the

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was for developing the test implementing Comment T3.1-2procedures and doing the tests at regularfrequencies. It was not meant to imply thatinservice testing be done before maintenance. If the condition of a component must beassessed, testing before performingmaintenance may be performed. Post-maintenance testing is only one part ofinservice testing.

Table 3.1, “Required tests and testfrequencies for pumps and valves”

Comment T3.1-1 3420, with certain provisions for record

In the frequency column for fail-safeactuators, the frequency is given as only onceevery 3 months. The Code allows for theextension of the fail-safe tests as it does forvalve exercise tests. Refer to IWV-3415 andOM-10, Paragraph 4.2.1.1.

Response T3.1-1

Change made as noted.

There appears to be an omission that leak testrequirements may be satisfied when theoperation in the course of plant operationwould satisfy the exercising requirements ofthe code.

Response T3.1-2

The allowance for demonstrating the leak-tightfunction during the course of operation istreated as an exception to the scope of IWV-

requirements (Paragraph 4.2.2.1 of OM-10). The test frequency for valves not subject tothe exception continues to be once every 2years (see IWV-3421 or Paragraph 4.2.2.3(a)of OM-10).

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COMMENTS ON SECTION 4,“SUPPLEMENTAL GUIDANCE

ON INSERVICE TESTING OF VALVES”

Section 4.1, “Check Valves” auxiliary device that maintains the disc in an

Comment 4.1-1

A normally open check valve is alsoconsidered an active valve and should beincluded in the IST program even if IWV-3414applies.

Response 4.1-1

IWV-3414 discusses valves in regular use andstates that valves that operate in the course ofplant operation at a frequency that wouldsatisfy the exercising requirements need notbe additionally exercised if the observationsotherwise required for testing are made andanalyzed during such operation, and arerecorded in the plant record at intervals nogreater than specified in IWV-3411. Even ifvalves are "exercised" in accordance withIWV-3414, they need to be included in thevalve list in the IST program, and the record(e.g., plant log, test procedure) needs to statethat the test requirements are met.

Comment 4.1-2

What constitutes a "blocked" check valve? Test Connections”What is meant by "positively held in place"?

Response 4.1-2

A check valve is blocked if in a system thathas flow blocked by a flange closure in theline, a locked closed valve other than a checkvalve, or some other means of precluding flowthrough the system. A valve that is "positivelyheld in place" has an operator or other

open or closed position. A stop check valve isan example.

Comment 4.1-3

Is it permissible to establish groups of checkvalves for disassembly and inspection wherethe population is drawn from multiple units oflike design and construction?

Response 4.1-3

It is acceptable to group valves from multipleunits if two units are "identical," if the unitswill be subjected to the same serviceconditions, and if the valves otherwise meetthe grouping criteria. If a generic problem isfound while disassembling and inspectingvalves during a refueling outage on one unit,all valves in the group in that unit must beinspected during the refueling outage, and thevalves in the group in the other unit must beinspected at the next refueling outage for thatunit.

Section 4.1.1, “Closure Verification forSeries Check Valves without Intermediate

Comment 4.1.1-1

Criterion 14 does not mention two valves forthe reactor coolant pressure boundary.

Response 4.1.1-1

Though most plants were licensed with twovalves at each reactor coolant pressure

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boundary, the two has been deleted from thesentence.

Comment 4.1.1-2

In the guidance for testing two check valves inseries, it states that both valves must bedeclared inoperable and be repaired orreplaced before they are returned to service. The guidance should state that only theaffected valve or valves be repaired orreplaced and not imply that it is mandatory torepair or replace both valves.

Response 4.1.1-2

The recommendation has been modified tostate that corrective actions for both valves, asnecessary, are to be taken. The basis for thevalves being tested in series includes anassumption that the condition of the individualvalves cannot be ascertained. If the conditionof each valve can be determined individually,the recommendation does not apply. However, a condition may be observableexternally, or special tests may be available toindicate the affected valve. The change madeto the recommendation addresses the concernsof the comment, as "corrective actions" coversmore that "repair" or "replacement." The OMCommittee is developing Code requirementsto address such conditions.

Section 4.1.2, “Exercising Check ValvesWith Flow and Nonintrusive Techniques”

Comment 4.1.2-1

Is the relief for an extension of the testfrequency mentioned in this section forextension beyond the sample testing matrixgiven?

Response 4.1.2-1

The sentence has been modified to clarifywhen relief is required.

Comment 4.1.2-2

Is it permissible to include groups of valves fornonintrusive testing from a population ofgreater than four valves if there is acommensurate increase in the testingfrequency?

Response 4.1.2-2

The group size of four was selected becausemost plants would not have more than fourvalves that have identical service (e.g., fouraccumulator discharge check valves, fourinjection loop valves). Groups of valvestested according to the guidance in Section4.1.2 are valves of the same design,manufacturer, service, and service conditions. If a group of more than four valves meetsthese criteria, the group may be appropriatefor the testing described in Section 4.1.2,because each valve is tested and the test isverified regularly on at least one of the group.

Comment 4.1.2-3

Is audible indication of check valve "slam"qualify an acceptable nonintrusive testingtechnique for verifying check valve closure?

Response 4.1.2-3

The OM Committee is better suited todetermine whether this method would meetthe "other positive means" allowed in theCode; however, NRC would expect that ifsuch a method was used, it would berepeatable, could be distinguished from othernoise contributors, and would be done inaccordance with the applicable qualitycontrols and assurance.

Comment 4.1.2-4

The NRC recommendation stated that theflow rate must be sufficient to stroke the valveto the backstop. This statement could be

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interpreted to mean that nonintrusive Response 4.1.2-4examination results are unacceptable unlessthe valve makes an acoustic impact from thedisc striking against the backstop. Most checkvalves at our facility are sized toaccommodate large flows that may beexpected with various accident conditions. Many valves are larger than needed to passthe design flow and are thus not affected bythe small drop in pressure across the valve. As a result, in many valves the disc will notimpact the backstop even though full designflow is passed. Our check valve nonintrusiveexamination (NIE) equipment has twotechnologies: acoustics and either externalmagnetics or ultrasonics.

The NUREG-series report seems to be basedon acoustics only. This limits the usefulnessof the plant's NIE system since credit for UTor magnetic data cannot be taken. Forexample, credit cannot be taken for the NIEtest if full design flow is verified through avalve but the acoustic sensor does not detectan impact. This appears to be true even ifultrasonic testing (UT) data shows the valvedisc to be 90-percent open. Our plan is to usetwo technologies to obtain NIE data for theIST program. We envision a greater role forthe UT (or magnetic) data than the NUREG-series guidance seems to allow.

We suggest that appropriate NIE acceptancecriteria can be developed once full design flowis verified. In our example, acceptancecriteria would be a 90-percent open disc(verified by UT) plus or minus a tolerance. Inother cases, the acceptance criteria may be anacoustic impact detected at the backstop. However, the NUREG-series report seems toset a generic acceptance criterion of backstopimpact with which we do not agree.

The description in this section was not meantto limit the use of nonintrusive techniques toacoustics. The statement suggesting that theflow rate must be sufficient to stroke the valveto the backstop was incorrect and has beendeleted. An acceptable test method mustdemonstrate that a check valve disc opens tothe position necessary to fulfill its safetyfunction, which may not be full-open to thebackstop.

Comment 4.1.2-5

Please clarify the requirements for checkvalve full flow testing. Can full-strokeexercising be verified by passing maximumrequired accident flow through the valve? Isnonintrusive testing acceptable to verify fullstroke?

Response 4.1.2-5

Full-stroke exercising of a check valve can beverified by passing full accident flow(measured) through the valve or by usingnonintrusive techniques that verify thecapability of the valve to stroke to the positionnecessary for it to fulfill its safety function. Ifthat position is known, as discussed inComment 4.1.2-4 above, or if the valvestrokes fully open, nonintrusive techniquescan be used to verify the stroke. Section 4.1.2describes an acceptable method for testing agroup of identical valves located in differenttrains of the same system where it has beendemonstrated that nonintrusive methods canverify that the valves stroke to the positionnecessary to fulfill their safety function. Inthe example, the same reduced flow is usedfor subsequent testing, with direct flowmeasurement, or without direct flowmeasurements but with procedurally-controlled system alignment and monitoring of

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a system characteristic or parameter to Comment 4.1.2-7establish the same reduced flow. The methodmust be repeatable.

Comment 4.1.2-6

The question is related to using a samplingprogram when converting from an intrusive to Response 4.1.2-7a nonintrusive testing program for a group offour identical check valves. After the first testof all four valves of the group using thenonintrusive method, is a relief request thenrequired to go to a rotating sampling testprogram in accordance with Section 4.1.2? We understand that a relief request is notrequired to change from an intrusive methodto a nonintrusive method.

Response 4.1.2-6

If all the valves in the group are flow tested,the staff would accept a "sampling" of onevalve each refueling outage to verify that thetest method is repeatable for implementingnonintrusive test methods. If the "sampling"reveals problems with repeatability of the testconditions, or other problems that might affectthe testing of the other valves, thenonintrusive techniques must be used for theother valves during the same outage. Relief isnot required because the method meets the"other positive means" of the Code. A testdeferral justification is not necessary whenextending the test interval in accord with OM-10. If a sampling program does not include aflow test of each valve on a regular basis,relief would be necessary. The OM-22working group on check valves changed theOM Code to allow a similar sampling fordisassembly and inspection as discussed inPosition 2 of GL 89-04. OM-22 is alsoconsidering a sampling plan with broaderapplications.

Please discuss in detail the process forqualifying nonintrusive testing as analternative method to check valve full flowtesting.

Position 1 of GL 89-04 gives general guidancefor qualifying such a method. Furtherinformation is available through the OMworking group for check valves and theNuclear Industry Check (NIC) valve group.

Comment 4.1.2-8

Once nonintrusive techniques have beensuccessfully used to verify that a check valvedisc reached the backstop under reduced flowconditions, should not measurement of theflow through the valve be sufficient forperiodic full-flow testing if meaningful flowcriteria can be established?

Response 4.1.2-8

Measurement of the flow through the valve issufficient with periodic reverification orsampling a group of valves. The example inSection 4.1.2 is not the only acceptable meansto implement such a program for a group ofvalves. Periodically verifying single valvesmay also be acceptable as "other positivemeans." The example could apply to (1) testsin which flow can be measured but is belowdesign accident flow, and (2) tests in whichflow cannot be measured directly in the linebut is otherwise quantifiable to ensurerepeatable conditions.

Comment 4.1.2-9

Will the use of nonintrusive techniques on arotating schedule for full-flow testing requireoccasional disassembly and inspection of thecheck valves to verify the adequacy of the

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nonintrusive techniques, as has been suggestedComment 4.1.2-11by the NRC to some licensees in the past?

Response 4.1.2-9

Disassembly and inspection may be necessary for the failed train? In some cases, littleas part of the initial or periodic verification for time is available to do nonintrusive testingcertain techniques. Disassembly and with flow (e.g., safety injection checkinspection would not otherwise be necessary valve testing), and the conditions forto meet the requirements of IST. Valves may performing another flow test cannot beneed to be disassembled to confirm a duplicated without delaying startup. nonintrusive conclusion, to take correctiveactions, or to do preventive maintenance as (2) Certain flow tests used withpart of a check valve program. nonintrusive techniques impart just

Comment 4.1.2-10 make a marginally audible impact

Is measurement of C with the application ofv

meaningful flow versus differential pressurecriteria considered "other positive means" inaccordance with IWV-3522 of the Code?

Response 4.1.2-10

The NRC contracted with Oak Ridge NationalLaboratory (ORNL) to review such a testmethod used at the Fort Calhoun and BeaverValley plants. ORNL was to determine if themeasurements and reduction of the data giveadequate assurance that the accumulatordischarge check valves at both plants wouldfunction properly. ORNL found that theresults are useful if the test is performed in acontrolled manner with accurate instruments. The tests can also be verified usingnonintrusive techniques during the initialtesting. A safety evaluation was issued for theFort Calhoun test, which included the reportprepared by the ORNL staff on the results oftheir review (see NRC Letter, Docket 50-285,to OPPD, October 2, 1993).

(1) If a nonintrusive test fails to verify fulldisk movement, are disassembly andinspection acceptable corrective actions

enough energy to the disk to cause it to

against the backstop. In these cases,variations in initial conditions couldproduce inconclusive nonintrusive testresults. The only reasonable correctiveactions would be disassembly andinspection because the tests may be ofmarginal value.

Response 4.1.2-11

(1) The licensee determines the types ofcorrective action taken when a test isinconclusive or when the results indicateunacceptable functioning of the checkvalve. Disassembly and inspection maybe parts of corrective actions to ensurethe functional capability of the valve. Inresponse to Question Group 15 inAppendix A, the staff stated that a flowtest for part-stroke exercising of the valve"is expected to be performed" followingreassembly if practical.

(2) Several nonintrusive methods such asradiography, ultrasonics, and magneticscan verify disk position without requiringaudible disk-backstop impact. Themethod selected must give conclusiveresults and be repeatable for the

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application. example) is to verify that the test method andComment 4.1.2-12 test conditions remain constant.

If the flow testing proposed in Section 4.1.2must pass the maximum required accidentflow through each check valve, why would What are the accuracy requirements andnonintrusive techniques ever be required? specifications for non-intrusive testing andWhat actions are necessary if one of the diagnostic techniques? Are they as stringentvalves that is only flow tested and found to as current code requirements for instrumenthave problems? Would all of the valves in theaccuracy?group have to be tested using nonintrusivetechniques? What is the minimum required Response 4.1.2-13data to be obtained from the periodic flowtesting and what deviation from the dataobtained during the baseline test isacceptable?

Response 4.1.2-12

The test method discussed in Section 4.1.2 necessary to qualify the method forapplies to tests performed with less than an repeatability and adequate results. accident flow rate. If accident flow rate ispassed through the check valve being tested, Comment 4.1.2-14nonintrusive techniques are not necessary toestablish the functionality of the valve. Thenonintrusive techniques would be used toverify that the test at reduced flow wouldindicate adequate disk movement for full-stroke exercising the valve in accordance withthe Code. An allowable flow variation wouldbe established during the baseline testing usingthe nonintrusive techniques. If the flow rateduring future testing cannot be establishedwithin the range, the test is unacceptable andthe licensee could begin (1) nonintrusive tests to verify that full-stroke exercising is achievedeven at different flow conditions or (2)corrective actions to determine the cause ofthe failure to meet the acceptance criteria forthe test. If other valves meet the acceptancecriteria, the licensee need take correctiveaction only for the valve with a problem if it isnot the valve used for reverification bynonintrusive techniques unless the cause isdetermined to apply to the other valves aswell. The rotation of the nonintrusivetechniques over the four outages (in the

Comment 4.1.2-13

The code does not address instrumentaccuracy for testing valves. The owner hasthe responsibility to qualify the methodfollowing the steps in GL 89-04, Position 1,with particular emphasis on items 3, 4, and 6. The instruments used must accurate as

Does the use of a sampling program to fullystroke check valves constitute a change in testfrequency from that required by the code? Isdemonstration of impracticality required forthis new test frequency?

Response 4.1.2-14

When using a sampling for non-intrusivetechniques, all the valves in the group are flowtested at the same frequency, which can bedeferred in accordance with OM-10 asneeded; however, only one of the groups mustbe tested using non-intrusive techniques eachtime. Therefore, this practice does not changethe test frequency.

Comment 4.1.2-15

Section 4.1.2 clearly states that a relief requestis not required to use non-intrusive techniques. Is a relief request also not required toimplement a check valve non-intrusive

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sampling plan? Response 4.1.3-1

Response 4.1.2-15

A relief request is not required for a sampling only be tested by performing a leak test, whenplan that calls for the licensee to continue flow test equipment setup is necessary. Relieftesting all valves in the group with non- would be necessary to perform the testing at aintrusive techniques applied to one of the frequency other than as specified in the Code. group during each test. If not all the valves Entering an LCO is not, alone, sufficient basisare flow tested, the alternative must be for deferring testing, as the LCO wereevaluated by the NRC. established with testing in mind; however, if a

Comment 4.1.2-16 further justify deferring the test. Refer to

We have several check valves that weexercise by disassembly. We cannot flow testthese valves because we do not have the Testing for Valves That Can Be Tested Onlyinstrumentation or test fittings to allow testing. What would be an acceptable test plan forexercising these valves by non-intrusivetesting?

Response 4.1.2-16

Other positive means using nonintrusivemethods may be acceptable if the methods arequalified and repeatable. A method qualifiedaccording to the guidance in GL 89-04,Attachment 1, Position 1, would beacceptable.

Section 4.1.3, “Use of NonintrusiveTechniques for Check Valve Testing”

Comment 4.1.3-1

Please confirm that "test setup andperformance limitations" of backflow testingby performing a leak test is adequatejustification for deferring testing to a refuelingoutage. Could such a test be scheduled onceeach cycle instead of during a refuelingoutage? Can the tests be deferred because theplant has to enter an extended limitingcondition for operation (LCO) to do them?

