1 ISTOG QUESTIONS –2007 1. 5-YR Frequency of Class 1 Relief Valves A Nuclear Station has three class 1 safety valves. A Nuclear Station has three class.

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ISTOG QUESTIONS –2007ISTOG QUESTIONS –20071. 5-YR Frequency of Class 1 Relief Valves1. 5-YR Frequency of Class 1 Relief Valves

A Nuclear Station has three class 1 safety valves. A Nuclear Station has three class 1 safety valves.

To meet the code, one safety valve is typically sent offsite To meet the code, one safety valve is typically sent offsite each refueling outage, tested, refurbished, sent back, and re-each refueling outage, tested, refurbished, sent back, and re-installed. installed.

The NPP typically has 18 month refueling outage frequencies. The NPP typically has 18 month refueling outage frequencies. However, due to some shifts in scheduling, our next However, due to some shifts in scheduling, our next scheduled refueling outage (April of 2008) places the scheduled refueling outage (April of 2008) places the individual safety valve selected for this outage at over 5 individual safety valve selected for this outage at over 5 years (5 years plus approximately one month). years (5 years plus approximately one month).

We are currently required to follow the 2003 Addenda to the We are currently required to follow the 2003 Addenda to the 2001 Edition of the Code. 2001 Edition of the Code.

Our Technical Specifications require the testing of these Our Technical Specifications require the testing of these valves to be per the IST Program. valves to be per the IST Program.

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ISTOG QUESTIONS –2007ISTOG QUESTIONS –20071. 5-YR Frequency of Class 1 Relief Valves1. 5-YR Frequency of Class 1 Relief Valves

Our code of record requires that any individual valve shall not Our code of record requires that any individual valve shall not exceed 5 years. exceed 5 years.

Our Technical Specifications allow IST frequencies of 2 years Our Technical Specifications allow IST frequencies of 2 years or less to have a grace period of 1.25 times the frequency, if or less to have a grace period of 1.25 times the frequency, if necessary. necessary.

NUREG 1482, Revision 1, section 3.1.3, states "However, NUREG 1482, Revision 1, section 3.1.3, states "However, licensees should not extend the test intervals for safety and licensees should not extend the test intervals for safety and relief valves defined in Appendix I to the OM Code, other than relief valves defined in Appendix I to the OM Code, other than to coincide with a refueling outage….“to coincide with a refueling outage….“

A preliminary look by our Licensing Department is that we will A preliminary look by our Licensing Department is that we will have to submit a relief request to the NRC for approval. I am have to submit a relief request to the NRC for approval. I am looking for input from the industry on this subject.looking for input from the industry on this subject.

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ISTOG QUESTIONS –2007ISTOG QUESTIONS –20071.1. 5-YR Frequency of Class 1 Relief Valves5-YR Frequency of Class 1 Relief Valves

1. Are we required to obtain NRC approval to perform the 1. Are we required to obtain NRC approval to perform the safety valve test at just over 5 years to make it to the safety valve test at just over 5 years to make it to the refueling outage?refueling outage?

2. Has anyone invoked this NUREG 1482 position at their 2. Has anyone invoked this NUREG 1482 position at their plant?plant?

NRC Question 1:NRC Question 1:

Can the five years (or ten years) for relief valve testing as Can the five years (or ten years) for relief valve testing as stated in the OM Code Appendix I 1998 and later be stated in the OM Code Appendix I 1998 and later be exceeded without relief?exceeded without relief?

Are you allowed to exceed the five (ten) years as a result of Are you allowed to exceed the five (ten) years as a result of the refueling outage frequency being changed if, the relief the refueling outage frequency being changed if, the relief valve’s original schedule was within the Code interval? valve’s original schedule was within the Code interval?

Would this require relief (exigent or otherwise) or just Would this require relief (exigent or otherwise) or just notification to the NRC?notification to the NRC?

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ISTOG QUESTIONS –2007ISTOG QUESTIONS –20072. AFW Flow Instrumentation When on Miniflow2. AFW Flow Instrumentation When on Miniflow

NPP utilizes the 1998 ed of the ASME O&M Code with the 1999 NPP utilizes the 1998 ed of the ASME O&M Code with the 1999 and 2000 addenda. and 2000 addenda.

The auxiliary feedwater pumps are run on miniflow to the The auxiliary feedwater pumps are run on miniflow to the condensate storage tank during quarterly IST's. condensate storage tank during quarterly IST's.

The miniflow line has a multistage orifice to provide a fixed The miniflow line has a multistage orifice to provide a fixed flow resistance and flow. flow resistance and flow.

Flow is assumed constant based upon the manufacturer Flow is assumed constant based upon the manufacturer supplied orifice flow curve and pump differential pressure is supplied orifice flow curve and pump differential pressure is measured. measured.

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No permanent plant flow instrumentation was installed on the No permanent plant flow instrumentation was installed on the miniflow line. miniflow line.

During the initial ten year IST interval and subsequent ten year During the initial ten year IST interval and subsequent ten year updates, the NRC has granted relief for this lack of updates, the NRC has granted relief for this lack of instrumentation. instrumentation.

NPP is considering installation of flow instrumentation due to NPP is considering installation of flow instrumentation due to concerns about orifice blockage or erosion, pump damage if concerns about orifice blockage or erosion, pump damage if orifice should become blocked and uncertainty of future relief orifice should become blocked and uncertainty of future relief request approvals. request approvals.

The following questions are submitted for industry peer input: The following questions are submitted for industry peer input:

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1. Does your plant have instrumented flow instrumentation for 1. Does your plant have instrumented flow instrumentation for auxiliary feedwater or similar pumps when on miniflow? auxiliary feedwater or similar pumps when on miniflow?

2. Was your plant refused relief during initial IST program 2. Was your plant refused relief during initial IST program submittal or subsequent updates for lack of flow submittal or subsequent updates for lack of flow instrumentation for auxiliary feedwater pumps or other IST instrumentation for auxiliary feedwater pumps or other IST pumps? If so, please provide approximation of when relief pumps? If so, please provide approximation of when relief was requested and denied. was requested and denied.