It is acceptable to defer backflow testing to arefueling outage for a check valve that can

test necessitates entry into an LCO, that may

Section 3.1.2.

Section 4.2.1, “Increased Frequency of

During Cold Shutdown Outages”

Comment 4.2.1-1

The first sentence of the NRCrecommendation is not clear. It appears to saythat power-operated valves cannot be tested atpower.

Response 4.2.1-1

The sentence contained a typographical errorthat has been corrected ("it" was supposed tohave been "if"). The recommendation is forpower-operated valves that cannot be testedduring power operation of the plant.

Comment 4.2.1-2

There is no advance notice about which valvestested during cold shutdown will be in a rangefor stroke time which requires increasedtesting as specified in IWV-3417(a). Since acold shutdown justification has demonstratedthat the test can only be performed at coldshutdown, it is not practical to prepare a reliefrequest, submit the request to the NRC forevaluation, and obtain approval within 30

NUREG-1482)���

days, when the next test would be required. Comment 4.2.1-4Would it be acceptable to do an engineeringanalysis to determine the acceptability of thevalve for continued operation and do the nexttest during the next cold shutdown outage?

Response 4.2.1-2

Paragraph 4.2.1.9(c) of OM-10 allows analysisfor declaring a valve operable after testingindicates the stroke time is above the limitingvalue, or has increased above the referencevalue by a specified percentage. Thisapproach may be used to the extent that itapplies. If a valve stroke time exceeds thelimits of the safety analysis, it could not bedeclared operable until a reanalysis indicatesthe new (increased) stroke time is acceptable. The intent of Section 4.2.1 was to informlicensees that the requirements of IWV-3417for increased testing apply to valvesindependent of the exercising frequencyspecified in IWV-3412.

Comment 4.2.1-3

Can licensees that have not updated to OM-10delete monthly testing without an approvedrelief request in accord with10 CFR 50.55a(f)(4)(iv) because OM-10deletes monthly testing for valves that requirean increased stroke time?

Response 4.2.1-3

OM-10 not only deleted the monthly test, butit changed the test requirements formonitoring changes in the stroke time ofvalves. If the requirements of OM-10 areused as discussed in Section 4.2.7 of thisdocument, the monthly testing do not apply. However, the requirements of IWV-3417(a)apply if the testing is continued in accord withSubsection IWV-3400.

It is not clear that the requirements of IWV-3417(a) and (b) for corrective action ormonthly testing apply to valves with valid coldshutdown justifications.

Response 4.2.1-4

It appears that the requirements of IWV-3417are independent of the deferral of exercisingto cold shutdown outage allowed by IWV-3412. If a valve demonstrates the effects ofdegradation, it is appropriate to assess theacceptability of operating with the valve inthat condition or to repair the valve while theplant is in a cold shutdown condition.

Comment 4.2.1-5

Section 4.2.1 states, in part, that OM-10 doesnot allow for an increased test frequency. It isour understanding that while OM-10 does notspecifically state that frequency shall beincreased, neither does OM-10 prohibit anincrease in test frequency. The increase intest frequency may be selected as anadditional corrective action or as a temporarycorrective action. We interpret this section tobe applicable to those times when testingfrequency is not able to be increased due toplant conditions (i.e., plant is operating).

Response 4.2.1-5

The statement was not meant to imply thatlicensees may not take actions that exceed therequirements of OM-10 as a precautionarymeasure or temporary monitoring. Thestatement has been changed.

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Section 4.2.2, “Stroke Time Measurements also in milliseconds. Is there a conflict in thisfor Rapid-Acting Valves”

Comment 4.2.2-1

Does GL 89-04, Position 6, require individualstroke time testing of rapid-acting valves, or isa pass/fail determination based on a 2.0second criterion sufficient?

Response 4.2.2-1

GL 89-04 and OM-10 allow assigning alimiting stroke time of 2 seconds for rapid-acting valves. The stroke times for thesevalves need not be compared to previousstroke times. It is necessary to measure thestroke times only to assure that they are lessthan 2 seconds. Recording the measuredvalue would be necessary and then a pass/failcriterion could be applied easily. Comment 4.2.2-2

Two rapid-acting valves are actuated by thesame handswitch and share the same positionindicating lights. Is it permissible to stroketime both valves simultaneously if the lightsverify that both valves full stroke in twoseconds or less?

Response 4.2.2-2

The approach appears to meet the intent ofGL 89-04, Position 6, and OM-10, Paragraph4.2.1.8(e).

Comment 4.2.2-3

New technologies allow for stroke timingvalves locally as connected to the valveactuator (motor operator, air operator,solenoid operator, etc.). These techniques donot include the initiation time (signalprocessing from switch to actuation) which is

guidance and old guidance defining "switch-to-light" testing?

Response 4.2.2-3

The traditional method of stroke timingpower-operated valves was to use stopwatchesto measure the stroke time from initiation ofthe signal at the handswitch to the change inposition-indicating lights (switch to light). Thetraditional method includes signal processingtime from the switch to the valve actuator. Monitoring stroke times for valves that strokein milliseconds using the diagnostic equipmentthat measures only actual valve travel isacceptable for indicating degrading trends;however, the method does not reveal increasesthat could occur in the signal to the valve.

Most valves that would benefit from thismonitoring are rapid-acting valves. Thetraditional method would have a set limit of 2seconds, which masks any signal processingtime unless a gross change occurs. Ifmeasuring the stroke times locally needs to besupplemented by a periodic test to include thesignal processing times, a periodic 2-secondlimit test could be performed to augment theIST. The code does not specify a particularmethod, so there is no conflict in using morethan one method.

Section 4.2.3, “Measurement of ValveStroke Time”

Comment 4.2.3-1

This section indicates that when diagnosticequipment is used for measuring the valvestroke time, the additional informationobtained on the condition of the tested valvecould justify extending the test interval. Could a test interval be extended for thedisassembly and inspection of check valves?

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Response 4.2.3-1 Section 4.2.4, “Main Steam Isolation

The OM-22 working group is considering sucha possibility. Position 2 of GL 89-04 discussesextension of disassembly and inspection andthe justification necessary to extend thefrequency established for sampling a group ofvalves.

Comment 4.2.3-2

IWV-3413(b) specifies that "the stroke time ofall power-operated valves shall be measuredto the nearest second for stroke times 10 sec.or less." Paragraph 4.2.1.4(b) of OM-10 statesthat "the stroke time of all power-operatedvalves shall be measured to at least the nearestsecond." When establishing a limit of 2seconds for rapid-acting valves in compliancewith Position 6 of GL 89-04 or Paragraph4.2.1.8(e) of OM-10, is it acceptable to roundoff the measured stroke time to the nearestsecond? Can rounding off be applied whenestablishing reference values? For example ifthe reference value is measured as 3.75seconds, can this be specified as 4 seconds inthe procedures with acceptance criteria basedon 4 seconds and then rounded off? Example(in seconds):

Measured reference value: 3.75Alert Low: 2.81Alert High: 4.69

Rounding off to nearest second:

Measured reference value: 4 Alert Low: 3 Alert High: 5

Response 4.2.3-2

Basing measurements and reference values onat least the nearest second meets the Coderequirements.

Valves”

Comment 4.2.4-1

The word "fraction" has been changed to"friction."

Response 4.2.4-1

Change made as noted.

Comment 4.2.4-2

The inadequacy discussed in the referencedinformation notice (IN 85-84) pertained tofail-safe testing of the MSIVs at a couple ofutilities, including Turkey Point. This issuewas resolved at Turkey Point by reviewing thedesign of the actuator and eliminating the fail-safe classification in the IST program. Thestaff recommended in this section thatlicensees review their fail-safe testing. Perhaps this recommendation should point outthis fact and request other licensees to reviewtheir fail-safe designations.

Response 4.2.4-2

If a valve does not have a fail-safe function,the Code requirements for fail-safe testing donot apply. A change in the safety function ofa valve is subject to the requirements of10 CFR 50.59.

Section 4.2.5, “Verification of RemotePosition Indication for Valves by MethodsOther Than Direct Observation”

Comment 4.2.5-1

Would the use of nonintrusive testing methodsalso be acceptable?

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Response 4.2.5-1 Response 4.2.6-1

If nonintrusive methods can be used to verify Although the Code does not restrictthe position of the valve obturator, it would be verification of position indication to only thesimilar to using an "other method" such as safety position of a valve, the NRC has foundleak testing or observing flow shutoff. during inspections that some plants verifyNonintrusive techniques has been added as an valve position indication for only the safetyexample of other methods that are not directly position of the valve. A portion of theobservable. recommendation has been removed so as not

Comment 4.2.5-2

When verifying the position indication ofvalves, direct observation of the valve stem of The NUREG-series report recommends thatcertain types of valves such as wedge disk the position indication for both positions of agate valves may not provide assurance that the valve be verified, even if the valve has onlyvalve disk is attached to the stem. In these one safety position. The ASME Code does notcases, the NRC should recommend that other require this verification if the valve has onlypositive means be used to supplement the one safety position. The staff recommendslocal observation. that the licensee periodically verify the remote

Response 4.2.5-2 operators for use in an accident condition, or

Paragraph 4.1 of OM-10 includes such arequirement, where practicable, to supplementlocal observation by other indications such asuse of flow meters or other suitableinstruments to verify obturator position. Astatement has been added to Section 4.2.5,though the recommendations were originallyintended to address cases where localobservation is not possible.

Section 4.2.6, “Requirements for Verifying therefore, cannot be enforced as such. Position Indication”

Comment 4.2.6-1

The Code requirement for position indicationverification should be applied to any positionindicators associated with a valve. It wasnever the intent of the Code to restrictverification of position indication to only thesafety position of a valve.

to conflict with the code requirements.

Comment 4.2.6-2

locations that include position indication for

in cycling the valve to the safe position. Thisrecommendation exceeds requirementsspecifically addressed by the OM Code andclarified by ASME Code Interpretation XI-1-89-10. This recommendation would imposeadditional testing requirements that have notbeen reviewed for backfit considerations.

Response 4.2.6-2

The recommendation is not a requirement, and

Although it is thus not a backfit, a portion ofthe recommendation has been deleted becauseit could be misinterpreted. The NRC believesit is good practice to verify any positionindications that an operator may rely on in anemergency situation. NRC would not takeenforcement action if the recommendation isnot followed. However, it may be necessary,as part of an integrated program foremergency operating procedures or AppendixR safe shutdown, to periodically verify

NUREG-1482)���

position indication for valves that are also in with stroke time 10 seconds or less and givesthe scope of IST. These verifications may be no guidance on how such testing is to becombined for the IST valves. implemented. Because the requirements have

Section 4.2.7, “Stroke Time Measurements of the OM Committee, it is appropriate toUsing Reference Values”

Comment 4.2.7-1

Position 6 of Generic Letter 89-04 states it isacceptable to measure changes in stroke timefrom a reference value as opposed to theprevious test. If the licensee's IST program isunder the rules of ASME Section XI, but thelicensee elects to use the reference valuemethod as opposed to the previous stroke,why must the licensee also follow OM-10,Paragraphs 4.2.1.8, 3.1, 3.2, 3.6, 4.2.1.1,4.2.1.9, and 5? If the reference value methodis as good as or better than using the previoustest for measuring changes in stroke time,what is the technical reason for it beingunacceptable to use ASME Section XIacceptance criteria with the reference valuemethod? The NUREG-series report should berevised to allow plants that have not updatedto OM-10 and that have developed proceduresin accordance with GL 89-04 for usingreference values to continue in accordancewith the procedures.

Response 4.2.7-1

The editions of Section XI before the 1989Edition did not address the use of referencevalues. The acceptance criteria in Section XIare based on changes from the previous test. Therefore, the requirements in OM-10 forusing reference values for the stroke time ofpower-operated valves are the only onesapproved by the NRC (except for specificplants). GL 89-04, Position 6, discussesalternatives for rapid-acting valves and statesthat measuring changes in stroke times from areference value is an acceptable alternative tothe requirements of IWV-3417(a); however,the statement in Position 6 applies to valves

been developed through the consensus process

allow the use of OM-10 for the monitoring ofstroke times for power-operated valves. Nofurhter action is needed if NRC has approvedrelief for a program a licensee alreadydeveloped for monitoring power-operatedvalves that is not in accordance with OM-10. The requirements in OM-10 differ onlyslightly for a licensee using reference valuesincorporating the 25-percent increase for thecorrective action limit for valves with stroketimes greater than 10 seconds andincorporating the 50-percent increase forvalves with stroke times of 10 seconds or less.

NUREG-1482 does not change any previousguidance on the methodology because GL 89-04 gave no specific guidance. Rather, thereport only refers a licensee to therequirements in OM-10 developed to allow theuse of reference values. An existing programestablished to an edition of the Code beforethe 1989 Edition would not have to bechanged if the program has been submitted toNRC in response to GL 89-04. However, theprogram would have to be revised if itconflicts with the guidance of GL 89-04 or ifan NRC safety evaluation has basedacceptance on OM-10 requirements. Therequirements of OM-10 may be used for thetest methodology. Other licensees may needto assess whether a relief request is needed toensure their methodology is acceptable. Licensees may review the use of OM-10 foreliminating the need for increased testing,whether using reference values or not,especially for valves not tested during poweroperations. Licensees may propose specificalternative requirements

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Comment 4.2.7-2 comparing historic stroke timing data. It is

It is unclear if relief is required to use stroketime reference values. The recommendationsection states that reference values can beused in accordance with the later approvedcodes. The basis section and referenced reliefrequest seems to indicate relief is required. Section 4.2.7 does not discuss a method forAlso, is "Figure 4.2" now Appendix C, page establishing reference values. The CodeC-11? requirements are specified in Paragraph 3.3 of

Response 4.2.7-2 measured value be the reference value.

When using editions of Section XI, IWV,before the 1989 Edition, relief was required touse reference values because the method wasnot in accordance with the Code. Some plantsused reference values and documented themethod as meeting Position 6 of GL 89-04. However, Position 6 "granted" generic relieffor this alternative only for valves with stroketime of 10 seconds or greater (see Response to Section 4.2.7 seems to remove the option toQuestion 40 in Appendix A). Section 4.2.7 establish a limiting value which is a deviationapproves of the licensee using the from a reference value based upon valve size,requirements of OM-10 for establishing valve type, and actuator type as specified instroke-time acceptance criteria for these and GL 89-04, and seems to say that OM-10 limitsother valves in plants not using OM-10. Any are the only acceptable limits. What is themethod not in conformance with OM-10 intent?would require relief. Response 4.2.7-4

The referenced figure is Appendix C, page C-11.

Comment 4.2.7-3

We expect there will be times, when following discuss details of using reference values. "lube and tune" type maintenance, when the Licensees have typically made proposals forpost-maintenance stroke test used for implementing such an alternative that haveestablishing the reference value will be too been evaluated by the NRC. Guidance in GLfast, resulting in an overly restrictive reference 89-04, Position 5, for establishing "limiting"range. This will result in needless values of stroke times remains acceptablenonconformance reports because of "out-of- even when using OM-10. Paragraph 4.2.1.4range" strokes on subsequent tests. This is of OM-10 specifies that the limiting value(s)particularly true of air-operated valves that of full-stroke time be specified by the owner. have a large standard deviation when Perhaps you are confusing the use of

recommended that the first measured stroketime following maintenance or design changeactivities not be the reference value.

Response 4.2.7-3

OM-10, which does not require that the first

Licensees establish reference values for valvestroke times in various ways such as byaveraging a specific number of testsperformed following the maintenance activity,averaging several IST tests, or using the firsttest following maintenance.

Comment 4.2.7-4

The recommendation allows the use of OM-10requirements in lieu of IWV-3413 for power-operated valves. The discussion in Section4.2.7 refers to the use of reference values. Guidance in GL 89-04, Position 6, does not

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reference values, and the recommendation to OM-10 does give specific requirements for theuse the multipliers specified in Paragraph use of reference values and acceptance4.2.1.8 of OM-10, with establishing limiting criteria. Licensees may continue to use IWV-values. These are two separate issues, though 3413, if applicable for the current interval, orboth pertain to establishing the values at use OM-10 and Section 4.2.7 of the NUREG-which corrective action is required. series report. When alternatives to the

Comment 4.2.7-5 appropriate by a licensee, an alternative can

When using OM-10 for monitoring stroketimes of valves, can separate reference valuesbe established for the same valve to accountfor different train-related fail safeperformance characteristics?

Response 4.2.7-5

Paragraph 3.5 of OM-10 gives therequirements for establishing additionalreference values and may allow differentreference values for a single valve if there isjustification. For example, test conditionscould affect the reference stroke timedepending on pressure or flow in the system. It may be necessary to have more than onetest condition, such as dynamic and static,which would necessitate different referencevalues. The licensee should consider suchdifferences when monitoring the stroke time.

Comment 4.2.7-6 References to Paragraphs 3.1, 3.2, and 3.6

The recommendation implies that licenseesmust use OM-10 if they use reference valuesto measure changes in stroke time. This is notthe case. Licensees may continue to useIWV-3413 along with the guidance originallyprovided in GL 89-04.

Response 4.2.7-6

IWV-3413 requirements are not based onusing reference values. GL 89-04 discussesthe use of reference values in Position 6 forvalves with stroke times of less than 10 When evaluating certain nonintrusive testingseconds. It does not, however, give guidance methods for pilot-operated solenoid valves,on the use of reference values for stroke time. the licensee should be cautioned to ensure that

requirements of OM-10 are deemed

be proposed and will be reviewed andevaluated individually. NRC incorporatedOM-10 into the regulations and thusrecommends the guidance therein onreference values for stroke timing of valves.

This guidance does not preclude a licenseefrom using IWV-3413 and a conservativebaseline value for comparison to future tests.

Comment 4.2.7-7

The following paragraphs from OM-10 do notstate requirements related to the methodologyof measuring stroke time from a referencevalue as opposed to the previous test, andshould be deleted from the list of relatedrequirements: Paragraphs 3.1, 3.2, 3.6, and4.2.1.1.

Response 4.2.7-7

have been deleted because they are notspecific to monitoring stroke times of power-operated valves. However, 4.2.1.1 through4.2.1.9 remain as related requirementsbecause they constitute the alternative toparagraphs IWV-3410 through IWV-3417. Paragraph 4.2.1.1 specifies the frequency oftesting.

Section 4.2.8, “Solenoid-Operated Valves”

Comment 4.2.8-1

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the technique evaluates the disc movement portion of a system and the test of the majorand not merely the movement of the plug or component is the IST of the "skid-mounted"pilot valve. component, it is recommended that the

Response 4.2.8-1 program. If the determination is not

A caution has been added to the basis for therecommendation.

Section 4.2.9, “Control Valves with a Fail-Safe Safety Function”

Comment 4.2.9-1

If a valve must control (regulate) to performits safety function, why should the appropriatetesting be determined by the existence of afail-safe position? Even if a valve does nothave a safe position, this does not diminish theimportance of its safety function to control.

Response 4.2.9-1

The control function is exempted from thecode requirements; however, the fail-safefunction is not. The OM Committee discussedan inquiry at the OM meeting in December1994 and may issue clarifications.

Comment 4.2.9-2

Is it the intent to require additional full stroke-time tests of control valves such as turbinecontrol valves when the operability isdetermined adequately during the componenttest? This question also applies to skid-mounted components.

Response 4.2.9-2

Section 3.4 covers skid-mounted components. Valves in this classification may requiretesting, but a valve in the non-code portion ofa system is outside the scope of Section50.55a. If a valve is within the code-class

determination be documented in the IST

documented, it may not be clear that thedetermination was made.

Comment 4.2.9-3

Section 4.2.9 states that the motor-operatedvalve (MOV) testing program established inaccordance with GL 89-10 and performed ona periodic schedule is an acceptablealternative, along with a periodic valve stroke,for control valves that cannot be stroke-timetesting by traditional methods. Would the GL89-10 periodic testing program be anacceptable alternative for other motor-operated valves with appropriate justification?

Response 4.2.9-4

The alternative discussed in Section 4.2.9 hasbeen found acceptable in consideration ofdesign limitations that made the testingrequired by the code impractical. The NRCmay approve an alternative such as an GL 89-10 program if the licensee can show anequivalent level of quality and safety. TheOM Code Committee is developing testingrequirements for MOVs that could replacecurrent testing requirements.

Section 4.3, “Safety and Relief Valves”

Comment 4.3-1

What is the appropriate test frequency for aClass 2 or 3 safety or relief valve that cannotbe grouped with other valves based on valvetype and manufacturer? Should the valve beset pressure tested once every 10 years oronce every 48 months?

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Response 4.3-1 Response 4.3.1-2

Note (1) of Table 2 in OM-1 appears to The revised scope in Part 1 of the OM Coderequire set pressure testing of a single valve more clearly states that the requirements areevery 48 months if it is in a group of one. The applicable to safety and relief valves requiredquestion was discussed by OM-1 working to protect systems or portions of systems thatgroup members in the June 1994 meeting. perform a specific function in shutting down aThough the requirements were written with reactor to the safe shutdown condition, inlarger groups of valves in mind, the committee maintaining the safe shutdown condition, or indetermined that any fractions of valves mitigating the consequences of an accident. calculated to comply with the table would be The NRC has asked the Working Group forrounded up to the next higher number. Part 1 to assess and clarify the scope. SeeTherefore, a single Class 2 or 3 safety valve Thomas F. Hoyle's paper, "Introduction towould be tested at least every 48 months. OM-10, Technical Differences Between IWV

Section 4.3.1, “Scope” 1994 Addenda to Part 1 of the OM Code for

Comment 4.3.1-1

Overpressure protection relief valves that donot perform safety-related functions should beincluded in the preventive maintenanceprogram of the plant.Response 4.3.1-1

Although the proposed alternative to includethese valves in the preventive maintenanceprogram rather than in the IST program hasmerit, approval of the alternative would berequired because the proposal does not meetthe requirements of the 1989 Edition of theCode.

Comment 4.3.1-2

The NUREG-series report should provideguidance on whether the scope defined inIWV-1100 of the 1986 Edition of Section XIand OM-1 applies to small sentinel valvesinstalled for thermal relief of service waterheat exchangers in the uncommon event theyare isolated from service. The issue ofwhether the 1986 Edition of ASME, SectionXI, expands the scope of pressure relief underIWV-1100 is debatable and clearly does notprovide an increase in safety.

and OM-10," NUREG/CP-0111, and OMc-

further guidance.

Comment 4.3.1-3

Are plants currently subject to the 1986Edition or 1989 Edition of Section XI the onlyplants that must include safety and reliefdevices that give only overpressure protectionin the IST program? In these plants, thedevices do not perform a specific function inshutting down a reactor to the safe shutdowncondition, in maintaining the safe shutdowncondition, or in mitigating the consequences ofan accident.

Response 4.3.1-3

Previous editions of ASME Section XIdescribed the scope as those Class 1, 2, and 3valves (and their actuating and position-indicating systems) in light-water coolednuclear power plants, that are required toperform a specific function in shutting down areactor to the cold shutdown condition or inmitigating the consequences of an accident. Therefore, if the safety or relief devices didnot perform a function in shutting down areactor to the cold shutdown condition or inmitigating an accident, they would not besubject to the requirements of ASME SectionXI, Subsection IWV.

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Comment 4.3.1-4 motion during the course o f accomplishing a

Does OM-1 require testing of a relief valveinstalled on a non-essential portion of a safetysystem if the valve is isolated automaticallyduring design basis accidents?

Response 4.3.1-4

The valve would not be within the scope ofOM-1 if the portion of the system for whichthe valve provides overpressure protection isisolated during design basis accidents, and thatportion of the system is not required toshutdown the plant, maintain safe shutdown,or mitigate the consequences.

Comment 4.3.1-5

If a system relief valve is not required or evenexpected to actuate during any accidentscenario or sequence of events, is the valverequired to be tested in accordance with OM-1?

Response 4.3.1-5

The scope of OM-1 is not directly related toan actuation during an event. It includesvalves that provide overpressure protectionfor a system required to function during anaccident as defined in Section III, SubsectionsNB, NC, and ND.

Comment 4.3.1-6

The draft NUREG-series report states that the"pressure relief valves which are installed inthe applicable system to protect againstoverpressure may not typically perform asafety-related function." The classificationmethodology for active components is takenfrom Regulatory Guide 1.48 and includesthose pumps, valves, and pressure relief

devices "that must perform a mechanical

system safety function."

System safety functions include any functionthat is necessary to ensure (1) the integrity ofthe reactor coolant pressure boundary, (2) thecapability to shutdown the reactor andmaintain it in a safe shutdown condition, or (3)the capability to prevent or mitigate theconsequences of accidents that could result inoffsite exposures comparable to the guidelineexposures of 10 CFR Part 100. This activecomponent classification methodology and thescope statements of ASME OM (Parts 1, 6,and 10) have the same meaning (i.e., pumps,valves, and pressure relief devices performingnuclear safety functions).

The passive valves in the IST program arefound through individual system reviews. Thepassive valves include those valves required toperform a nuclear safety function (as definedabove) by maintaining their position and forwhich ASME OM Part 10 specifies leakagetesting or position indicator testingrequirements. ASME OM Part 1 providesrequirements for pressure relief devicesrequired to perform a specific function inshutting down a reactor or in mitigating theconsequences of an accident. The ISTprogram scope should include those pressuredevices that do an active nuclear safetyfunction, which is consistent with ASME OM-1987 Interpretation. 1-2 and the activecomponent classification methodologydescribed above.

Response 4.3.1-6

The scope issue for Part 1 will need to beaddressed by regulatory changes or changesby the OM Committee. The comments havebeen referred to the OM Committee to use inassessing and clarifying the scope.

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NRC-approved code case?Section 4.3.3, “Test SupervisorQualifications”

Comment 4.3.3-1

(1) ASME Performance Test Code (PTC)25.3-1976, Paragraph 1.06, states that"this Code only applies to testing ofvalves where the pressure and flowcapacity of the facility is adequate toconduct the test." PTC 25.3-1976,Paragraph 3.02, concludes with "may beconsidered qualified to supervise thetest." How can this be interpreted as arequirement for IST as stated in Section4.3.3?

(2) What must be included in an acceptableformal education for the test supervisorqualification in the 1977 Addendum toPTC 25.3-1976? For example, how many Yes. The code case could be used toclass hours are needed? determine an acceptable alternative and to

Response 4.3.3-1

(1) PTC 25.3-1976 applies to IST throughreference in ASME Section XI, IWV- What action is required for plants which have3512. The ASME Code committee performed relief valve setpoint testing thatstated that, although the test was not supervised by an individual whosupervisor's qualification of PTC 25.3- satisfies the requirements of Test Supervisor1976, paragraph 3.02, apply in accord as defined in ASME/ANSI PTC 25.3-1976? Iswith IWV-3512, the provisions are this a reportable occurrence?permissive (allow discretion).

(2) The alternative in the 1977 Addendumstates that a person who supervises the The licensee could review test records totest shall have a formal education in verify that the set pressure tests werethermodynamics and fluid mechanics, supervised by a person meeting the minimumbut the alternative does not require an requirements of the licensee's QA program. engineering degree. The qualifications are discretionary in that the

Comment 4.3.3-2 PTC or specify other qualifications. If

The section refers to Code Case N-442 whichis not listed in Section 2.1 with the otherreferenced code cases for IST. Is this an

Response 4.3.3-2

Code Case N-442 applies to Section III,Division 1, Subsections NB, NC, ND, and NE,of the ASME Code and has been endorsed bythe NRC in Regulatory Guide 1.84. Becauseit does not apply to Section XI, it has not beenlisted in Regulatory Guide 1.147 for use bylicensees in IST programs.

Comment 4.3.3-3

Code Case N-442 has been annulled becauseit has been incorporated into the ASME Code,Section III. May it be referenced in a reliefrequest?

Response 4.3.3-3

justify the alternative in the proposed request.

Comment 4.3.3-4

Response 4.3.3-4

licensee can use the qualifications given in the

minimum qualifications cannot be determined,the "event" may be reportable.

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Comment 4.3.3-5 Comment 4.3.4-3

Section 4.3.3 recommends that the test PECO has established a maximum limitingsupervisor's qualifications be included in the stroke time of greater than 2 seconds for thetest records. We use personnel qualified in automatic depressurization valves because ofaccord with requirements of the quality the variance in the measured values from 1.4assurance program and believe this is to 2.2 seconds. We do not consider the 2-sufficient documentation. second stroke time limit reasonable based on

Response 4.3.3-5 Response 4.3.4-3

The recommendation has been changed from Stroke times may vary when attempting totest records to plant records. The obtain the indication of valve full stroking bydocumentation need not be part of the test using acoustic monitors as that does not allowreport, but be readily available in the plant for tight control of the test. The OMrecords system at the site. Committee is addressing whether the ADS

Section 4.3.4, “Frequency and Method of test requirements, or if OM-1 gives adequateTesting Automatic Depressurization Valvesin Boiling-Water Reactors”

Comment 4.3.4-1

In the NRC Recommendations, "... if a 2-second limiting value of is assigned using ..." Delete "of" in the sentence.

Response 4.3.4-1

Change made as noted.

Comment 4.3.4-2

Does IWV-3410 (OM-10, Paragraph 4.2.1)require exercising Category A/C and B/Csafety valves and relief valves?

Response 4.3.4-2

Valves in more than one category are subject a root cause analysis of the failure and taketo the testing requirements for all the corrective actions to prevent recurrenceapplicable categories unless there is a specific before returning a safety/relief valve tocode exemption. The OM Committee is service if the valve has exceeded its setpointreviewing exercising requirements for safety by greater than 3 percent? Can the licenseeand relief valves. follow logic discussed in Section 3.2 as an

reference stroke times achieved.

valves need to be subject to the stroke time

indication of the capability of the valves tostroke.

Section 4.3.5, “Jack-and-Lap Process”

Comment 4.3.5-1

Paragraph 3.4.1.1(d) of OM-10 is referencedalthough no paragraph by this number exists.

Response 4.3.5-1

The reference has been changed to Paragraph3.4.1.1(d) of OM-1.

Section 4.3.6, “Safety/Relief Valve SetpointAdjustments”

Comment 4.3.6-1

Does this section imply that a licensee must do

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alternative and do a preliminary analysis to 7.3.1.1 of OM-1-1987). If no maintenance ordeclare the valve operable and exit the action set pressure adjustment is performed and thestatement, with a more detailed analysis to set pressure meets the acceptance criteria,follow? then the number of tests required by the

Response 4.3.6-1 example. An inquiry to the OM Committee to

OM-1 requires the "cause" of failure to bedetermined and corrected. A condition couldbe found and corrected and the valve setpointverified to be within the acceptable range such Given the hypothetical, but not unusual, casethat it may be placed in service. Once the where the first lift of a relief valve is found tocondition that necessitated corrective action be unacceptable but two or more succeedinghas been found, the licensee could do further lifts are within tolerance, what is the properanalysis into the "root cause" of the particular course of corrective action?condition. Generally, corrective actionprograms are established to take such an Response 4.3.7-2approach. An example of the differencebetween "cause" and "root cause" can beshown for setpoint drift. When the safetyvalve setpoint has "drifted" above theacceptable limit, adjustments may correct thecondition such that the valve can be put backinto service. However, the root cause of thesetpoint drift may be unknown. The Boiling-Water Reactor Owners' Group has conductedresearch on the root cause of the setpoint driftin main steam safety and relief valves ofboiling-water reactors, for example, and hasrecommended a change to the valves that maycorrect the condition to prevent recurrence.

Section 4.3.7, “Setpoint As-Found Value”

Comment 4.3.7-1

If the as-found test is within acceptancecriteria, and no adjustment or maintenance isrequired, is it permissible to perform only oneadditional lift (i.e., two total lifts to verify bothas-found and as-left set pressure)?

Response 4.3.7-1

The as-found set-pressure must be determinedbefore doing a maintenance or set pressureadjustment, or both (e.g., see Paragraph

"number of tests" would be met in your

clarify the intent may be appropriate.

Comment 4.3.7-2

The first lift is the only lift which may beinterpreted as being the as-found test. If thisas-found set pressure exceeds the appropriateacceptance criterion, corrective action, asdetermined necessary by the owner, must befollowed. Additional valves shall be tested asrequired.

Section 4.3.8, “Vacuum Relief Valves”

Comment 4.3.8-1

It appears that only those vacuum breakersthat protect components from an increase ininternal vacuum (as it is associated withpressure relief or pressure equalization) arerequired to be in the scope, such assuppression pool-to-reactor building vacuumbreakers in a BWR. Does this mean thatvacuum breakers that only prevent theformation of a water leg in piping are notrequired to be in the scope (e.g., vacuumbreakers in the safety relief valve dischargepiping to the suppression pool in a BWR)?

Response 4.3.8-1

The valves in your example are within thescope of OM-1 since they open to equalize

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pressure resulting from "vapor condensation . .Section 4.4.1, “Pressurizer Power-Operated. capable of causing an internal or externalpressure increase" as stated in Section III,Division 1, Subsection NC/ND-7111. However, if you determine that these valvesdo not perform functions within the scope ofthe definition for "overpressure protection,"they would not be required to be in the ISTprogram.

Comment 4.3.8-2

What is the setpoint of a "simple check valve"used as a vacuum breaker? What if the checkvalve has no leak tight criteria (i.e., if it is isnot Category A/C)?

Response 4.3.8-2

The setpoint is the pressure (vacuum) force atwhich the valve is required to open to relievevacuum. If the check valve has no leak tightcriteria, leak testing is not required. If therequirements for vacuum breakers do notapply, only the requirements of OM-10 applyto the check valves.

Comment 4.3.8-3

This section implies that licensees must useOM-1. If a licensee is required to use onlyIWV, then OM-1 does not apply for vacuumrelief valves and their requirements.

Response 4.3.8-3

Your comment is correct. The words "ifapplicable" have been added after "OM-1."

Relief Valve Inservice Testing”

Comment 4.4.1-1

Is it assumed that where PORV testing at eachcold shutdown is prescribed, it is notnecessarily limited to more frequently thanevery 92 days?