Is relief being given for non-instrumented minimum recirc Is relief being given for non-instrumented minimum recirc lines (as was provided in GL 89-04, position? lines (as was provided in GL 89-04, position?

Is relief required if, per the Code 1998 Ed and later, it Is relief required if, per the Code 1998 Ed and later, it appears that you do not need to FIX a parameter?appears that you do not need to FIX a parameter?

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ISTOG QUESTIONS –2007ISTOG QUESTIONS –20073. AOV Issue3. AOV Issue During our refuel outage in March of this year the actuators During our refuel outage in March of this year the actuators were rebuilt and the packing adjusted (packing load was were rebuilt and the packing adjusted (packing load was increased due toincreased due tohistory of packing leaks) for our Reactor Recirc Pump seal history of packing leaks) for our Reactor Recirc Pump seal cooling supply isolation valves (CV1804A an CV1804B). cooling supply isolation valves (CV1804A an CV1804B).

Post maintenance stroke time for CV1804A was 3.22 seconds Post maintenance stroke time for CV1804A was 3.22 seconds and 3.19 seconds for CV1804B without system pressure which and 3.19 seconds for CV1804B without system pressure which is about 1500 psi. The reference stroke time for CV1804A is is about 1500 psi. The reference stroke time for CV1804A is 3.0 seconds and for CV0804B 3.4 seconds. 3.0 seconds and for CV0804B 3.4 seconds.

Since the outage, the stroke time for both valves has Since the outage, the stroke time for both valves has increased to near their upper IST limits as follows:increased to near their upper IST limits as follows:

CV1804ACV1804A CV1804BCV1804B3/8/07 3.22 3.193/8/07 3.22 3.195/2/07 3.84 3.855/2/07 3.84 3.858/2/07 4.17 4.978/2/07 4.17 4.97

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ISTOG QUESTIONS –2007ISTOG QUESTIONS –20073. AOV Issue3. AOV Issue The limiting value for full stroke is 4.5 seconds for CV1804A The limiting value for full stroke is 4.5 seconds for CV1804A and 5 seconds for CV1804B, which is the same as the and 5 seconds for CV1804B, which is the same as the acceptance criteria. acceptance criteria. These are 3/4 inch category A valves with a safety function to These are 3/4 inch category A valves with a safety function to close for primary containment isolation. close for primary containment isolation.

Average stoke time over the past 12 years has been very Average stoke time over the past 12 years has been very close to the reference value for both valves with variation of close to the reference value for both valves with variation of about .+/- 0.3 seconds.about .+/- 0.3 seconds.

Doing maintenance online is impractical due to the manual Doing maintenance online is impractical due to the manual isolation valve being inside the primary containment. isolation valve being inside the primary containment.

An LLRT, if required, would also be impractical due to the An LLRT, if required, would also be impractical due to the location of the isolation valve.location of the isolation valve.

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ISTOG QUESTIONS –2007ISTOG QUESTIONS –20073. AOV Issue3. AOV Issue We think that we can explain the increase in the first stroke We think that we can explain the increase in the first stroke time after the outage, increased packing load and system time after the outage, increased packing load and system pressure. However, we are struggling with explaining the pressure. However, we are struggling with explaining the second increase in stroke time. Any insight that you could second increase in stroke time. Any insight that you could provide on the second increase in stroke time would be provide on the second increase in stroke time would be welcomed.welcomed.

Also, our AOV engineer and I&C Supervisor recommend cycling Also, our AOV engineer and I&C Supervisor recommend cycling one of the valves as part of the troubleshooting. If we were to one of the valves as part of the troubleshooting. If we were to do this and the stroke time exceeds the acceptance criteria do do this and the stroke time exceeds the acceptance criteria do we declare the valve inoperable? My first thought is yes. What we declare the valve inoperable? My first thought is yes. What do you all think?do you all think?

So, we are basically looking for options to address the issue So, we are basically looking for options to address the issue with these two valves. Any insight that you can provide would with these two valves. Any insight that you can provide would be appreciated.be appreciated.


Any insight that you can provide for the above?Any insight that you can provide for the above?

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ISTOG QUESTIONS –2007ISTOG QUESTIONS –20074. BWR's - NRC Concerns with HPCI IST Criteria4. BWR's - NRC Concerns with HPCI IST Criteria NPP recently had an NRC CDBI inspection that included NPP recently had an NRC CDBI inspection that included review of HPCI pump/turbine testing relative to design basis review of HPCI pump/turbine testing relative to design basis versus ASME based IST and NUREG-1482 requirements. versus ASME based IST and NUREG-1482 requirements.

The bottom line is that we needed to do more extensive The bottom line is that we needed to do more extensive instrument tolerance analysis for the inspection than was instrument tolerance analysis for the inspection than was previously done, especially including speed limiter tolerance previously done, especially including speed limiter tolerance and flowmeter orifice uncertainties, to show that the IST and flowmeter orifice uncertainties, to show that the IST procedure did not have LTA acceptance criteria or allow procedure did not have LTA acceptance criteria or allow performance below the HPCI design requirements. performance below the HPCI design requirements.

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ISTOG QUESTIONS –2007ISTOG QUESTIONS –20074.4. BWR's - NRC Concerns with HPCI IST CriteriaBWR's - NRC Concerns with HPCI IST Criteria

The OS trip setpoint is 5000 rpm. We have a design The OS trip setpoint is 5000 rpm. We have a design requirement of 5000 gpm injected at a discharge pressure of requirement of 5000 gpm injected at a discharge pressure of SRV setting (plus tolerance), plus discharge piping head loss. SRV setting (plus tolerance), plus discharge piping head loss.

(Another "heads-up": We were also highly challenged due to (Another "heads-up": We were also highly challenged due to the BJ DVS12x14x23 booster pump impeller change out in the the BJ DVS12x14x23 booster pump impeller change out in the middle 1980's. I am led to believe this was a common change middle 1980's. I am led to believe this was a common change in the industry. This left us with booster pump curves that in the industry. This left us with booster pump curves that were not certified since the casing was not sent back for were not certified since the casing was not sent back for testing. However, we eventually beat that issue back and it testing. However, we eventually beat that issue back and it was dropped.)was dropped.)

I don't know if our flow/speed controls are the same, but ours I don't know if our flow/speed controls are the same, but ours essentially tries to meet a flow demand by varying pump essentially tries to meet a flow demand by varying pump speed, subject to maximum speed being limited to 4100 rpm speed, subject to maximum speed being limited to 4100 rpm (nominal). (nominal).

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ISTOG QUESTIONS –2007ISTOG QUESTIONS –20074. BWR's - NRC Concerns with HPCI IST Criteria4. BWR's - NRC Concerns with HPCI IST Criteria

Back to instrument tolerances, some engineers here pointed Back to instrument tolerances, some engineers here pointed to the fact that GE has stated numerous times that the HPCI to the fact that GE has stated numerous times that the HPCI design includes sufficient margin to cover instrument error, design includes sufficient margin to cover instrument error, and so tolerances do not need to be incorporated in testing. and so tolerances do not need to be incorporated in testing. However, this view is inconsistent with DEMONSTRATION that However, this view is inconsistent with DEMONSTRATION that the design is met, and did not seem to have any merit at all the design is met, and did not seem to have any merit at all with the NRC inspectors. with the NRC inspectors.

Factoring in all the instrument tolerances, and backfitting our Factoring in all the instrument tolerances, and backfitting our past HPCI test results, we showed operability, but with much past HPCI test results, we showed operability, but with much less margin that desired. I have an action to improve our less margin that desired. I have an action to improve our margin before restart from RF12 in the last week of this margin before restart from RF12 in the last week of this October.October.

I spoke with GE briefly to inquire about the feasibility of I spoke with GE briefly to inquire about the feasibility of increasing the turbine speed limiter by 100 rpm or so, for a 5% increasing the turbine speed limiter by 100 rpm or so, for a 5% discharge pressure margin gain. I was told that it might be discharge pressure margin gain. I was told that it might be feasible in the time frame I need if anyone else already has a feasible in the time frame I need if anyone else already has a higher speed. higher speed.

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ISTOG QUESTIONS –2007ISTOG QUESTIONS –20074. BWR's - NRC Concerns with HPCI IST Criteria4. BWR's - NRC Concerns with HPCI IST Criteria I would also like to know if you think we are in left field by I would also like to know if you think we are in left field by incorporating speed control tolerance in the analysis for incorporating speed control tolerance in the analysis for maximum allowable pump degradation. (Note: we have the maximum allowable pump degradation. (Note: we have the same issues with RCIC, but margins are better)same issues with RCIC, but margins are better)

NPP requests feedback on the following questions (please read NPP requests feedback on the following questions (please read the explanation text below for the context of these questions). the explanation text below for the context of these questions).

What are your HPCI speed limiter and overspeed trip What are your HPCI speed limiter and overspeed trip setpoints?setpoints?

Do you consider instrument tolerances, Do you consider instrument tolerances, includingincluding speed speed controller error, in your IST acceptance criteria? For flow controller error, in your IST acceptance criteria? For flow measurement accuracy, do you include any uncertainty for the measurement accuracy, do you include any uncertainty for the flow element / orifice?flow element / orifice?

NRC Question 4:NRC Question 4: Would the NRC consider the instrument error for instrument Would the NRC consider the instrument error for instrument tolerances to include the speed controller error or, would this tolerances to include the speed controller error or, would this be covered under the IN 97-90 for “design” inclusion? be covered under the IN 97-90 for “design” inclusion?

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ISTOG QUESTIONS –2007ISTOG QUESTIONS –20075. Category A Designation for Feedwater Isolation 5. Category A Designation for Feedwater Isolation ValvesValves

NPP requests feedback on the Comprehensive Pump Test NPP requests feedback on the Comprehensive Pump Test InstrumentInstrument

issues: issues:

1.1. For those stations who have gone to comprehensive For those stations who have gone to comprehensive pumppumptesting, what has been your experience with the new testing, what has been your experience with the new

+/- 0.5%+/- 0.5%pressure instrument accuracy requirements?pressure instrument accuracy requirements?

2.2. Did you use existing plant instrumentation, previouslyDid you use existing plant instrumentation, previouslycalibrated to 2%, and now calibrate it to the tighter calibrated to 2%, and now calibrate it to the tighter

range? range?

3.3. Do you do pre and post calibrations around the Do you do pre and post calibrations around the comprehensivecomprehensivepump test to assure the instrument is demonstrated to pump test to assure the instrument is demonstrated to

bebewithin range during the test? If not, what is your within range during the test? If not, what is your

calibrationcalibrationfrequency? frequency?

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ISTOG QUESTIONS –2007ISTOG QUESTIONS –20075. Category A Designation for Feedwater Isolation 5. Category A Designation for Feedwater Isolation ValvesValves

4.4. Do you have any pumps to where you have differential Do you have any pumps to where you have differential pressure as the set value? pressure as the set value?

5.5. If so, what is you experience in meeting the +/- 0.5% If so, what is you experience in meeting the +/- 0.5% set range (ref. new draft NUREG 1482, Section 5.3)? set range (ref. new draft NUREG 1482, Section 5.3)?

6.6. What is your experience with instrumentation What is your experience with instrumentation fluctuations in trying to achieve the set value? fluctuations in trying to achieve the set value?


Has the NRC given any more consideration to relaxing the Has the NRC given any more consideration to relaxing the upper limit for CPT of 3% by approval of a relief request?upper limit for CPT of 3% by approval of a relief request?

Also has the NRC given any relief approval for the use of 0.5% Also has the NRC given any relief approval for the use of 0.5%

gages for pressure? Any examples?gages for pressure? Any examples?

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ISTOG QUESTIONS –2007ISTOG QUESTIONS –20076. Cooling Water/Service Water Pumps6. Cooling Water/Service Water Pumps

1.1. Do your emergency safeguards pumps run Do your emergency safeguards pumps run continuously or are they Cat B Pumps? continuously or are they Cat B Pumps?

2.2. How many Safeguards Cooling Water pumps do you How many Safeguards Cooling Water pumps do you have per unit? have per unit?