Response 4.4.1-1

Item (e) of the recommendation states that ifthe plant frequently enters the cold shutdownmode, testing of the PORVs is not requiredmore often than once every 3 months. TheIST program could clearly state such aprovision.

Comment 4.4.1-2

The original guidance in ANO-1 was also to leak test a block valve (Category A). Laterguidance, including Section 4.4.1, leaves thattest out. What is the expectation?

Response 4.4.1-2

The basis of the original guidance could bereviewed to determine if it still applies. Thelicensee could do a review under10 CFR 50.59 to determine if anycommitments made in response to GL 90-06were beyond guidance it later obtained fromNRC. The licensee could then revise itsresponse to GL 90-06. The safety evaluationfor ANO-1, of May 24, 1994, does not discussleakage testing of the block valve but statesthat the block valve is tested in accordancewith Section XI. Section XI does not requireleak testing if the valve is not required to beCategory A.

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Section 4.4.2, “Post-Accident Sampling that could result from a particle that is belowSystem Valves”

Comment 4.4.2-1

Section 4.4.2 notes that containment isolationvalves included in the post-accident samplingsystem are required to be included in the ISTprogram. The basis for including this as aseparate section of the NUREG-series reportis not clear, since containment isolation valvesin any system should come under the testrequirements of Appendix J, the IST program,or both.Response 4.4.2-1

The section was included in the guidelines toclarify that the remaining valves may not bewithin the scope of 10 CFR 50.55a. The issuehas been discussed in previous NRCinspections.

Section 4.4.3, “Multiple ContainmentIsolation Valve Leak-Rate Testing”

Comment 4.4.3-1

The requirement to base the leak rateacceptance criteria on the smallest valve in agroup is inconsistent with common sense. If asmall valve that is tested with several largevalves is severely degraded, the leakage willnot likely increase at a significant rate. Incontrast, a minor change in the condition of alarge valve could result in leakage orders ofmagnitude greater than that even plausibly in asmall valve. Are other approaches acceptableto establishing acceptance criteria?

Response 4.4.3-1

As noted in the recommendation, othermethods of establishing acceptance criteriamay be acceptable, and other methods havebeen approved. For example, tests wereconducted at the Clinton Power Station todetermine the maximum size of an opening

the system filtration size. The acceptancecriteria are based on the results of these tests. A method that ensures detection of leakagewithin safety analysis limits is acceptable. Fora discussion on the approach used at theClinton Power Station, see "Modeling ValveLeakage," by Steven R. Bell and RandallRohrscheib in NUREG/CP-0137.

Comment 4.4.3-2

The methodology for establishing leakagelimits for valves tested in groups is theresponsibility of the licensee and need not beapproved by the NRC. This methodology is ata level of program detail that should not beincluded in the IST program documentsubmitted to the NRC, but rather should bedescribed in the IST program implementingprocedures available at the plant site.

Response 4.4.3-2

When using OM-10, the leakage rateacceptance criteria are the responsibility ofthe owner. The approval of relief requests toIWV-3420 requirements was necessary beforeOM-10. It is recommended thatdocumentation of the method be available atthe plant site as part of the implementation ofIST.

Comment 4.4.3-3

Sections 4.4.3 and 5.3 give details formethodology to be included in the ISTprogram. Can the methodology be included inplant IST administrative procedures orsurveillance test procedures, as appropriate?

Response 4.4.3-3

The details may be included in the ISTprogram documents, which includeadministrative procedures or implementingprocedures. The statements have been

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clarified. Response 4.4.4-2

Section 4.4.4, “Post-Maintenance TestingFollowing Stem Packing Adjustments and address this comment. Backseating of Valves to Prevent PackingLeakage”

Comment 4.4.4-1

Can Section 4.4.4 be revised to includemanual adjustment of valves with backseats tostop external packing leakage, to be allowedthrough performance and acceptable results ofan engineering evaluation?

Response 4.4.4-1

In NRC Information Notice 87-40, the staffdiscusses backseating valves. BothWestinghouse and General Electric had issuedguidance on backseating to minimizedeformation to valve stems. Backseating isnot listed in IWV or OM-10 as an example ofa maintenance activity. The licensee wouldhave to assess the effect on the operation of aparticular valve if backseating is performedand determine if post-maintenance is required. GL 89-10 test results may indicate whetherbackseating of a particular valve affects thestroke time of a valve. Any informationwould need to be included in an evaluation.

Comment 4.4.4-2

It is not clear that an engineering evaluation in the IST program if their only safety functionmust be performed in all cases where packing is for leak tightness? Do they have to beis adjusted without post-maintenance testing, included if they only have to be capable ofand not just in those cases where the torque changing position, but do not have to be leak-value exceeds the manufacturer's limit. It tight to perform their safety function?should be clarified that if the torque exceedsthe manufacturer's limit, the manufacturer Response 4.4.6-1must supply data for the engineering analysis.

The recommendation has been clarified to

Section 4.4.5, “Leak-Rate Testing UsingOM-10 Requirements”

Comment 4.4.5-1

Section 4.4.5 states that one differencebetween IWV-3420 and Paragraph 4.2.2.3 ofOM-10 is that OM-10 allows a pressure decaytest. IWV-3424 states that "valve seat leakagemay be determined by one of the following...". Does Section 4.4.5 preclude the use of otherseat leakage test techniques such as pressuredecay? Why was the word "may" usedinstead of "shall"?

Response 4.4.5-1

The statements in Section 4.4.5 do notpreclude the use of other methods in accordwith IWV-3424. For the purposes of theASME codes and standards, the use of theword "may" is discretionary action, while theword "shall" means a requirement.

Section 4.4.6, “Manual Valves”

Comment 4.4.6-1

Are manual (handwheel) valves required to be

If a manual valve is not required to changeposition, periodic exercising is not required. Ifa manual valve is required to be leak-tight,

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periodic leak testing is required. If a manual (e.g., computer mimics)?valve is required to both change position andto be leak-tight, periodic exercising and leak Response 4.4.6-3testing are required. If a manual valve hasposition indication, the position indicationmust be periodically verified even if no othertesting is required.

Comment 4.4.6-2

Must a manual valve be tested if it is Class 1, position indication except Category D valves. 2, or 3and "can be used" to mitigate accidents, This testing applies whether the valve is activebring a plant to cold shutdown, or maintain the or passive, power-operated, or manuallyplant in that mode, even if it is used for operated (see Table 1 of OM-10). Earlierconditions "outside design basis" (i.e., editions of IWV were not so specific.accident with more than a single failure)?

Response 4.4.6-2

IST is not required if the function is not actions and frequency justifications (e.g.,required by the safety analysis. Such valves stroke time not required on manual valves,may be required to be periodically exercised valve position verification for manual valves).under another program or as a good practice.

Comment 4.4.6-3

Why would it be necessary to verify theposition indication for passive valves? This Additional guidance has been noted in theseems to imply that the valve may not be in its recommendation. While stroke-timing wouldrequired position during an accident. If so, not apply, other test requirements wouldthen the valve is not passive. Does this apply apply. to manual valves or to computer indications

If position indication has not been periodicallyverified, an operator may incorrectly assume,based on incorrect position indication, that avalve is in its passive position, when in fact, itis in the wrong position. OM-10 requiresposition indication testing for all valves with

Comment 4.4.6-4

We request additional guidance on relief

Response 4.4.6-4

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COMMENTS ON SECTION 5,“SUPPLEMENTAL GUIDANCE

ON INSERVICE TESTING OF PUMPS”

General Pump Issues program for tracking and scheduling purposes,

Comment 5-1

Define "vertical line shaft pumps." Does thisterm include vertical pumps having a commonpump/motor shaft, such as residual heatremoval or containment spray pumps?

Response 5-1

The OM Task Group on Pumps recentlyproposed to define "vertical line shaft pump"as "a vertically suspended pump, where thepump driver and pumping element areconnected by a line shaft within an enclosingcolumn which contains the pump bearings,making pump bearing vibration measurementsimpracticable." This definition may changebefore it is approved.

Comment 5-2

Do the lube oil systems on safety-relatedpumps and diesels fall under the ISI/ISTprogram since their failure would render theparent component inoperable?

Response 5-2

These systems are not typically Code classand, therefore, are not included in ISI/ISTprograms, other than as augmentedcomponents. However, the section has beenrevised to discuss skid-mounted componentsthat may be in a code class. The OMCommittee is reviewing "skid-mounted"components (see Section 3.4). Also, seeRegulatory Guide 1.26 for guidance on thecode classification of components. Suchcomponents may be included in the IST

noting if the testing is of the major componentand not the pump or valve individually.

Comment 5-3

Another issue that should be addressedconcerns instrument inaccuracies. Forexample, technical specifications or the safetyanalysis report requires a pump to produce1000 gpm at 500 psid (design), but the ISTreference values are 1000 gpm (fixed) and 550psid. The low end of the acceptable range fordifferential pressure from OM-6 (0.90) wouldbe 495 psid, although conservatively set at500 psid. Now if this test revealed the pumpwas operable and met IST requirements, andthe 2-percent instrument inaccuracies weretaken into account for flow and differential,the pump could be creating less than therequired volume. In this example, should theinstrument accuracies be taken into account orshould they have been incorporated when thedesign numbers were calculated?

Response 5-3

Limits in the safety analysis must beconsidered when writing pump testprocedures. The requirements for inservicetesting are broadly written. If specific plantlimits are more conservative, they are theabsolute "operability" limits for meeting thelicensing basis of the plant and may need to beused with adequate pump performance for ISTacceptance criteria. For example, see Section5.2, item (5) of the elements listed for usingpump curves. The value as read would beused if it was obtained using instruments thatmeet the accuracy requirements for IST data. If a licensee is attempting to perform a critical

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test, more accurate instruments may be in the relief request. An explanation wouldnecessary; however, the value recorded would help NRC review the relief request andbe the value read if the accuracy of the preclude questions. instruments met the specified accuracy. Onlywhen instruments are used that cannot meet Comment 5.2-2the specified accuracy for a test would anadjustment be necessary to meet Coderequirements. Design analyses most likely donot account for instrument accuracy inobtaining readings; however, when the pumpis selected, the designer generally selects froma catalog of available sizes and chooses onewith margin above the analyses numbers. The"comprehensive pump testing" approachrecently approved for incorporation into theOM Code (OMc-1994 Addenda) specifies aninstrument accuracy of 0.5 percent fordifferential pressure, but continues to specify2 percent for flow rate instruments.

Section 5.2, “Use of Variable ReferenceValues for Flow Rate and DifferentialPressure During Pump Testing” explain the basis for the specific pump tests

Comment 5.2-1

In the use of pump curves, therecommendation includes guidance for reliefto "construct each curve with a minimum offive points." We disagree with the need forfive points because it does not differentiatebetween the amount of pump curve used. Forexample, five points would be appropriate fora curve encompassing the entire pumpoperating range, but three points are sufficientfor a curve encompassing five percent of thepump operating range. What is the basis forfive points?

Response 5.2-1

The guidance in the recommendation will notcover all cases. As noted, the five points aremore appropriate for a large range on thepump curve. When testing over a morenarrow range and thus plotting fewer points,the licensee could state the number of points

Element (4) of the recommendation statesthat the curve be constructed in a range asclose as practicable to design basis flow rates. Sometimes the design basis flow rate is in the"flat" portion of the curve. , Constructing therange as close as practicable to the point ofmaximum hydraulic efficiency would be moremeaningful than using the design basis flowrate.

Response 5.2-2

Most pumps are selected for the design flow tobe close to the best efficiency point of thecurve. For pumps that do not appear to fit therecommendation, a relief request could

and use of curves for establishing acceptancecriteria. The recommendation is for guidancerather than to establish restrictions.

Comment 5.2-3

Element (7) refers to revalidating the previouscurve by doing an inservice test. If it isdetermined that the maintenance activityshould not significantly affect the referencecurve, is one point adequate to revalidate thecurve? Also, if a new reference curve needsto be plotted because of maintenance, doesthe entire curve need to be reverified or onlythe portion of the curve that is used in the testprocedure?

Response 5.2-3

"Should not" versus "could not" may be thedetermining factor for determining the numberof points needed to reverify the curve. Theowner would have to make the determinationbased on the type and extent of maintenance

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and document the basis for using a single respective reference values." Section 5.3 ofpoint. Plant conditions may preclude more NUREG-1482 also states that certain designsthan one point until a plant shutdown, for do not allow for the licensee to set the flow toexample, which would be an acceptable basis an exact value because of limitations in thefor returning a pump to service based on instruments and controls for maintainingreverification of a single point on the curve, steady flow. Diesel fuel transfer pumps atwith additional points verified at the next WNP-2 do not have inline flow meters. Theplanned shutdown. For post-maintenance and pump flow rate is determined by measuringother testing, only the portion of the curve volume of fluid pumped and dividing by theused in the test procedure needs to be corresponding pump run time. A clamp-onreverified for inservice testing. If a major flowmeter will not accurately measure themodification or repair/replacement is flowrate in a repeatable manner because theperformed on the pump, a design-basis of a low flowrate and lack of time available to(startup type) test may be necessary before set up the instrument with the pump running. placing the pump into service. Such a test Pump discharge piping has a manual dischargecould also verify the pump curve for IST. isolation and day tank inlet isolation valves,

Comment 5.2-4

The example given references an acceptableoperating range of 0.93 - 1.02 times the pumpcurve value. These are IWP ranges. If OM-6is used, can the OM-6 range of 0.9 - 1.1 timesthe pump curve value be used?

Response 5.2-4

As noted in the recommendation, theallowable ranges for the pump curve must beconsistent with Table IWP-3100-2 or Table 3bof OM-6, as appropriate for the requirementsused for pump testing. The acceptable rangesfor various types of pumps listed in Table 3bof OM-6 are not 0.9 - 1.1 for all pump types.

Section 5.3, “Allowable Variance fromReference Points and Fixed-ResistanceSystems”

Comment 5.3-1

Paragraph 5.2(c) of OM-6 specifies that, if thepump is in a system in which the resistancecannot be varied, the "flow rate and pressureshall be determined and compared to their

which are always fully open.

If system resistance is based on the systemlineup remains constant from test to test, theflowrate would normally remain constant. Since the flowrate is calculated based on thechange in the tank level during the pump run,any adjustment of flow rate with the globevalve will be meaningless. Thus, the onlyprudent choice is to run the test with bothvalves fully open, by maintaining the systemat a constant resistance. The system designand lack of inline flow meters indicate thatthis situation meets the intent of paragraph5.2(c) of OM-6, which allows that "wheresystem resistance cannot be varied, flowrateand pressure shall be determined andcompared to their respective referencevalues." Section 5.3 of the draft NUREG-series report and Question Group 49 includesimilar guidance. Please comment.

Response 5.3-1

In NUREG/CP-0111, John Zudans discussedthe differences between IWP and OM-6. Forthe fixed resistance discussed in paragraph5.2(c) of OM-10, the change is described as an"enhancement to current standard" not

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addressed in IWP. Zudans also noted that attempts to allow some band around theparagraphs 5.2 (b) and (c) of OM-10 allow reference value that will continue to givedetermination of differential pressure or flow repeatable results. Readability of the gaugesrate, whereas IWP implies these quantities is an important aspect of the recommendation,must be measured. He stated that the change but if the gauges cannot be read to + 2was to "allow determination when percent, and a single reference value cannotinstrumentation has not been installed or is be achieved, the licensee may justify animpractical to install." If the testing can be alternative and submit a request for relief. Ifperformed with the system at a fixed the OM Committee addresses this situation,resistance, paragraph 5.2(c) of OM-10 would the recommendation will no longer bepermit the use of change in tank level over necessary. time, which can be used to further verify afixed resistance. Factors that could affect theComment 5.3-3resistance of the system must be controlled tothe extent practical to ensure repeatableconditions (e.g., level of tank at the beginningof the test, alignment of valves not in thedirect flow path). Paragraph 5.2(c) clarifiesan issue not addressed in IWP, though notprohibited by IWP; therefore, the use ofparagraph 5.2(c) for fixed resistance systemswould be acceptable without further NRCapproval.

Comment 5.3-2

In the discussion of establishing a tolerance, Response 5.3-3establishing the independent reference valuevariable is inconsistent with the discussionrelated to the precision to which readings areto be taken. It is easily conceivable thatreading a gauge to 2 percent is not practical. By the same token, in some instances,allowing a deviation of + 2 percent wouldallow test personnel to effectively expand theacceptable range significantly. For thisreason, the Commission should reconsider thepolicy that is negative with respect to usingpump curves for pump acceptance criteria.

Response 5.3-2

The recommendation was written to reflectconcerns of several NRC inspectors inattempting to deal with situations wherelicensees specify a range of values rather thana single reference value. The recommendation

We disagree with establishing a + 2-percentallowance variance and requesting relief forany variance greater than 2 percent. Licensees should be able to establish andjustify a range for a reference value. Forexample, a pump that operates onrecirculation by an automatic control valvemay represent the flat part of the pump curve. Monitoring at any value higher than 500 gpmand within the range would provide improvedability to monitor for degradation.

This recommendation addresses the problemthat the code discusses only a reference value. In reviewing IST during inspections, inspectorsfound cases where a plant used a range for theset reference value. The OM Committeeaddressed the use of ranges in response toInterpretation 92-6 (see Section 5.2) statingthe code is not met. The example given doesnot appear to meet the code requirements.

Comment 5.3-4

If a total tolerance of less that + 2 percent ofthe reference value is achievable, relief is notrequired; however, in using this guidance, thevariance and the method for establishing thevariance must be documented in the ISTprogram. Must the method be documented in IST program submittal to the NRC, or does

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"IST program" refer to the whole documented times the reference values be unlimited? Doprogram of which the submittal is just a utilities have the latitude for interpretationportion? The variance around the reference through relief requests?value can change because of new instruments,improved flow control, or different flow paths. Response 5.4-1The variance around the reference value is alevel of program detail that should not beincluded in the IST program submittal. However, the variances are described in theIST program documents residing at thestations, and these documents are available foraudits.

Response 5.3-4

The document submitted to the NRC needonly state your intent to use therecommendation at your plant (e.g.,"Recommendation 5.2 of NUREG-1482 isused for the tests conducted on pumps forwhich the reference value "point" is notachievable"). The details and specific valuesmay be in the test procedures or other ISTprogram documents that are appropriate toimplement the recommendation.

Section 5.4, “Monitoring Pump Vibrationin Accord with OM-6" recommends that the NRC allow relief to limit

Comment 5.4-1

OM-6 separates all positive displacementpumps from centrifugal pumps in the tableswhich give the acceptable ranges for hydraulicperformance; however, the mechanicalvibration surveillance criteria thereindistinguish only the difference betweenreciprocating pumps and centrifugal pumps. No section within the NUREG-series reportgives guidance for the vibration performancecharacteristics of other types of positivedisplacement pumps (i.e., gear, screw, etc.). Must licensees cap the alert and action rangesfor these types of pumps at 0.325 and 0.70inches per second respectively. Can 2.5 and 6

The NRC has received relief requests forpumps of types not addressed in OM-6. Thequestion could be addressed to the OMCommittee.

Comment 5.4-2

Section 5.4 discusses the OM-6 requirementsthat the frequency response range of thevibration-measuring transducers and theirdisplay system be from one-third minimumpump shaft rotational speed to at least 1000Hz. The minimum speed for the liquid poisonpumps at Nine Mile Point 1 and 2 is 360 rpm,or 6 Hz. Obtaining certifiable calibrations atpump shaft rotational speeds of 2 Hz using themore up-to-date equipment available can bedifficult. Therefore, to obtain a certifiablecalibration as prescribed by OM-6 requires theuse of less up-to-date and more time andlabor-intensive equipment. Niagara Mohawk

the frequency response range for low speedpumps to a range of 3 to 1000 Hz. This wouldallow the use of more up-to-date andeconomical equipment available to theindustry.

Response 5.4-2

The NRC cannot "rewrite" the Code through arecommendation. The OM Committee isaddressing slow speed pumps. Currently, arelief request must be submitted when it isimpractical to meet the frequency responserange. The basis for relief should discuss thetype of pump, type of bearings, whether thepump or bearings are subject to failures thatwould be indicated at less than the running

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speed, and the specific problems experienced incorrect "A" gap in a centrifugal pump. with the calibration process. Other causes of subsynchronous vibration

Comment 5.4-3 bearings, and electrical surges; however these

Paragraph 4.6.1.6 of OM-6 requires that thefrequency response range of the vibration-measuring instruments be from one-thirdminimum pump shaft rotational speed to atleast 1000 Hz. A generic problem exists inthat the specified required lower limit ofresponse range for vibration equipment cannotbe met by equipment in use today. Thissituation typically applies to reciprocatingcharging pumps (PWR) and standby liquidcontrol pumps (BWR). It would be helpful ifthis topic was addressed in the NUREG-seriesreport. It was not discussed when OM-6 wasdeveloped. WNP-2 has standby liquid controlpumps that turn at 370 rpm, or 6.16 Hz. One-third shaft speed is 2.05 Hz. Instruments thatcan read 2 Hz may be available, but thisfrequency is less than what is traceable to theNational Bureau of Standards for calibration. Although licensees could implement anexpensive program for obtaining a vibrationinstrument that is traceable to the NationalBureau of Standards, such a cumbersomeprocess would add nothing to the vibrationdata presently obtained from the standbyliquid control pumps using CSI 335accelerometers, which are calibrated down to6 Hz. This frequency will capture the pumprotating frequency, which is the mainfrequency of interest for these pumps.

The following technical assessment is basedon a qualitative roto-dynamic evaluation ofthe standby liquid control pumps. NRC doesnot require subsynchronous vibration data onselect slow speed reciprocating machines(1000 rpm or less) with short shafts that aresupported on frictionless bearings. In general,subsynchronous vibrations are attributable tothree causes: (1) shaft rubs, (2) fluid whirl in ajournal bearing, and (3) axial instability causedby improper axial positioning of the rotor or

include bolts, cage problems in frictionless

either do not apply or are preceded by anindication at a higher frequency. Items 2 and3 do not apply for a reciprocating machinesupported on frictionless bearings because ashaft rub in a short shafted machine supportedon frictionless bearing would require a failureof one of the frictionless bearings. The shortshaft and slow speed implies that the machineoperates below its first critical speed. Therefore, it behaves as a rigid member andwill deform in such a way as to take upclearances and allow contact between stationand rotor. Thus, the only mechanism forcontact is a bearing failure, and therefore shaftrub will always be preceded by a bearingfailure.

Frictionless bearings proceed towards failurein stages, displaying rotor patterns foridentification. The patterns occur at amultiple of running speed, such as 3.25running speed for a typical outer race defect. This multiple will repeat harmonicallydepending on the severity of the problem. Thus, the subsynchronous region of thefrequency spectrum for such a slow speedmachine would add nothing to the data neededto find the problem early. The standby liquidcontrol pumps at WNP-2 are slow speed, shortshafted, pumps supported on frictionlessbearings and driven by a 4.8:1 gear train. Thespectral vibration data shows anothervibration in the subsynchronous region. All ofthe vibration indications, none of whichreveals a problem, are in the higher frequencyrange. Subsynchronous data for thesemachines is of little use, and the lowfrequency requirements of subparagraph4.6.1.6 of OM-6 do not add to the quality ofthe vibration data from the pumps.

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Response 5.4-3 overall indication of the condition of a pump

See Response 5.4-2 above. Apparently, thecode committee did not establish thefrequency response range for all types ofpumps. When the requirements appear to beimpractical, the licensee may request relief.

Comment 5.4-4

For pumps with very low vibration readings(e.g., 0.025 in/sec), can higher acceptablelimits be established at higher than 2.5 and 6times the reference values? Have reliefrequests been granted for smooth-runningpumps ?

Response 5.4-4

NRC has granted relief for using a minimumreference value for smooth-running pumps,while maintaining the 2.5 V as an alert limitr

and 6.0 V as the required action range. Ther

OM Committee is considering a code case toaddress smooth-running pumps. In grantingthe relief, the staff stated that when the OMCommittee has addressed the issue, the reliefrequest must be modified to be consistent withthe new requirements.

Comment 5.4-5

We will incorporate OM-6 into our ISTprogram in October 1994. We have two HPSIpumps that are acceptable by our presentprogram, but are in the required action rangeby OM-6. What can we do now to addressthis condition? Should we write a reliefrequest?

Response 5.4-5

Your question indicates you are comparing thevalues of velocity with those of displacement. Because velocity measurements are a better

than displacement measurements, and thelimits of OM-6 are set at values that mayrepresent degradation of a pump, you wouldneed to determine why the vibration is in therequired action range. Footnote 1 of OM-6may be useful in your assessment. The staffhas approved relief requests that increased thealert limit for pumps that have high vibration,but long-term relief has not be granted forexceeding the required action limits. OM-6allows use of either velocity or displacement,though velocity is recommended for pumpsthat rotate at greater than 600 rpm. If thecode requirements cannot be met, a reliefrequest would be necessary to comply with10 CFR 50.55a.

Comment 5.4-6

We have a group of pumps with referencevibration values close to 0.325 inches persecond. These pumps are often in the alertrange, but maintenance and vibration spectralanalysis shows acceptable pump performance. Can we state that we will monitor vibrationsclosely through the use of spectrum analysisand use engineering judgment for acceptablevibration limits and continue quarterly testing? We plan to use guidelines from the HydraulicInstitute.

Response 5.4-6

Your proposal would require a relief request. The OM Committee is considering the use ofspectral analyses for exiting the increasedfrequency required when a pump is in an alertrange as you have proposed.

Comment 5.4-7

If a pump, while operating acceptably,normally exceeds the absolute alert limit of0.325 inches per second in OM-6, can a new

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limit be established at a higher level following mean-square (rms), convert it to peak-to-peak,engineering analysis? and read it as peak-to-peak. OM-6 removed

Response 5.4-7 measured in peak or peak-to-peak. Newer

Your proposal would require relief from therequirements of OM-6 and must be justified. Relief has been granted in some cases to raisethe alert limit.

Comment 5.4-8

Section 5.4 states that vibration instruments inthe low-frequency response range arecommercially available. We obtained the bestaccelerometer standard we could find,calibrated by the National Institute ofStandards and Testing down to 1 Hz at 0.07gs. The reference values for our charging pumps(running speed 3.3 Hz) are around 0.5 mils(approximately 0.0002 gs at this speed). Thisacceleration is far below the calibrated rangefor our standard. Thus it does not appear thatvibration instruments calibrated in the rangesrequired for low-frequency applications areyet commercially available.

Response 5.4-8

The recommendation has been modified forthe very slow speed pumps used at somenuclear power plants. The OM Committee isassessing changes to address the unavailabilityof vibration instruments that can meet theserequirements and to address the considerationthat not all pump types need to be monitoredat frequencies less that running speed. Theunavailability of instruments may be a majorelement in justifying relief when the coderequirements cannot be met.

Comment 5.4-9

Editions of Section XI before the 1988Addenda required that vibration be "read" inpeak-to-peak. This could be interpreted tomean that it is acceptable to measure root-

this ambiguity and requires vibration to be

digital equipments measure directly in peak. The NRC mandated 10-year updates of the ISIand IST programs to reflects the need forlicensees to incorporate new technologieswhich have been incorporated into the codesand standards. However, there is continuingdebate with the OM Committee on whetherthe use of rms measurements is acceptable fordetermining the operational readiness ofpumps. The OM Committee recentlyresponded to an inquiry (File OMI 94-2) andexplained that the the OM Code (and OM-6)allows vibration to be measured in rms andmathematically converted to peak readings. Readers are cautioned that the code vibrationacceptance criteria are in peak or peak-to-peak units and that the use of rms, without amathematical conversion, are not acceptable.

Response 5.4-9

This is an important issue. Licensees who userms values for recording data must adjust thelimits of OM-6, or convert the data to peakvalues.

Comment 5.4-10

The vibration acceptance criteria in OM-6 arenot clearly stated (i.e., 2V to 6V and 0.325r r

ips alert limit, 0.7 ips required action limit),and it is not clear if these values are for full-flow testing or minimum flow testing, wherevibration levels typically increase because offlow noise.

Response 5.4-10

Such issues would have to be clarified by theOM Committee. The limits currently apply atthe test conditions for IST.

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Comment 5.4-11 relatively unimportant.

OM-6, Table 6100-1, has a more narrowacceptance band for "vertical line shaftpumps" (0.93 vs. 0.90). The basis for thisnarrow band should be explained. Noapparent increase in safety margin is obtainedwhen such pumps are analyzed fordegradation of 10 percent or greater.

Response 5.4-11

The change was made by the O&MCommittee. John J. Zudans's paper,"Introduction to ASME/ANSI OMA-1988A,Page 6 - `Inservice Testing of Pumps in Light-Water Reactor Power Plants' and TechnicalDifferences Between Part 6 and ASMESection XI, Subsection IWP," fromNUREG/CP-0111, it is stated that thehydraulic acceptance criteria for vertical line Compliance with the digital accuracyshaft pumps and positive displacement pumps standards may be impractical if a digitalwere made more stringent because "there are instrument replaces an analog instrument. inherent deficiencies in vibration testing and Although the requirement may improvedegradation will be identified sooner through accuracy, other (existing) components in thechanges in hydraulic parameters." instrument loop may render it unattainable without upgrading the entire circuit.Section 5.5, “Pump Flow Rate andDifferential Pressure Instruments” Response 5.5-2

Comment 5.5-1

The discussion in this section brings to light a however, the broader concern would require akey issue but does not go far enough. Other change to OM-6.issues related to instrumentation should beaddressed: Comment 5.5-3

(a) When measuring suction and dischargepressure that are subsequently used toderive differential pressure, the accuracyrequirements should be applied to thefinal result (differential pressure) and notto the individual readings. This isspecifically directed to the suctionpressure reading where accuracy is

(b) The code accuracy requirement should befocused on the accuracy of the readingand not arbitrarily on the instrument. Thediscussion in this document seems to begoing in this direction — why not theCode?

Response 5.5-1

The additional issues could be directed to theOM Committee for changes to the OM Code. The NRC may grant relief for an individualsituation at a specific plant. A number ofrelief requests have been received for therange of suction pressure gauges.

Comment 5.5-2

Relief could be requested based on theimpracticality in the existing instruments;

The discussion of the absolute accuracyrequirements for flow loop instrumentation iscorrect regarding repeatability, which is thebasic assumption of the code; however, whenthe Commission imposes other demands onthe test program where absolute values areimportant, it is no longer valid. This isespecially true when test data is used to verify

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"acceptable pump operation" or compliance Comment 5.5-6with the plant technical specifications orassumptions used in plant safety analyses.

Response 5.5-3

The comment is correct for operability issues humidity effects, and the accuracy of theoutside the area of inservice testing. IST is to device used to calibrate the instrument bemonitor for degrading conditions and is not a considered when determining if instrumentdesign basis verification test. It may verify accuracies meet the requirements of IWP andthat a component functions at a specific, OM-6?repeatable condition, at a point in time. Itdoes not ensure that a component will Response 5.5-6function under accident conditions. Ifsupplemental testing is performed to verifydesign basis capability, more accurateinstruments may be necessary, or the licenseecould make adjustments for knowninaccuracies of the instruments.

Comment 5.5-4

The recommendation in 5.5.2 for applyingOM-6 requirements to digital instruments isnot a requirement.

Response 5.5-4

The second sentence has been modified tostate that it is recommended that therequirements in OM-6 for digital instrumentsapply when using such instruments for IST.

Comment 5.5-5

Why is replacement or installation ofadditional instrumentation not considered abackfit?

Response 5.5-5

The response to Question 105 in Appendix Aaddresses this comment. Typically, if anequivalent means of determining the"measured" parameter is available, installationof a permanent instrument would not berequired.

Does the guidance in Section 5.5.4 on the loopaccuracy calibration of analog instrumentsapply to digital as well? Must factors such asdrift, readability, temperature effects,

The referenced code inquiry discussed inSection 5.5.4 states that it applies to analoginstruments. The question on factors toconsider in determining instrument accuracyneeds to be directed to the OM Committee.

Comment 5.5-7

Section 5.5.4 addresses flow device elementsand the interpretation concerning notincluding certain items in the loop accuracycalculation. How are digital flow instruments,where the "flow element" is the pipe andultrasound (e.g., Controlotron) or other suchtechnology, to be characterized? Would onlythe loop accuracy of the computer (processingunit) need be addressed?

Response 5.5-7

This question would need to be addressed tothe OM Committee. However, it seems to beindustry practice to account for the accuracyof the measuring device and the installationrequirements for ensuring the accuracy of thereading (e.g., length of pipe runs).

Comment 5.5-8

In the report, NRC discusses the range andaccuracy of both analog and digitalinstruments. It is unclear whether computerpoints or printouts can be used to meet the

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necessary instrument requirements and if relief?additional requirements are associated withthe use of the computer. Response 5.5-10

Response 5.5-8

Some plants do use computer points to record requirement not in earlier editions of the Codetest data for IST. If the requirements of the is included in a later edition, it is presumedcode are unclear, questions could be that if an inquiry were submitted to the Codeaddressed to the OM Committee. Committee (Section XI or OM), the response

Comment 5.5-9 the later edition. However, IWV (1986

In safety evaluation reports for some utilities,the NRC has stated that an analog instrumentwith an accuracy of + 2 percent of full-scale isin effect accurate to + 6 percent at 1/3 ofrange. The draft NUREG-series report seemsto imply that analog instruments are requiredto be accurate to + 2 percent at the referencevalues (2 percent at 1/3 range). Thisrequirement needs to be clarified, as the draftreport seems to be in conflict with pastpositions.

Response 5.5-9

There does not appear to be a conflict inSection 5.5.1, which discusses the maximuminaccuracy of the reading that could beobtained using the code requirements for + 2-percent full-scale, with a full scale of up to 3times the reference value. Perhaps theconfusion was with the statement of Section5.5 listing the three accuracy statements fromOM-10. The sentence has been reformatted toeliminate confusion.