3.3. How often are your pumps refurbished? How often are your pumps refurbished? (overhauled/impellers replaced?) (overhauled/impellers replaced?)

4.4. Are the pumps in a severe service environment? (e.g. Are the pumps in a severe service environment? (e.g. a lot of sand or silt in the water?) a lot of sand or silt in the water?)

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ISTOG QUESTIONS –2007ISTOG QUESTIONS –20076. Cooling Water/Service Water Pumps6. Cooling Water/Service Water Pumps

NRC Question 6:NRC Question 6: Would the NRC consider pumps that are ONLY operated (from Would the NRC consider pumps that are ONLY operated (from a convenience standpoint) routinely operated pumps and a convenience standpoint) routinely operated pumps and require that they be classified as Group A? require that they be classified as Group A?

(Typically this involves the HPSI pumps being used to “fill” the (Typically this involves the HPSI pumps being used to “fill” the SITs.)SITs.)

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ISTOG QUESTIONS –2007ISTOG QUESTIONS –20077. IST Program Question on Diesel Starting Air Skid 7. IST Program Question on Diesel Starting Air Skid

CheckCheckValvesValves

During a replacement of the starting air pressure controlDuring a replacement of the starting air pressure controlvalves (PCVs) that reduce pressure from 250 psig to 125 psigvalves (PCVs) that reduce pressure from 250 psig to 125 psigfor use in the starting and over-speed interlocks on ourfor use in the starting and over-speed interlocks on ouremergency diesel generator 4, both the right and left bankemergency diesel generator 4, both the right and left bankPCVs were found installed backwards. PCVs were found installed backwards.

These are ball type check valves associated with the PCVsThese are ball type check valves associated with the PCVswhich are utilized to bleed back pressure to the inlet of thewhich are utilized to bleed back pressure to the inlet of thePCVs and back to the air header. PCVs and back to the air header.

The right bank check valve was found installed backwards asThe right bank check valve was found installed backwards aswell. Further investigation found that this condition has beenwell. Further investigation found that this condition has beenthis way since first installed. this way since first installed.

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ISTOG QUESTIONS –2007ISTOG QUESTIONS –20077. IST Program Question on Diesel Starting Air Skid 7. IST Program Question on Diesel Starting Air Skid Check ValvesCheck Valves

This led the NRC to question, why this condition was not found This led the NRC to question, why this condition was not found before?before? Are these check valves in theAre these check valves in the IST program IST program and if not, should and if not, should they be?they be?

I am aware that NPP and NPP are the only plants with the I am aware that NPP and NPP are the only plants with the same manufactured type diesel system, Nordberg, but I am same manufactured type diesel system, Nordberg, but I am hoping that others may have diesels with pneumatic starting hoping that others may have diesels with pneumatic starting air systems with these PCVs and check valves on a skid. air systems with these PCVs and check valves on a skid.

Hence my question, Do you have these check valves in yourHence my question, Do you have these check valves in yourIST program? If not, how did you justify exclusion? If so, areIST program? If not, how did you justify exclusion? If so, arethey in your augmented program?they in your augmented program?

NRC Question 7:NRC Question 7: Would these check valves be required to be in the IST Would these check valves be required to be in the IST Program? Program?

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ISTOG QUESTIONS –2007ISTOG QUESTIONS –20078. Drywell Purge and Vent Valves8. Drywell Purge and Vent Valves

NPP has 24in M.O. butterfly valves as Inbd Cont Isol valves on NPP has 24in M.O. butterfly valves as Inbd Cont Isol valves on ourour

Drywell N2 Purge and Vent penetrations.Drywell N2 Purge and Vent penetrations.

Our Tech Specs require LLRT every 6 months and/or withinOur Tech Specs require LLRT every 6 months and/or within

92 days following a valve stroke. These are normally closed 92 days following a valve stroke. These are normally closed valves,valves,

safety function to remain closed, stroke time tested onlysafety function to remain closed, stroke time tested only

during Cold S/D. Our Drywell is maintained N2 inertedduring Cold S/D. Our Drywell is maintained N2 inerted

during operation. during operation.

Operators would only open them by choice during postOperators would only open them by choice during post

accident recovery phase. For many years NPP has tested accident recovery phase. For many years NPP has tested these valvesthese valves

online every 6 months AND every RFO. online every 6 months AND every RFO.

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ISTOG QUESTIONS –2007ISTOG QUESTIONS –20078. Drywell Purge and Vent Valves8. Drywell Purge and Vent Valves

We are considering a change to testing only online every 6 We are considering a change to testing only online every 6 monthsmonths

and would appreciate responses to the following questions and would appreciate responses to the following questions for yourfor your

equivalent valves:equivalent valves:

1.1. Do you perform online LLRT of these valves? If so, do Do you perform online LLRT of these valves? If so, do you also perform scheduled LLRTs during RFOs? you also perform scheduled LLRTs during RFOs?

2.2. Have you made (or considered making) a change to Have you made (or considered making) a change to LLRT schedule similar to what we are planning?LLRT schedule similar to what we are planning?

3.3. How often do you stroke test these valves? How often do you stroke test these valves?

4.4. Do you utilize a CSJ for these stroke tests?Do you utilize a CSJ for these stroke tests?

NRC Question 8:NRC Question 8: Would the NRC consider the justification for testing these Would the NRC consider the justification for testing these

valves atvalves atCSJ to be acceptable?CSJ to be acceptable?

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ISTOG QUESTIONS –2007ISTOG QUESTIONS –20079. Experience Stopping Packing Leak without 9. Experience Stopping Packing Leak without Performing PMTPerforming PMT

We have an MOV that is stroke time tested closed at a cold We have an MOV that is stroke time tested closed at a cold shutdown frequency that has developed a packing leak shutdown frequency that has developed a packing leak while in the open position (online).while in the open position (online).

In our case, electrically, the valve would be 8% off of theIn our case, electrically, the valve would be 8% off of the

backseat. The valve would be taken to manual and fully backseat. The valve would be taken to manual and fully opened. opened.