Comment 5.5-10

IWP (1986 Edition and earlier) does notspecify requirements for digital equipment. Ifa licensee uses IWP (1986 Edition or earlier)and not OM-6, may the licensee developinternal guidance for use without a request for

An inquiry could be submitted to the OMCommittee for clarification. When a

would be consistent with the requirements in

Edition and earlier) does not state that therequirements for instruments apply only toanalog instruments. Therefore, if therequirements of IWV can be met for bothdigital and analog instruments, no relief wouldbe required to continue to apply therequirements of IWV. A program not inconformance with either IWV (1986 Editionor earlier) or OM-10 (which is moreconservative than IWV) would require reliefor approval of an alternative. Digitalinstruments are generally calibrated within apercentage of reading.

Section 5.6, “Operability Limits of Pumps”

Comment 5.6-1

Add the word not to the second sentence: "theOM-6 Working Group ... limits of theappropriate table could not be met."

Response 5.6-1

Change made as noted.

Comment 5.6-2

It appears that OM-6 eliminates the option toperform an operability analysis to determine ifa pump exceeding the action limit can stillperform its safety function (reference SectionXI, 1983 Edition, paragraph IWP-3230,

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"Corrective Action"). This option allowed the Comment 5.6-4continued operation of pumps that have alarge margin between minimum system flow-DP requirements and the 10-percent degradedlimit. That is, once these pumps hit the lowaction limit, a significant margin existedbetween that limit and the minimumoperability limit required of that pump. Thisoffers considerable economic and schedulingadvantages without affecting the safety-related function of the pump. Such pumps asthe boric acid transfer pumps, essential servicewater pumps, and emergency diesel jacketwater pumps have margins that allow forcontinued operation once the low action limitis reached. OM-6 should retain thatalternative, or the NUREG-series reportshould allow for such analysis. Otherwise,code relief requests will be required forextended allowable ranges to capitalize onsuch margin.

Response 5.6-2

This issue is addressed in Section 5.6 of theNUREG-series report. The intent of the OM-6changes was discussed in NUREG/CP-0111,pages 45 and 46. Analysis continues to beacceptable, but must be applied in a differentmanner than allowed in IWV-3230. Theanalysis may now necessitate changes to thereference values of the pump. New referencevalues must be justified in a manner thatensures the pump is capable of fulfilling itssafety function.

Comment 5.6-3

Does Section 5.6 allow an expanded range of0.89 — 1.03 for differential pressuremeasurements?

Response 5.6-3

The range of 0.89 — 1.03 stated in the basis the "alert" limit for some of the pumps andfor recommendation is an example from the have the "required action limit" at, forinterpretation. example, 93 percent of the reference value

If a pump is declared inoperable and an LCOentered because of test data in the actionrange, can an analysis be used to exit the LCOif the analysis demonstrates that the pump iscapable of performing its safety function inthe degraded condition? Can this be donewithout baselining the pump as required byIWP-3230(c)?

Response 5.6-4

IWP-3230(c) discusses an analysis todemonstrate that the unacceptable conditiondoes not impair pump operability and that thepump will still fulfill its function. IWP-3230(c) states that a new set of referencevalues shall be established after such analysis. If the licensee elects to maintain the currentreference values rather than establish newreference values, the evaluation must includethe reason and the basis for the acceptabilityof retaining the previous reference values. OM-6 does not include provisions forperforming an analysis; however, members ofthe OM Committee Working Group on Pumpsstated that future editions of the OM Codemay address analysis as corrective action. GL91-18 includes guidance for the use of analysisfor such conditions (see Section 7 herein).

Comment 5.6-5

We have several pumps that do not havesufficient margin to be considered capable ofperforming their design-basis safety functionto the action limits of IWP or OM-6. Forexample, the reference value of a pump maybe 1000 gpm, with a minimum design-basisflow requirement of 930 gpm. We realize thatwe cannot allow degradation below thedesign-basis capability limits and need toadjust the limits for IST. May we eliminate

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rather than the allowed 90 percent of the Response 5.6-5reference value? Similarly, may we, forexample, raise the "alert" limit from 93 to 95percent of the reference value, with a"required action limit" of 93 percent of thereference value?

When a pump does not have sufficient margin,adjustment of the acceptable limits mayneeded to account for the design and licensingbasis requirements. NRC approval is notnecessary because these adjustments are moreconservative than the Code.

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COMMENTS ON SECTION 6,“REVISED STANDARD TECHNICAL

SPECIFICATIONS”

This section has changed from the draft report the comment. The extension is forthat was issued for public comment. In the surveillance scheduling and considers plantdraft report, the staff stated that that operating conditions that may not be suitable10 CFR 50.55a did not requre an NRC for conducting the surveillance (e.g., transientevaluation of an impracticality determination conditions or other ongoing surveillance orbefore the licensee could be considered in maintenance activities). The 25-percentcompliance; however, NRC has concluded extension is not to be used repeatedly merelythat it must first grant the relief before the as an operational convenience to extendlicensee can be considered to be in surveillance intervals beyond those specified.compliance with the regulatory requirements. The staff discusses the operability of Comment 6.2-2components during the period from when acode requirement is found impractical until thelicensee receives a safety evaluation fromNRC. The guidance in Generic Letter 91-18applies during that period of time.

Section 6.2, “History”

Comment 6.2-1

Paragraphs 4.2.1.2(f) and 4.3.2.2(f) of OM-10state that exercising power-operated valves As noted in Response 6.2-1, the 25-percentand check valves during cold shutdown "is not tolerance is not to be used as a convenience. required if the time period since the previous The tolerance would apply to increasedfull-stroke exercise is less than 3 months." frequencies the same way that it applies toSection 6.2 of the NUREG-series report regular frequencies as specified in TS 3.0.2further defines quarterly as being 92 days and and 4.0.2. recommends incorporation of this definitioninto technical specifications. Since standard 6.3, “Discussion”technical specifications also contain astatement allowing extension of the testingintervals up to 25 percent, does this imply thatcold shutdown exercising need not beperformed if exercising has been completedwithin the last 115 days rather than 92 days?

Response 6.2-1

No. The basis for the technical specificationsthat allow the 25-percent extension addresses

The revised standard technical specificationsdiscuss test frequencies and surveillancerequirements for IST. Tolerances and graceperiods such as + 25 percent of due dateshould be specified. Any tolerance that isapplicable during "increased frequencies"should be stated.

Response 6.2-2

Comment 6.3-1

In the discussion of 10 CFR 50.55a(3)(i) and(ii), the document states that when analternate method is requested, approval fromthe NRC is required before implementing thealternate method of testing. IWA-2240 ofSection XI implies that prior approval from theNRC is not required as long as the authorizednuclear inspector concurs. IWA-2240 states

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that "alternative examination methods, a demonstrated to be equivalent or superior tocombination of methods, or newly developed those of the specified method." Please clarifytechniques may be substitutes for the methods when IWA-2240 may be applied to alternativespecified in this Division, provided the testing and exams.Inspector is satisfied that the results are

Response 6.3-1

IWA-2240 does not apply to inservice testing. NUREG-1482 does not apply to inserviceinspection. Examination methods which arespecified in Tables IWB-, IWC-, IWD-, IWE-,and IWF-2500-1 of IWA-2200 (1983 Edition). Examination is defined in Article IWA-2000(1983 Edition) as denoting the performance ofall visual observation and nondestructivetesting, such as radiography, ultrasonic, eddycurrent, liquid penetrant, and magneticparticle methods.

Comment 6.3-2

Section 6 recommends that licensees changetheir TS to incorporate the revised STS for ISTprograms. TS 5.7.2.12 of the revised STS wasgiven along with the basis for the change. In aseparate correspondence from the NRC onOctober 25, 1993, "Content of StandardTechnical Specifications, Section 5.0,Administrative Controls," from William T.Russell, Associate Director for Inspection andTechnical Assessment, Office of NuclearReactor Regulation, NRC sent a markedversion of the revised STS, Section 5.7.2.12. Will the final version of Section 6 of theNUREG-series report recommend working asprovided in the October 25, 1992, letter?

Response 6.3-2

The revision to the administrative section ofthe revised STS may be issued while the finalNUREG-series report is being prepared. Alicensee may follow the most current versionof that section of the related revised STS asrecommended in the report. If the

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requirements are removed from the revised recommendations for voluntary use. STS, a licensee may request to remove theaffected paragraphs from TS in accordance Response 6.3-3with the revised STS.

Comment 6.3-3

Section 6.3 discusses implementation of relief impractical, the licensee has the responsiblityrequests for impractical requirements to make the determination with reviews by thefollowing a change to TS, if necessary. Is appropriate management and safetyreview by the plant safety committee a committeess as deemed necessary. Therequirement for such implementation? If so, guidance of Generic Letter 91-18 applies forwhere can the requirement be found? The operability of the component during an interimapprovals needed to implement a relief request period between the time such a plant conditionbefore obtaining NRC approval should be has been identified and the time that the NRCrevised to "approval by the plant staff issues a safety evaluation. The licensee may according to plant administrative policies." establish a review process that ensures that theThe general term "plant administrative individuals, group, or groups responsible forpolicies" is broad enough to include a plant safety are included in the review process. Thesafety committee review and a 10 CFR 50.59 review process established for changes, tests,review. The amount and levels of review and experiments under 10 CFR 50.59 may benecessary should be left to the licensee's acceptable to review these relief requests. discretion and not dictated by a NUREG-series report, which contains

The guidance in the draft recommendationwas not based on specific requirements of theregulations. When a test is found to be

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COMMENTS ON SECTION 7,“IDENTIFICATION OF CODE NONCOMPLIANCE”

Comment 7-1 violation of TS 4.0.5 or equivalent, and should

Is it the intent to require "immediate" testingfor components discovered during design basisreviews or plant modifications? Can theCommission give a time span for implementing IST testing for newly added components.

Response 7-1

A discussion on design bases reviews has beenadded to Section 7 to address this comment.

Comment 7-2

Add guidance in this section to address certainother additions of components to a plant ISTprogram, such as when the componentsformerly did not clearly fall within the scopeof Code requirements, but the licensee haselected to add the component to the ISTprogram because of a modification, revisedinterpretation, or philosophy change. Engineering analysis or other types of testingcould be used for program additions in thiscategory in lieu of Section XI testing to justifyoperability of the components before they areadded to the IST program. Operability wouldlater be determined through normallyscheduled testing. In other words, the licenseeshould be able to assume operability forcertain categories of components newly addedto the IST program without invoking theguidance in GL 91-18 for a grace period untilthe next scheduled IST program testing iscompleted. In the discussion onnoncompliance situations, the staff discusseswhat it believes should be done when alicensee finds components that should be inthe IST program but are not. In most cases, iftesting is required, the component would be in

be declared inoperable. The staff goes halfway, and states that simply failure to performan IST should not cause a forced shutdown,but believes that a Temporary Waiver ofCompliance or other exigent relief fromASME code requirements is necessary. Exigent relief from ASME code may berequired if the testing is already innoncompliance, but a Temporary Waiver ofCompliance should not be necessary if,consistent with the discussion in the NUREG-series report, other tests or operationalperformance data reviews show that thesystem is operable. This would also beconsistent with the comments on GL 91-18.

Response 7-2

The IST guidelines do not supersede existingNRC guidance. GL 91-18 gives guidance onresolving degraded and nonconformingconditions. It defines a "code noncompliance"for IST as either a missed surveillance test orthe identification of a component that must beadded to the IST program, and either of theserepresent a nonconforming condition. That is,the "qualification" of the system, subsystem,or component (SSC) is being called intoquestion. A nonconforming condition thatdeals with the qualification of a componentmust be dealt with at a level of quality andsafety commensurate with the safety functionof the component. To resolve thequalification issue, the licensee may prepare a"justification for continued operation," whiletaking corrective action. Corrective actionmay include processing a request for coderelief or preparing a cold shutdown orrefueling outage justification.

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The "operability" of the component is a design bases review, the licensee may write aseparate issue. If a licensee determines that a "justification for continued operation" for thecomponent is inoperable because of a design bases review that would describe (1)nonconforming condition, the requirements of the process for doing the programmatictechnical specification limiting conditions for review, (2) the actions to be taken uponoperation must be met. At that time, a finding a component or test that was notlicensee may determine that testing is not in previously in the IST program, (3) thethe best interest of safety and seek schedule for performing any testing needed. enforcement discretion from the NRC. This description and justification for continued

To continue to follow the GL 91-18 guidance would not apply to nonconformances foundfor nonconforming conditions while doing a outside such a process.

operability for the design bases review process

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Comments on Appendix A, Positions, Questions, Responses,

and Current Considerations Regarding Generic Letter 89-04

Question Group 7 activities on check valves may address your

Comment

The response to Question 7 under Position 1of GL 89-04 seems to suggest that criteria forcheck valves be developed in order to detectdegradation. However, the Code neither Position 2 discusses valve disassembly as anspecified, as in a manner similar to pumps and alternative to valve full-flow testing. It statespower operated valves, nor mentioned that a partial-flow test is expected to bedeveloping flow criteria for detecting check performed following reassembly. What do wevalve degradation. Furthermore, GL 89-04 do for valves that cannot be partial-flowstates "A check valve's full stroke to the open tested?position may be verified by passing themaximum required accident condition flow Response A2-1through the valve. This is considered by thestaff as an acceptable full stroke." Is it theNRC's position that the imposition of flowcriteria to detect check valve degradation is arequirement for an acceptable full-strokeexercise, and if so, is this a change in theNRC's position as stated in GL 89-04?

Response

The response to Question 7 implies that thetest be conducted in a manner that isrepeatable and with specified acceptancecriteria, perhaps based on passing a measuredflow of a certain value. To verify passingaccident flow implies an acceptance criterionbased on a measured flow, but may also bemet in alternative ways such as by monitoringa change in tank level. The NRC's responseto Question 7 addresses questions on flow ratemeasurements. The intent of the code and GL89-04 is to monitor pumps and valves fordegrading conditions. Current OM Committee

comment more fully.

Position 2

Comment A2-1

The position states that if possible, partialvalve stroking must be performed quarterly,during cold shutdowns, or after reassembly. Ifthe check valves cannot be partially stroked,that situation should be stated in thedocumentation for using Position 2 as analternative.

Comment A2-2

Some utilities have grouped valves fromdifferent units for implementing Position 2 asan alternative to full-stroke exercising withflow and may now begin to group valves fornonintrusive testing. If there is a problem withthe sample valve, all valves must be testedduring the same outage. In the case of twounits, should the other unit(s) be shut downimmediately to examine the remaining valvesin the group or can the examination bedeferred until the next refueling outage?

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Response A2-2 Response

Guidance for grouping valves from two or NRC made no modification to the applicablemore units has been added to Section 4.1. section of OM-10 when it issued the rule

Comment A2-3 and by reference, OM-10. The

The NRC should make a strongerrecommendation on the use of nonintrusivetesting over disassembly and inspection, andthe benefits that could be realized by theutilities. There should be some incentive forperforming this testing.

Response A2-3

Through participation in the Nuclear Industry question 13 does not appear to be related toCheck Valve Users' Group (NIC), the industry the question.has seen the benefits in costs savings andpersonnel exposure. Licensees have the Responseoption to disassemble and inspect when fullflow cannot be measured or attained asallowed by the NRC through Position 2, andthe OM Committee through OM-10. Operations and maintenance costs may beadequate incentive for licensees to implementnonintrusive testing where such costs savingscan be realized. The NRC recently distributeda report to all PWR licensees on a utilitysurvey by Oak Ridge National Laboratory(ORNL/NRC/LTR-94/04). The report statesthe benefits of performing nonintrusive testingof these valves.

Question Group 11

Comment

It is stated that the previous response to thisquestion is valid even though the code doesnot require an evaluation of practicality tosubstitute disassembly for other methods ofexercising. Indeed, if this is NRC policy,exception should be taken in accord with10 CFR 50.55a; otherwise, this option shouldbe available.

incorporating the 1989 Edition of Section XI,

recommendation is for good practice purposesonly and does not have the force of either theregulation or the code; therefore, the option isavailable as stated in OM-10.

Question Group 13

Comment

The "Current Considerations" section for

The section has been deleted.

Question Group 14

Comment

The statements in Section 3.1.2, and theresponse to Question 14 of GL 89-04, Position2, imply that it may be inappropriate to useLCO hours for maintenance activities whenalternatives to the LCO may exist. Does thismean that periodic maintenance programs, inwhich a safety-related component may beremoved from service for extensivemaintenance (e.g., motor replacement,overhaul, etc.), is not allowed except duringperiods in which the LCO would not beapplicable?

Response

The NRC has issued guidance on enteringLCO to perform maintenance in GL 91-18 andin NRC Inspection Manual, Part 9900.

NUREG-1482 )���

Question Group 20 Question Group 27

Comment Comment

Position 2 allows disassembly of one valve in The "Current Considerations" section shoulda four-valve sample group at every refueling state that the inclusion of PIVs [pressure-outage (18-month refuel cycle). Can the indicating valves] and verification of closuredisassembly frequency be increased to once are not required by 10 CFR 50.55a or theevery fourth refueling outage for a one-valve ASME Code.group and to once every other refuelingoutage for a two-valve group? Is relief Responserequired for this frequency or is justificationusing the criteria in Position 2 to documentthis disassembly schedule required?

Response

The frequencies discussed may be acceptable are required to close and are within the scopeusing Position 2 if conditions of "extreme of 10 CFR 50.55a. The statement suggested inhardship" apply. The justification for an the comment may mislead a licensee intoextreme hardship must be documented in the believing these valves are not required to beIST program or supporting documentation verified closed.referenced in the program documents. If theguidance in Position 2 is not met, a relief Question Group 33request may be submitted on otherjustification that would be reviewed andevaluated individually.

Question Group 26

Comment

In the context of "other means," is verification have the justification available on site is stillof check valve closure by audible valid.confirmation of check valve "slam" anacceptable means? ResponseResponse

See new Section 4.1.3 for guidance on this OM-10" was added to the section. See themethod. comments on Section 4.2.7.

The basis for this comment is not clear. If thevalves have been included in the safetyanalysis report (SAR) as capable of closing toprovide reactor coolant pressure boundaryisolation at a high/low pressure interface, they

Comment

The "Current Considerations" section shouldbe clarified. A licensee need only use the reference value "multipliers" in OM-10 forestablishing limiting values if it committed toOM-10. Otherwise the original guidance to

The phrase "when the testing is conducted per

NUREG-1482)���

Position 9 - Current Considerations corrective actions cannot be taken during the

Comment

We have three high-pressure safety injectionpumps that are tested quarterly on minimumrecirculation and full-flow tested duringrefueling outages. The technical specificationsrequire two of the three pumps to be operablefor power operations. Recently, one of thethree pumps had indications of degradinghydraulic conditions during quarterly testingand was scheduled for rebuild during therefueling outage. During the outage, a secondpump, which had no indications of degradinghydraulic or mechanical conditions onquarterly tests, demonstrated excessivevibration at full-flow test conditions. Thethird pump demonstrated acceptable operationduring both the quarterly and full-flow tests. Parts were ordered, but not received, torebuild the second pump during the outage. At the end of the outage, two pumps wereoperable and the plant could proceed tooperating conditions. The other pump wasrebuilt during power operating conditions afterreceiving the appropriate parts. Because wecould not perform the full-flow test, weperformed the minimum flow test, evaluatedthe results, and declared the pump operable. Full-flow testing will be performed during thenext refueling outage. Such actions are notdiscussed in Position 9, but we believe theseactions are appropriate because minimum flowtesting met the Code requirements beforeNRC issued Position 9. This position is usedat our plant for these pumps because flow-measuring instruments are not installed in therecirculation lines. To reduce the paperwork burden on licensees,

Response such as IST unless a number of relief requests

When testing using the guidance in Position 9,if a pump is in the alert or required actionrange, it is recommended that efforts be madeto take corrective actions during the outageand repeat the test after maintenance. When

outage (e.g., a pump needs to be rebuilt, butparts are not available), or when a pump isrepaired during power operations, testing tothe extent practical during power operationsmust be conducted in accordance with thecode requirements, after taking correctiveactions, and before returning the pump toservice. The results could be evaluated andcompared to historical results of both thequarterly testing on minimum recirculationand the full- or substantial-flow testingperformed during outages for greaterassurance. The full-flow testing must beconducted at the first opportunity when plantconditions permit.

Question Group 61

Comment

In response to Question 61, the NRC requeststhat IST programs be re-submitted each timethey are revised. The reason given for thisrequest is that "it is needed to prepare for ISTinspections and to assist in the review of reliefrequests." It has been the experience of someutilities that the inspectors and/or reviewers donot use the docketed copy of the program forthese purposes. Submittal preparation andreview become needless administrativeexercises with no apparent benefit. Substantial review costs are involved as wasthe case for program submittal under theoriginal GL 89-04.

Response

NRC supports limiting submittals of programs

or alternatives are proposed, such as when amajor provision is revised. However, it isexpected that licensees will update the ISTprogram document periodically to reflectchanges made to the plant or to the program,as necessary, and maintain the document on

NUREG-1482 )���

site for NRC review. If the staff needs a copy, NRC consideration on this issue? In thisit will make a special request. reviewer's opinion, trending may produce

Question Group 70 considering the volume of IST data collected,

Comment

Does the response to Question 70 of GL 89-04under "Other Questions" imply that approvedrelief requests must be resubmitted for reviewand approval for subsequent 10-yearprograms?

Response

Yes.

Question Group 112

Comment

The idea of trending test data has beendiscussed in IST symposiums and OMmeetings; however, it was not addressed in theNUREG-series report. What is the current

some beneficial predictive information, but

manual trending by reviewing data plots of allof the data is not practical. For one of our twounit stations, over 1800 flow, pressure,vibration, stroke time, and leakage data pointsare collected.

Response

The OM Committees are processing severalrevisions to the OM Code that addresstrending for pumps and valves. Thoughtrending is not required for IST, the NRCcontinues to believe that trending is a usefultool for various reasons. For example, withthe movement toward performance basedtesting (e.g., local-leak rate testing, checkvalves), data will soon be more important forfuture uses.

NUREG-1482)���

GENERAL COMMENTS ON OTHER ISSUES

Relief Requests of Code Noncompliance." Section 2.5 states

Comment 1

It is unclear as to which class of NRC policyrequires submittal of a request for relief. Itwould be helpful if the document provided asummary of policies set forth with anindication of the requirement for submitting arelief request.

Response 1

A relief request needs to be submitted if thealternative to the Code requirements is not inone of the following categories: (1) thealternative conforms to the guidance ofPositions 1, 2, 6, 7, 9, or 10 of Attachment 1of GL 89-04 and such conformance isdocumented in the IST Program; (2) thealternative conforms to the guidance includedin Sections 3.1.1, 3.3.2, 4.1.4, 4.2.5, 4.2.7,4.3.3, 4.3.4, 4.4.3, 4.4.5, 5.1.2, 5.3, 5.4, 5.7, or5.8 of the NUREG-series report as endorsedby GL 89-04, Supplement 1, and suchconformance is stated in the IST program; (3)the alternative conforms with a Code Caseendorsed in Regulatory Guide 1.147 with theapplication of the specific Code Case listed inthe IST program; or (4) the alternative isaddressed and allowed by specific regulationsin 10 CFR 50.55a.

Comment 2

Guidance on the appropriate action to befollowed while a relief request is beingprocessed is found in three locations, and it isconfusing and possibly conflicting. Theguidance in contained in Section 2.5, "ReliefRequests and Proposed Alternatives," Section6.3, "Revised Standard TechnicalSpecifications," and Section 7, "Identification

"For those requirements which have beendetermined to be clearly impractical, thelicensee may implement the proposedalternative testing while the NRC is reviewingthe relief request (see Section 6)." Section 6.3discusses using 10 CFR 50.59 as a mechanismfor continued operation when a Coderequirement is impractical and a code reliefrequest is being processed, providingTechnical Specification (TS) 4.0.5 has beenrevised as recommended in Section 6. Section7, on the other hand, discusses the need toobtain a Temporary Waiver of Compliancewhen a Code noncompliance exists and NRCapproval of a relief request cannot be obtainedwithin the allowable TS action time period. The NRC position should be clearly delineatedand placed in a single, separately identifiedsection of the NUREG-series report.

Response 2

Section 2.5 describes the process forsubmitting a relief request. Section 6 clarifiesthe conflict between technical specificationsand the regulatory requirements and is not "amechanism for continued operation" as notedin the comment; however, Section 6 may beuseful for situations when the operability ofequipment is not in question. Section 7 relatesto unexpected conditions that arise where theoperability of equipment could be in question. It would be inappropriate to state a singlepolicy that would apply in all situations thatmay indicate a relief request is necessary .

IST Program Plan

Comment

There is some ambiguity as to the title of theprogram submittal. It is referred to as the "IST

NUREG-1482 )���

program document," "IST Program," and "IST Responsesubmittal." It is recommended that theSection XI terminology (ProgramPlan/Schedule) be used when referring to theprogram documentation.

The "IST Program Plan/Schedule" consists ofseveral different documents including the ISTsubmittal to the NRC, the administrativeprocedures that establish how therequirements are to be implemented, the testprocedures, and the test reports. All suchdocuments constitute the "IST Program." Section 2.4 describes a document that couldbe submitted to the NRC listing allcomponents included in the program.

Preservice Testing Requirements

Comment

Section 50.55a discusses inservice testingrequirements of only pumps and valves. OM-6 and OM-10 have both preservice testrequirements and inservice test requirements. Do preservice requirements need to be meteven though not addressed by 10 CFR 50.55a?

Response

Preservice test requirements are an integralpart of an inservice testing program, especiallyin establishing baseline (reference) values forcomponents. The preservice period is theperiod after completion of constructionactivities and before first electrical generationby nuclear heat. Therefore, the period doesnot apply to operating plants. Testing thatestablishes an initial baseline for componentsinstalled in an operating plant is necessary toimplement the requirements for inservicetesting. For example, if a third train of servicewater was added to a plant, initial testingwould be done before placing the system inservice.

NUREG-1482)���

Definitions valve's performance."

Comment 1

The term operational readiness is used innumerous locations within the draft NUREG-series report. Is there now a definition for IWP-3230(c) allows analysis as correctiveoperational readiness and has the conflict action, but IWV (1986 Edition or earlier) doesbetween this term and technical specificationoperability been resolved?

Response 1

The term operational readiness is used in thecode. It is defined in IWA-9000 of the 1986Edition of Section XI as the ability of acomponent or system to perform its intendedfunction when required. The technicalspecifications define operability to include thecapability of all necessary attendantinstruments, controls, power, cooling or sealwater, lubrication or other auxiliary equipmentto support the component. IST may not testeach of these support functions in a mannerthat ensures operability. For example, a valvemay be stroked locally rather than from theinitiation point of an engineered safeguardssignal. For IST purposes, the limiting stroketime for such a valve may have to account forthe actual delay in an initiating signal foraccident response. Guidance on operability isgiven in GL 91-18 and in Part 9900 of theNRC “Inspection and Enforcement Manual.”

Comment 2

Could the Commission provide a cleardefinition of maintenance activities for valvesthat require post-maintenance testing?

Response 2

No. It is recommended that this question thatbe addressed to the OM Committee. However, examples are included in the code,and the licensee has the responsibility fordetermining if the activity "could affect the

Analysis as Corrective Action

Comment

NUREG-1482 )���

not provide for analysis as corrective action. ResponseConversely, OM-10 provides for analysis ascorrective action, but OM-6 is silent. Whencan an engineering analysis be used ascorrective action?

The use of analysis is discussed in otherresponses, but it is usually appropriate that acondition be analyzed for assurance thatdesign-basis safety limits are met. GenericLetter 91-18 also gives guidance on actions totake that include justification for continuedoperation.

NUREG-1482)���

Letters Received Submitting Public Comments on Draft NUREG-1492

Organization Date (1994)

Brookhaven National Laboratory March 1Brookhaven National Laboratory March 21Commonwealth Edison March 9Entergy Operations, Inc. March 14Idaho National Engineering Laboratory March 9Korea Institute of Nuclear Safety March 14Niagara Mohawk Power Corporation January 28Nuclear Management and Resources Council March 10Omaha Public Power District February 18Pacific Gas and Electric Company January 14PECO Energy Company March 10State of Illinois Department of Nuclear Safety March 3VECTRA Technologies, Inc. February 17

Meeting AttendeesPublic Meeting On Draft NUREG-1482

February 2 - 3, 1994

Name Telephone Number

Andre N. Anderson, Engineer (704) 382-5553Duke Power Company, General OfficePost Office Box 1006 EC0713Charlotte, NC 28201-1006

John Arhar, Licensing Engineer (415) 973-9691Pacific Gas & Electric (Diablo Canyon)333 Market Street, Room 1068San Francisco, CA

Richard Balzano, Engineer (603) 474-2923North Atlantic Energy Services (Seabrook Station)Post Office 300Seabrook, NH

NUREG-1482 )���

Joe Barlok, Senior IST Engineer (914) 734-5325Indian Point Unit 2Broadway & BleakleyBuchanan, NY 10511

Jim Barron, Supv. Test Performance (419) 321-8219Davis Besse (Toledo Edison)5501 N. State, Rt. 2Mail Stop 1056Oak Harbor, OH 43449

D. Bruce Black, Sr. Nuclear Results Eng. (904) 563-4479Florida Power (Crystal River Unit 3)15760 W. Power Line StreetCrystal River FL 34426

R. Borsum, BWNT (301) 230-2100Suite 5251700 Rockville PikeRockville, MD 20852

Byron Bradley, Sr. Performance Eng. (616) 465-5901/1586Indian Michigan PowerOne Cook PlaceBridgman, MI 49106

Joe Brozonis, IST Engineer (610) 640-6388PECo Energy Company965 Chester Brook Blvd.63C-9Wayne, PA 19087-5691

C. J. Campbell, IST Coordinator (717) 456-7014/4818PBAPS - PECo CompanyRDIDelta, PA 17314

Dennis Carlson, Tech Support Engineer (612) 388-1121/4473Northern States Power (Prairie Island)1717 Wakonade Dr EWelch, MN 55089

Dean Carstens, Prod. Engineer (612) 295-1259Northern States Power (Monticello)

NUREG-1482)���

Loretta V. Cecilia, Nuclear Project Engineer (904) 563-4546FPC/Crystal River Unit 3Power Line Rd (NAZI)Crystal River, FL 34426

Paul Cervenka, Plant Engineer (609) 971-4894GPU Nuclear (Oyster Creek)Post Box 388Forked River, NJ

Jerry McClanahan, IST Specialist (615) 751-3830Tennessee Valley AuthorityLP4F Lookout Place1101 Market StreetChattanooga, TN 37402-2801

David G. Collins, Performance Engineer (914) 736-8958New York Power Authority (Indian Point 3)P.O. Box 215Buchanan, NY 10511

David Constance, Shift Technical Advisor (504) 464-3305Entergy Operations, Inc. (Waterford 3)P.O. Box BKillona, LA 70066

Carl B. Corbin, Sr. Licensing Engineer (214) 812-8859TV Electric/Comanche PeakSkyway Tower400 Olive Street L.B. 81Dallas, TX 75201

Paul A. Croy, Sr. Engineer (714) 368-6386So. Cal. Edison (San Onofre Station)P.O. Box 128San Cemente, CA 92674-0128

John Dore, Chief Engineer (610) 376-6315United Energy Services Corp.1210 Chestnut St.Reading, PA 19602

NUREG-1482 )���

Jim Eaton, Sr. Project Manager (202) 872-1280NUMARC1776 I Street, N.W.Suite 300Washington, D.C. 20006

Mark R. Ebel, Section XI Coordinator (512) 972-7744South Texas ProjectP.O. Box 289Wadsworth, TX 77483

M. Ali Egap, IST Program Manager (315) 428-7314Niagara Mohawk Power Corp.301 Plainfield RoadSyracuse, NY 13212

Richard M. Emrath, Manager, Codes & ISI Section (615) 751-3669Tennessee Valley Authority/Corporate EngineeringLookout Place 4F1101 Market St.Chattanooga, TN 37402-2801

Mike Estes, CAPOG Member (402) 825-5236NPPD/Cooper Nuclear StationP.O. Box 95Brownville, NE 68321

Kevin L. Glandon, Sr. Engineer (205) 877-7801Southern Nuclear40 Inverness Center ParkwayP.O. Box 1295Birmingham, AL 35201

Warren J. Hall, Manager (202) 872-1280NUMARC1776 Eye Street, N.W.Suite 300Washington, D.C. 20006

Jon Hallem, Sr. Manager (407) 465-3550/3086FPL (St. Lucie)P.O. Box 128Ft. Pierce, FL 34954

NUREG-1482)���

Bernard R. Hao, Mechanical Engineer (703) 425-7743Hao Engineering Inc.10913 Hampton, Rd.FairFax Station, VA 22309

John Heffner, Production Engineer (704) 875-4093Duke Power Co. (McGuire Nuclear Station)12700 Hagens Ferry Rd.Huntersville, NC 28078

Robert Hollingsworth (415) 973-9702Pacific Gas & Electric (Diablo Canyon)

Ron Jacobstein, Consulting Engineer (407) 225-2731Technical Services for Energy2370 N.E. Ocean Blvd.Suite 304AStuart, FL 34996

F. Jape (404) 331-4178U.S. Nuclear Regulatory CommissionRegion II

Dale Jones, Manager, ISI/IST (708) 778-4312VECTRA215 Shuman Blvd.Suite 200Naperville, IL 60563

M. T. Kalman, Manager, Mech. Design (301) 258-8582NUS Corp.910 Clopper Rd.Gaithersburg, MD 20878

Frank Kaminski, IST Engineer (609) 339-2024PSE&G (Salem Generating Station)P.O. Box 236Salem Station M/C S02Hancocks Bridge, NJ 08038