The affect on the closing stroke time would be estimated The affect on the closing stroke time would be estimated and it would be well within the design basis stroke time.and it would be well within the design basis stroke time.

2323

ISTOG QUESTIONS –2007ISTOG QUESTIONS –20079. Experience Stopping Packing Leak without 9. Experience Stopping Packing Leak without Performing PMTPerforming PMT

Alternatively, an option may be to tighten packing nuts toAlternatively, an option may be to tighten packing nuts to

a torque value that was previously obtained from a past a torque value that was previously obtained from a past work order,work order,

which would give a basis that the valve should stroke in a which would give a basis that the valve should stroke in a similarsimilar

time. time.

Has anyone justified taking a valve manually to the Has anyone justified taking a valve manually to the backseat to attempt to stop a packing leak without backseat to attempt to stop a packing leak without performing a post-maintenance stroke time test?performing a post-maintenance stroke time test?


Would the NRC consider this an acceptable practice?Would the NRC consider this an acceptable practice?

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ISTOG QUESTIONS –2007ISTOG QUESTIONS –200710. Failed Valve Stroke Time10. Failed Valve Stroke Time

At NPP we have an air operated valve that was repacked in At NPP we have an air operated valve that was repacked in Feb 2007 during our last RFO. Feb 2007 during our last RFO.

The valve was stroked closed in 3.13 sec during post The valve was stroked closed in 3.13 sec during post maintenance testing (reference value is 2.87 sec). maintenance testing (reference value is 2.87 sec).

During the next quarterly test the valve initially stroked in During the next quarterly test the valve initially stroked in 4.5 sec which is outside the upper acceptance criteria of 4.3 4.5 sec which is outside the upper acceptance criteria of 4.3 second (this valve does not have a limiting value). second (this valve does not have a limiting value).

The valve stroked a second time in 3.14 seconds. The valve stroked a second time in 3.14 seconds.

ISTC-5115 states that we can accept the second stroke time ISTC-5115 states that we can accept the second stroke time providing we can explain the initial deviation. However, no providing we can explain the initial deviation. However, no such explanation is revealing itself.such explanation is revealing itself.

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ISTOG QUESTIONS –2007ISTOG QUESTIONS –200710. Failed Valve Stroke Time10. Failed Valve Stroke Time

This valve is normally open during the quarterly test and This valve is normally open during the quarterly test and stroked closed and timed and then reopened. During this stroked closed and timed and then reopened. During this most recent test the valve was closed and de-energized most recent test the valve was closed and de-energized because its partner isolation valve had also failed its stroke because its partner isolation valve had also failed its stroke time (a whole other story). The valve was re-energized time (a whole other story). The valve was re-energized opened and then timed closed which is when it failed its opened and then timed closed which is when it failed its stroke time. stroke time.

1.1. Any suggestions on resolving this situation?Any suggestions on resolving this situation?

2.2. Also what criteria do you use for when to re-Also what criteria do you use for when to re-baseline valve stroke times?baseline valve stroke times?


Is it the NRC’s position that ALL power operated valves in Is it the NRC’s position that ALL power operated valves in the IST Program require that a Limiting Value of Full Stroke the IST Program require that a Limiting Value of Full Stroke Time be established?Time be established?

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ISTOG QUESTIONS –2007ISTOG QUESTIONS –200711. IST Instrumentation11. IST Instrumentation

Questions pertaining to use of permanent plant Questions pertaining to use of permanent plant instruments:instruments:

For the dozen or so of these instruments we use for IST we For the dozen or so of these instruments we use for IST we have an existing evaluation that lists the instrument have an existing evaluation that lists the instrument accuracy. accuracy.

For instance, one flow instrument is listed with an accuracy For instance, one flow instrument is listed with an accuracy of +/- 1% (of +/- 1% (flow transmitter feeding analog flow indicator in flow transmitter feeding analog flow indicator in the control room).the control room).

When I look closely at it's instrument calibration spec sheets When I look closely at it's instrument calibration spec sheets there is an allowed as found tolerance band of 0.95% at full there is an allowed as found tolerance band of 0.95% at full scale ( 100% scale is 9150 GPM and cal tolerance range is scale ( 100% scale is 9150 GPM and cal tolerance range is 9063 - 9237). 9063 - 9237).

However, our typical IST measurement is around 6200 GPM. However, our typical IST measurement is around 6200 GPM. At the calibration cardinal point of 6000 GPM the cal At the calibration cardinal point of 6000 GPM the cal tolerance range is 5868-6132, or +/- 2.2%. tolerance range is 5868-6132, or +/- 2.2%.

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The actual loop accuracy is not linear down from 100% scale,The actual loop accuracy is not linear down from 100% scale,it is logarithmic. At the lowest cardinal point of 2000 GPM theit is logarithmic. At the lowest cardinal point of 2000 GPM theacceptable readings are 1634-2366, or +/- 18.3%.acceptable readings are 1634-2366, or +/- 18.3%.

I have been given to understand that this is industry standardI have been given to understand that this is industry standardcalibration methodology and that accuracy of better than 2%calibration methodology and that accuracy of better than 2%of full scaleof full scale is what the Code requires - not accuracy of +/- is what the Code requires - not accuracy of +/-2% 2% of readingof reading. .

The Code does say that 2% of full scale is acceptable for The Code does say that 2% of full scale is acceptable for individualindividual

analog instruments.analog instruments.

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1.1. Does this type of flow instrument described above Does this type of flow instrument described above classify as an "individual analog instrument"?classify as an "individual analog instrument"?

2.2. For combinations of instruments (loop accuracy) is the For combinations of instruments (loop accuracy) is the Code criteria applicable as 2% of full scale or 2% of Code criteria applicable as 2% of full scale or 2% of reading?reading?


How does the NRC determine if an instrument is analog orHow does the NRC determine if an instrument is analog ordigital? digital?

Is it based on the “output” device (i.e. if the gage or meter is Is it based on the “output” device (i.e. if the gage or meter is analog,analog,

then the instrument is analog)?then the instrument is analog)?

2929


NRC Question 11:NRC Question 11: Is it based on the “input” device (i.e. if the transmitter is Is it based on the “input” device (i.e. if the transmitter is digital thendigital thenthe instrument is digital)?the instrument is digital)?

If a suction and discharge pressure gages are used to If a suction and discharge pressure gages are used to determine the differential pressure of a pump, do we need to determine the differential pressure of a pump, do we need to add the inaccuracies of each of the gages together using the add the inaccuracies of each of the gages together using the Square Root Sum of the Squares (SRSS) method or, can we Square Root Sum of the Squares (SRSS) method or, can we just consider the individual instruments solely on the bases of just consider the individual instruments solely on the bases of each instrument satisfying the Code instrument tolerance each instrument satisfying the Code instrument tolerance requirements of +/- 2%?requirements of +/- 2%?

If you use multiple flow instruments to determine the “total” If you use multiple flow instruments to determine the “total” flow, do you need to use the SRSS method to determine total flow, do you need to use the SRSS method to determine total instrument inaccuracy?instrument inaccuracy?

3030

ISTOG QUESTIONS –2007ISTOG QUESTIONS –200712. Mode Change Checklist Question12. Mode Change Checklist Question

I am interested in how other plants make sure that all required I am interested in how other plants make sure that all required IST tests have been performed when the plant is getting ready IST tests have been performed when the plant is getting ready to change modes at the end of an outage.to change modes at the end of an outage.

At NPP, each department has a mode change checklist listing At NPP, each department has a mode change checklist listing requirements that have to be completed before going from requirements that have to be completed before going from

Mode 5 to Mode 4, Mode 4 to Mode 3, etc.Mode 5 to Mode 4, Mode 4 to Mode 3, etc.

The STA keeps the master checklist. After each department The STA keeps the master checklist. After each department completes their checklist for the applicable mode change, they completes their checklist for the applicable mode change, they sign the master checklist. sign the master checklist.

We do not change modes until the master checklist is We do not change modes until the master checklist is complete for that mode change.complete for that mode change.

3131

ISTOG QUESTIONS –2007ISTOG QUESTIONS –200712. Mode Change Checklist Question12. Mode Change Checklist Question

1. Do you use a checklist or some other tool to verify that all1. Do you use a checklist or some other tool to verify that all

required IST tests have been performed before changingrequired IST tests have been performed before changing

modes?modes?

2. If you use a checklist, what do you do with the checklist 2. If you use a checklist, what do you do with the checklist when when

it is complete? Throw it away, file it, archive it as a QA it is complete? Throw it away, file it, archive it as a QA

record, etc?record, etc?


Any comments to the above?Any comments to the above?

3232

ISTOG QUESTIONS –2007ISTOG QUESTIONS –200713. MOV Stroke Time Testing13. MOV Stroke Time Testing

NPP Technical Specification 3.3.5.4 requires verifying that ESF NPP Technical Specification 3.3.5.4 requires verifying that ESF Response Time is within limits. For power-operated valves, Response Time is within limits. For power-operated valves, the ESF Response Time ends when the valve travels "to its the ESF Response Time ends when the valve travels "to its required position". required position".

When calculating ESF Response Time, we use IST stroke times When calculating ESF Response Time, we use IST stroke times for the valve stroke portion. No allowance is made for the for the valve stroke portion. No allowance is made for the valve position indication limit switch setting tolerance (0-10% valve position indication limit switch setting tolerance (0-10% of stroke).of stroke).

If you stroke time your safety related MOVs in the closed If you stroke time your safety related MOVs in the closed direction using a stopwatch that is stopped when the red direction using a stopwatch that is stopped when the red indicating light goes out, does your stroke time acceptance indicating light goes out, does your stroke time acceptance criteria take into account that the red light limit switch is set criteria take into account that the red light limit switch is set in a 10% of band from the full closed position? Or is the red in a 10% of band from the full closed position? Or is the red light turning off considered to indicate that the MOV is fully light turning off considered to indicate that the MOV is fully closed?closed?

NRC Question 13:NRC Question 13: As asked above? Also, is it the NRC position that position As asked above? Also, is it the NRC position that position indication verification of a power operated valve be performed indication verification of a power operated valve be performed in “both” positions, regardless of the safety function of the in “both” positions, regardless of the safety function of the valve?valve?

3333

ISTOG QUESTIONS –2007ISTOG QUESTIONS –200714. NIC Query14. NIC Query

NPP has experienced through-body leakage on (3) saltwater NPP has experienced through-body leakage on (3) saltwater pump discharge nozzle check valves when operating at pump discharge nozzle check valves when operating at normal system flow and pressure. normal system flow and pressure.

NPP is attempting to determine if similar valve failures of this NPP is attempting to determine if similar valve failures of this nature have occurred in the industry. nature have occurred in the industry.

Any information you can provide regarding the questions Any information you can provide regarding the questions listed below would be greatly appreciated:listed below would be greatly appreciated:

1. Does your facility have these make & model nozzle 1. Does your facility have these make & model nozzle check valves in service and if so, in what application? check valves in service and if so, in what application?

3434

ISTOG QUESTIONS –2007ISTOG QUESTIONS –200714. NIC Query14. NIC Query

2. Have you experienced through-body leakage with 2. Have you experienced through-body leakage with these valves? these valves?

3. Have you identified the presence of casting defects or 3. Have you identified the presence of casting defects or

crevice corrosion with these valves?crevice corrosion with these valves? Make --Enertech Make --Enertech Model --DRV-B Model --DRV-B Size -- 24" Size -- 24" System Application --check valve for saltwater System Application --check valve for saltwater

pump pump Service Condition --saltwater @ 35psi Service Condition --saltwater @ 35psi

NRC Question 14:NRC Question 14: Any comments on above?Any comments on above?

3535

ISTOG QUESTIONS –2007ISTOG QUESTIONS –200715. Observations of Surveillance Tests (IST's)15. Observations of Surveillance Tests (IST's)

At NPP, there recently has been a question relative to At NPP, there recently has been a question relative to involvement of the Engineering staff in observation of IST's. involvement of the Engineering staff in observation of IST's.