Doug Kerr, Sr. Engineer (903) 894-2296Virginia Power (North Anna)P.O. Box 402Scobn Bldg.Mineral, VA 23117

John Kin, Sr. Staff Engineer (804) 273-2122

NUREG-1482 )���

Virginia PowerInnsbrook Tech Center5000 Dominion Blvd.Glen Allen, VA 23060

M. R. Knight, Licensing Engineer (717) 948-9554GPU Nuclear (TMI)P.O. Box 480Middletown, PA 17057

Harold Lefkowite, Systems Engineer (803) 885-3445Duke Power Co. (Oconee)

Brian P. Lindenlaub, IST Pump & Valve Engineer (602) 393-5251Arizona Public Service (Palo Verde Nuclear Generating Station)P.O. Box 52034, M/S 7545Phoenix, AZ 85072-2034

W. C. Liu, Project Manager, ME (301) 492-3822U.S. Nuclear Regulation CommissionWashington D.C. 20555

Charles W. Martin, ISI Engineer (203) 267-3698Connecticut Yankee Atomic Power Co.(Haddam Neck Plant)362 Injon Hollow RoadE. Hampton, CT 06424

R. B. Mays, Codes & Standards Eng. Supv. (817) 897-6816TU ElectricP.O. Box 1002Glen Rose, TX 76043

Greg Nogrady, Engineer (614) 223-1923AEPSC (Cook Nuclear Plant)One Riverside Plaza - Nuclear EngineeringColumbus, OH 43215

Howard Onorato, Senior Staff Engineer (609) 339-1488Public Service Electric & Gas CompanyP.O. Box 236Hancocks Bridge, NJ 08038

NUREG-1482)���

Robert I. Parry, Project Manager (603) 474-9521/2550North Atlantic Energy Services Corp.P.O. Box 300Seabrook, NH 03874

Joel Page, Task Manager (301) 492-3941U.S. Nuclear Regulatory CommissionWashington, D.C. 20555

Brian J. Payne, Component Engineer (215) 327-1200/3795PECO Energy (Limerick Station)P.O. Box 2300Pottstown, PA 19464

Lee Parris, Senior Staff Engineer (609) 339-5344Public Service Electric & Gas Co. (Hope Creek)P.O. Box 236, MC N32Hancocks Bridge, NJ 08038

Christopher Pendleton, Senior Engineer (805) 545-3628Pacific Gas & Electric (Diablo Canyon)P.O. Box 56Avila Beach, CA 93424

Norm Peterson, Sr. Engineer-Licensing (419) 321-8450Toledo Edison (Davis-Besse)300 Madison AvenueToledo, OH 43652

Antony A. Pfeffer, Licensing Engineer (301) 417-8816Bechtel/Search Licensing9801 Washington Blvd. 1C3 (R)Gaithersburg, MD 20878-5356

B. J. Puckett, Project Specialist (217) 935-8881/3044Illinois Power Company (Clinton Power Station)P.O. Box 678Clinton, IL 61727

Tom Raidy, Licensing Engineer (714) 454-4565SCE (San Onofre)23 Parker StreetIrvine, CA 92718

Raj Rana, Lead ASME Programs (509) 377-4313WPPS (WNP-2)P.O. Box 968 (PE 27)

NUREG-1482 )���

Richland, WA 99352

Kevin Remington, System Performance Supv. (305) 246-6528Florida Power And LightP.O. Box 3088Princeton, FL 33034

Doug Ritter, IST Engineer (717) 542-3547PP&L (Susquehanna SES)P.O. Box 467Berwick, PA 18603

Michael Robinson, Engineer (910) 295-0313EPRIP.O. Box 985Pinehurst, NC 28374

C. W. Rowley, Consultant (704) 743-2925The Wesley CorporationP.O. Box 980Cashiers, NC 28717

Thomas Ruggiero, Senior Engineer (201) 316-7308GPU - NuclearOne Upper Pond RoadParsippany, NJ 08083

Vernon C. Ruppert, Jr., Nuclear Group Inst. (717) 456-7014/4251PECo EnergyRD #1 Box 208Delta, PA 17314-9739

Joseph L. Sabiwa, Senior Program Engineer (508) 830-8030Boston Edison Company (Pilgrim Station)Rockhill RoadPlymouth, MA 02360

Rocky A. Schultz, Senior Mechanical Engineer (402) 825-5675Nebraska Public Power (Cooper Nuclear Station)P.O. Box 98Brownville, NE 68321

Randall S. Smith, Senior Lead Engineer (501) 964-8926Entergy Operations Inc. (Arkansas Nuclear One)Rt. 3 Box 137G

NUREG-1482)���

Russellville, AR 72801

David C. Stadler, Senior Engineer ISI (919) 362-2199Carolina Power & Light (Shearon Harris NPP)Harris Nuclear Project - Zone 4P.O. Box 165New Hill, NC 27562-0165

Brad Stockton, Principle Consultant (708) 778-4252Vectra Technologies, Inc.215 Shuman Blvd.Suite 200Naperville, IL 60563

Dennis Swann, Supervisor, Engineer (205) 868-5788Southern Nuclear Operating CompanyP.O. Box 1295Birmingham, AL 35201

Robert G. Vasey, Senior Engineer (614) 223-2035American Electric Power1 Riverdale PlazaColumbus, OH 43215

Joann H. West, IST Coordinator (412) 393-7552Duquesne Light (Beaver Valley)P.O. Box 4Shippingport, PA 15077

Don Zebrauskas, IST Engineer (708) 663-7377Commonwealth Edison1400 Opus PlaceSuite 400Downers Grove, IL 60515

APPENDIX H

GENERIC LETTER 89-04, SUPPLEMENT 1

UNITED STATESNUCLEAR REGUL/!TORY COMMISSION

OFFICE OF IWJCLEAR REACTOR REGULATIONWASHINGTON, D.C. 20555

April 4, 1995

NRC GENERIC LETTER 89-04, SUPPLEMENT 1: GUIDANCE ON DEVELOPING ACCEPTABLEINSERVICE TESTING PROGRAMS

Addressees

All holders of operating licenses or construction permits for nuclear powerreactors.

PurDose

The U.S. Nuclear Regulatory Commission (NRC) is issuing this generic letter tonotify addressees t+at it is issuing NUREG-1482, “Guidelines for InserviceTesting Programs at Nuclear Power Plants.” NUREG-1482 containsrecommendations that addressees may follow in developing and implementinginservice testing programs and includes the positions from Generic Letter (GL)89-04, “Guidance on Developing Acceptable Inservice Testing Programs,”supplemented with current considerations for using these positions.

Descrir)tion of Circumstances

NUREG-1482 describes historical and current perspectives on the regulatoryrequirements for inservice testing of pumps and valves in nuclear powerplants. It includes information on the format and content for inservicetesting programs and relief requests, examples of relief requests,clarification of issues described in information notices or other NRC letterson inservice testing, and current considerations for positions in GL 89-04.Many of the recommendations relate to issues that either are not addressed inthe American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel~ (the Code), were not considered in the’development of the Coderequirements, or have been identified at a group of plants that were builtprior to the promulgation of requirements for inservice testing. Beca~se thestaff has received a number of similar relief requests, the general guidancewill allow for greater efficiency in licensee preparation and the staff reviewof these submittals.

In Appendix G to the NUREG report, the staff responds to public commentsreceived on the draft NUREG-1482 published in 1993. The information has alsobeen incorporated into the text of the final NUREG as appropriate. Addresseesmay obtain copies of NUREG-1482 from the Superintendent of Documents, U.S.Government Printing Office, P.O. Box 37802, Washington, D.C. 20013-7082.

9503280042

H-1 NUREG- 1482

GL 89-04, Sllpp. iApril 4, 1995Page 2 of 3

Discussion

Addressees may use NUREG-1482 as guidance for developing 1ST programs. Theintent of the guidelines document is, in part, to provide the required“Commission approval” pursuant to 10 CFR 50.55a(f)(4)(iv) to allow licenseesto implement portions, as listed in Attachment 1, of the 1989 Edition of theASME Code incorporated in 10 CFR 50.55a(b) without further submittals offormal “relief requests.” Other portions may be used in 1ST programs subjectto receipt of specific Commission approval. No new staff interpretations areimposed on licensees. The remaining recommendations provide guidance on theinformation that should be included in relief requests and provide specificdetails for those requests that have generic applications.

Reauested Information

Licensees who voluntarily choose to use the guidance in NUREG-1482 to makeci,~nges to their inservice testing programs may need to submit revised reliefrequests or program documents to NRC if such documents are affected. Use ofthe guidance does not necessarily require any information to be submitted.

Licensees who do not modify their inservice testing programs are not expectedto submit any response to this generic letter.

Reauired ResDonse

All addressees who voluntarily choose to use the guidance in NUREG-1482 tomake changes to their inservice testing programs are required to submit aresponse to the previously requested information, if appropriate.

Address the required written reports to the U.S. Nuclear RegulatoryCommission, ATTN: Document Control Desk, Washington, O.C. 20555, under oathor affirmation under the provisions of Section 182a, Atomic Energy Act cf1954, as amended, and Section 50.54(f) of Title 10 of the Code of:aferalRegulations (10 CFR 50.54(f)).

Backfit Di-scussion

This generic letter only requests applicable information under the provisionsof 10 CFR 50.54(f) from addressees who voluntarily choose to use the guidancein NUREG-1482 to make changes to their inservice testing programs. Therefore,the staff has not performed a backfit analysis. The information requested isneeded to evaluate voluntary changes to the inservice testing programs inresponse to the information in this generic letter.

The evaluation required by 10 CFR 50.54(f) to justify this information requestis included in the preceding discussion.

Federal Reqister Notification

A notice of opportunity for public comment on this generic letter and thedraft NUREG-1482 was published in the Federal Register (58 FR 65738) on

NuREG-1482 H-2

GL 89-04, SUPP. 1April 4, 1995Page 3 of 3

December 16, 1993. In Appendix G to the NUREG report, the staff responds topublic comments received. The information has also been incorporated into thetext of the final NUREG as appropriate.

PaDerwork Reduction Act Statement

The voluntary information collections contained in this request are covered bythe Office of Management and 8udget clearance number 3150-0011, which expiresJuly31, 1997. The public reporting burden for this voluntary collection ofinformation is estimated to average 40 hours per response, including the timefor reviewing instructions, searching existing data sources, gathering andmaintaining the data needed, and completing and reviewing the collection ofinformation. Send comments regarding this burden estimate or any other aspectof this voluntary collection of information, including suggestions forreducing this burden, to the Information and Records Management 8ranch(T-6 F33), U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, and tothe Desk Officer, Office of Information and Regulatory Affairs, NEO8-102O2,(3150-0011), Office of Management and 8udget, Washington, D.C. 20503.

Compliance with the following request for information is purely voluntary.The information would assist NRC in evaluating the cost and benefits ofinservice testing program changes associated with this generic letter:

(1) the licensee staff time and costs to prepare any changes to theinservice testing program and

(2) an estimate of the long-term costs or savings accruing as a result ofimplementing any changes to the inservice testing program

If you have any questions about this matter, please contact the technicalcontact listed below or the appropriate Office of Nuclear Reactor Regulation(NRR) project manager.

~~

P

Roy P. ZimmermanAssociate Director for ProjectsOffice of Nuclear Reactor Regulation

Technical contact: Patricia Campbell, NRR301-415-1311

Lead Project Manager: Jacob Zimmerman, NRR301-415-2426

Attachments:1. Approved Code Editions, Addenda,

or Portions Thereof2. List of Recently Issued NRC Generic Letters

H-3NUREG-1 482

Attachment 1GL 89-04, Supp. 1April 4, 1995Page 1 of2

A1.wroved Code Editions. Addenda. or Portions Thereof

Section 50.55a of Title 10 of the Code of Federal Regulations (10 CFR 50.55a)defines the requirements for applying industry codes and standards to boilingor pressurized water-cooled nuclear power facilities. Each of thesefacilities is subject to the conditions in paragraphs (a), (f), and (g) ofIO CFR 50.55a for inservice inspection and inservice testing (1ST). Byrulemaking effective September 8, 1992 (see Federal Register Vol. 57, 34666),the U.S. Nuclear Regulatory Commission (NRC) established paragraph (f) toseparate the 1ST requirements from the inservice inspection requirements inparagraph (g). The American Society of Mechanical Engineers (ASME) Boiler andPressure Vessel Code (the Code), Section XI, Subsections IWP and IWV, specifythe 1ST requirements for pumps and valves. The 1989 edition of Section XI wasincorporated by reference into paragraph 50.55a(b) by the rulemaking effectiveSeptember, 1992. The 1989 edition specifies that the rules for the 1ST ofpumps and valves are stated in the ASME/ANSI Operations and Maintenance {OM).Standards, Part 6, “Inservice Testing of Pumps in Light-Water Reactor PowerPlants,” and Part 10, “Inservice Testing of Valves in Light-Water ReactorPower Plants.” An exception to OM-10 was taken in the regulation related toleakage testing of containment isolation valves (see 10 CFR 50.55a(b)(2) (vii).

NUREG-1482, “Guidelines for Inservice Testing at Nuclear Power Plants,”discusses OM-6 and OM-10, which may be implemented by licensees pursuant to10 CFR 50.55a (f)(4)(iv). NUREG-1482, through the staff’s endorsement in thegeneric letter supplement, gives the requisite approval for 10 CFR 50.55a(f)(4) (iv) for updating an 1ST program to the requirements of OM-6 and OM-10(and OM-1 through reference in OM-10) provided the licensee documents the useof OM-6 and OM-10 in the 1ST program. The NUREG, through the generic lettersupplement per (f)(4)(iv), also gives approval to implement selected portionsof OM-6 and OM-10 as discussed in the following sections of NUREG-1482:

3.1.1 Deferring Valve Testing to Cold Shutdown or Refueling Outage

3.3.2 Concurrent Intervals (in part)

4.1.4 Extension of Test Interval to Refueling Outage for Check ValvesVerified Closed by Leak Testing

4.2.5 Verification of Remote Position Indication for Valves by MethodsOther Than Direct Observation

4.2.7 Stroke Time Measurements Using Reference Values

4,3.3 Test Supervisor Qualifications

NUREG-1482 H-4

Attachment 1GL 89-04, Sllpf). 1April 4, 1995Page 2 of 2

4.3.4 Frequency and Method of Testing Automatic Depressurization Valvesin Boiling Water Reactors

4.4.3 Multiple Containment Isolation Valve Leak-Rate Testing

4.4.5 Leak-Rate Testing Using OM-10 Requirements

5.1.2 Continued Measurement of Parameters Deleted from OM-6

5.3 Allowable Variance from Reference (for fixed resistance systems)

5.4 Monitoring Pump Vibration Per OH-6

5.7 Use of OM-6 Table 3b Ranges for Hydraulic Parameters

5.8 Duration of Tests

H-5 NUREG-1482

Attachment 2GL 89-04, Supp. 1April 4, 1995Page 1 of 1

LIST OF RECENTLY ISSUED GENERIC LETTERS

GenericLetter Sub.iect

95-01 NRC STAFF TECHNICAL POSI-TION ON FIRE PROTECTIONFOR FUEL CYCLE FACILITIES

94-04 VOLUNTARY REPORTING OFADDITIONAL OCCUPATIONALRADIATION EXPOSURE DATA

94-03

94-02

94-01

INTERGRANULAR STRESSCORROSION CRACKING OF CORESHROUDS IN BOILING WATER

LONG-TERM SOLUTIONS ANDUPGRADE OF INTERIMOPERATING RECOMMENDATIONSFOR THERMAL-HYDRAULICINSTABILITIES IN BOILINGWATER REACTORS

REMOVAL OF ACCELERATEDTESTING AND SPECIAL RE-PORTING REQUIREMENTS FOREMERGENCY DIESEL GENERATORS

Date ofIssuance Issued To

01/26/95 ALL CURRENT LICENSEES& APPLICANTS FOR URANIUMCONVERSION & FUELFABRICATION FACILITIES.

09/02/94 ALL HOLDERS OF OLS OR CPSFOR NPRs, RADIOGRAPHYLICENSEES, FUEL PROCES-SING LICENSEES, FABRICA-TING & REPROCESSINGLICENSEES, MANUFACTURERS& DIST~.IBUTORS OF BY-PRODUCT MAT’L, INDEPEND-ENT SPENT FUEL STORAGEINSTALLATIONS, FACILITIESFOR LAND DISPOSAL OF LOW-LEVEL WASTE, & GEOLOGICREPOSITORIES FOR HIGH-LEVEL WASTE.

07/22/94 ALL HOLDERS OF OLS OR CPSFOR BOILING WATERREACTORS EXCEPT FOR BIGROCK POINT, WHICH DOESNOT HAVE A CORE SHROUD.

07/11/94 ALL HOLDERS OF OLS FORBOILING WATER REACTORSEXCEPT BIG ROCK POINT

05/31/94 ALL HOLDERS OF OLS FORNPRs

OL = OPERATING LICENSECP = CONSTRUCTION PERMITNPR = NUCLEAR POWER REACTORS

NUREG-1482 H-6