Pump IST's are performed by Operations Test Group and test Pump IST's are performed by Operations Test Group and test results are forwarded to the pump engineers for review and results are forwarded to the pump engineers for review and approval.approval.

Generally, the pump engineers do not witness the tests Generally, the pump engineers do not witness the tests unless there are unusual circumstances. unless there are unusual circumstances.

Each pump test is reviewed by a pump engineer and the Each pump test is reviewed by a pump engineer and the group supervisor. group supervisor.

3636


Valve IST's are performed by Operations including final Valve IST's are performed by Operations including final review and acceptance of test results. Corrective Actions are review and acceptance of test results. Corrective Actions are initiated when acceptance criteria is not met.initiated when acceptance criteria is not met.

Valve engineers periodically review trend data, but do not Valve engineers periodically review trend data, but do not participate in or observe valve IST's unless there is an participate in or observe valve IST's unless there is an abnormal situation. abnormal situation.

11. . Does your plant have a separate group who Does your plant have a separate group who performs the pump test vs. the actual pump performs the pump test vs. the actual pump engineer? engineer?

3737


2.2. If you have a separate group that performs the If you have a separate group that performs the pump pump tests, does the pump engineer(s) additionally tests, does the pump engineer(s) additionally observe observe the pump tests during performance? the pump tests during performance?

3.3. Does your plant have valve tests performed by Does your plant have valve tests performed by personnel other than engineering? personnel other than engineering?

4. If so, does engineering additionally observe4. If so, does engineering additionally observe

performance of valve testing?performance of valve testing?


Any comments on above?Any comments on above?

3838

ISTOG QUESTIONS –2007ISTOG QUESTIONS –200716. OMN-1 (ISTC App. III) Reconciliation16. OMN-1 (ISTC App. III) Reconciliation

As you know there has been heated debate about the 2 As you know there has been heated debate about the 2 versus 3 risk ranking issue. I would like to offer a fresh versus 3 risk ranking issue. I would like to offer a fresh perspective and get some feedback about whether a Code perspective and get some feedback about whether a Code inquiry is appropriate or even necessary.inquiry is appropriate or even necessary.

It seems to me that the main concern from the Code It seems to me that the main concern from the Code committee perspective, as it pertains to use of 2 risk committee perspective, as it pertains to use of 2 risk categories, is the scheduling frequency of the MOV exercise categories, is the scheduling frequency of the MOV exercise testing (EXER). testing (EXER).

The main concern from the MOV Program owners (MUG) The main concern from the MOV Program owners (MUG) perspective, as it pertains to continued use of the 3 risk perspective, as it pertains to continued use of the 3 risk categories, is the scheduling of GL 96-05 tests (which would categories, is the scheduling of GL 96-05 tests (which would now be considered Inservice Test – (IST).now be considered Inservice Test – (IST).

3939


What IF - plants took their existing 3 tier MOV risk What IF - plants took their existing 3 tier MOV risk classifications and lumped ALL High and Med MOVs into the classifications and lumped ALL High and Med MOVs into the HSSC category and all their Low MOVs into the LSSC category HSSC category and all their Low MOVs into the LSSC category and used this "new" list for the purpose of creating / and used this "new" list for the purpose of creating / scheduling the exercise test.scheduling the exercise test.

However, for the purposes of setting test intervals for their However, for the purposes of setting test intervals for their GL 96-05 tests they would still use the existing JOG matrix GL 96-05 tests they would still use the existing JOG matrix with their base 3 tier Risk and Margin classifications.with their base 3 tier Risk and Margin classifications.

In the latest version of ISTC App. III Section 3300 and 3310 In the latest version of ISTC App. III Section 3300 and 3310 there isthere is

NO specific discussion of the IST interval relative to HSSC. NO specific discussion of the IST interval relative to HSSC.

4040


Sect 6440 (Determination of Test Interval) also has NO specific Sect 6440 (Determination of Test Interval) also has NO specific discussion of the IST interval relative to HSSC. Only in Sect IIIdiscussion of the IST interval relative to HSSC. Only in Sect III3722 - LSSC MOVs is there any sort of tie-in between Risk 3722 - LSSC MOVs is there any sort of tie-in between Risk categorization and IST interval.categorization and IST interval. However, 3722 (c) allows for IST intervals for LSSC to be However, 3722 (c) allows for IST intervals for LSSC to be extended beyond 5Y given a mature program with solid extended beyond 5Y given a mature program with solid historical data (i.e., typical GL 96-05 Program). historical data (i.e., typical GL 96-05 Program).

3722 (d) stipulates a MAX IST interval of 10Y for LSSC's, but 3722 (d) stipulates a MAX IST interval of 10Y for LSSC's, but that is consistent with JOG max interval anyway.that is consistent with JOG max interval anyway.

4141


So in a nutshell - As long as plants set their So in a nutshell - As long as plants set their exerciseexercise testing testing intervals based on the 2 tier HSSC and LSSC intervals based on the 2 tier HSSC and LSSC classifications (would be HSSC = JOG H and M and classifications (would be HSSC = JOG H and M and LSSC = JOG L) they would meet the intent of the Code.LSSC = JOG L) they would meet the intent of the Code.

I don't think anyone has issues with doing that. The wording I don't think anyone has issues with doing that. The wording in App. III does NOT seem to directly impact how current GL in App. III does NOT seem to directly impact how current GL 96-05 test (IST) intervals are determined (could continue 96-05 test (IST) intervals are determined (could continue using the JOG matrix).using the JOG matrix).


Does the NRC accept the “2 tier” method of risk ranking in Does the NRC accept the “2 tier” method of risk ranking in accordance with OMN-1 as well as the “3 tier” method? accordance with OMN-1 as well as the “3 tier” method?

In other words, can you use the 2 tier method to rank MOVs In other words, can you use the 2 tier method to rank MOVs for diagnostic testing frequency and then use the 3 tier for diagnostic testing frequency and then use the 3 tier method to determine exercise frequency or, vice a versa?method to determine exercise frequency or, vice a versa?

4242


NRC Question 16 (continued):NRC Question 16 (continued):

Is it permissible to extend the frequency of the valve position Is it permissible to extend the frequency of the valve position indication to the diagnostic frequency of the MOVs when indication to the diagnostic frequency of the MOVs when implementing OMN-1 CC? implementing OMN-1 CC?

The CC is silent on ALL sections of the Code with the The CC is silent on ALL sections of the Code with the exception of the Leak section. It appears that the Code has exception of the Leak section. It appears that the Code has “included” the valve position indication verification within the “included” the valve position indication verification within the CC. Comments?CC. Comments?

4343

ISTOG QUESTIONS –2007ISTOG QUESTIONS –200717. PIV Testing17. PIV Testing

In today's world of performance based testing, risk based In today's world of performance based testing, risk based testing, etc., I thought it was time to bring up Pressure testing, etc., I thought it was time to bring up Pressure Isolation Valve (PIV) testing, once again.Isolation Valve (PIV) testing, once again.

At NPP, we currently perform PIV testing on Core Spray and At NPP, we currently perform PIV testing on Core Spray and RHR lines every refueling outage, utilizing a hydro pump test RHR lines every refueling outage, utilizing a hydro pump test skid and high pressure hoses. skid and high pressure hoses.

We have had 10+ years of successful tests (need to validate) We have had 10+ years of successful tests (need to validate) and pick up significant dose each outage performing this and pick up significant dose each outage performing this testing. Appendix J air tests are performed on the same testing. Appendix J air tests are performed on the same valves.valves.

4444

ISTOG QUESTIONS –2007ISTOG QUESTIONS –200717. PIV Testing17. PIV Testing

Therefore, I have the following questions: Therefore, I have the following questions:

1. Has any plant successfully extended the frequency of a 1. Has any plant successfully extended the frequency of a PIV test or eliminated a PIV test via a relief request? PIV test or eliminated a PIV test via a relief request?

2. What is your method of testing PIVs? 2. What is your method of testing PIVs?


Is it permissible to use the LLRT method of testing valves Is it permissible to use the LLRT method of testing valves by using air as a substitute for using water? (This has by using air as a substitute for using water? (This has been an ongoing discussion and at last we heard this was been an ongoing discussion and at last we heard this was NOT an acceptable method.) NOT an acceptable method.)

Can you provide further clarification or guidance?Can you provide further clarification or guidance?

4545

ISTOG QUESTIONS –2007ISTOG QUESTIONS –200718. Preconditioning Question18. Preconditioning Question

At NPP we isolated a section of Internal Containment Spray At NPP we isolated a section of Internal Containment Spray system piping using a tag out or clearance that included two system piping using a tag out or clearance that included two IST program valves as boundary isolations. The piping was IST program valves as boundary isolations. The piping was isolated to perform corrective maintenance for a flange boric isolated to perform corrective maintenance for a flange boric acid leak. acid leak.

Several hours later following completion of the corrective Several hours later following completion of the corrective maintenance, the scheduled quarterly Internal Containment maintenance, the scheduled quarterly Internal Containment Spray test was performed and was also used as a post Spray test was performed and was also used as a post maintenance test to leak check the flange repair. maintenance test to leak check the flange repair.

The valves that were used as tag out boundaries were stroke The valves that were used as tag out boundaries were stroke time tested during the surveillance. The stroke times were time tested during the surveillance. The stroke times were consistent with stroke times for the previous two years of consistent with stroke times for the previous two years of testing.testing.

4646

ISTOG QUESTIONS –2007ISTOG QUESTIONS –2007

18. Preconditioning Question18. Preconditioning Question

Our NRC resident is proposing a violation stating the valves Our NRC resident is proposing a violation stating the valves were unacceptably preconditioned.were unacceptably preconditioned.

The violation would be an appendix B procedure violation The violation would be an appendix B procedure violation based upon the statement in NUREG 1482, Rev. 1, page 3-21 based upon the statement in NUREG 1482, Rev. 1, page 3-21 that says: “...the staff considers unacceptable that says: “...the staff considers unacceptable preconditioning in the IST program to preconditioning in the IST program to include ... (2) ... (2) operation of a pump or valve shortly before a test, if such operation of a pump or valve shortly before a test, if such operation could have been avoided through plant procedures operation could have been avoided through plant procedures with personnel and plant safety maintained..." with personnel and plant safety maintained..."

4747



Please provide feedback on the following questions: Please provide feedback on the following questions:

1. Does your tagout/clearance procedure require as found 1. Does your tagout/clearance procedure require as found stroke time testing stroke time testing of IST valves used as boundaries when of IST valves used as boundaries when hanging/clearing hanging/clearing tags? tags?

2. If you identify a case of inadvertently stroking a valve prior 2. If you identify a case of inadvertently stroking a valve prior to to performing the inservice test how do you answer the NRC performing the inservice test how do you answer the NRC

Inspection Manual Part 9900 technical guidance question Inspection Manual Part 9900 technical guidance question “Does “Does the practice bypass or mask the as found condition of the practice bypass or mask the as found condition of the pump or the pump or valve?” valve?”

4848



3. What length of time do you consider as the minimum to 3. What length of time do you consider as the minimum to satisfy the satisfy the NUREG 1482, Rev. 1, statement on NUREG 1482, Rev. 1, statement on page 3-21 page 3-21 of “shortly before”? of “shortly before”?


Your thoughts on the above and, in general, “preconditioning”. Your thoughts on the above and, in general, “preconditioning”.

(In my opinion, unacceptable preconditioning is that activity (In my opinion, unacceptable preconditioning is that activity (whether deliberate or accidental), which interferes or affects (whether deliberate or accidental), which interferes or affects the ability of a facility to be able to detect or monitor for the ability of a facility to be able to detect or monitor for degradation. Acceptable would be pretty much the opposite.)degradation. Acceptable would be pretty much the opposite.)

4949


19.19. Pre-service IST Requirements Pre-service IST Requirements

We may be installing 4 check valves which will be included in We may be installing 4 check valves which will be included in our IST Check Valve Disassembly and Inspection Program. our IST Check Valve Disassembly and Inspection Program.

I would like to get some feedback on what you feel would be I would like to get some feedback on what you feel would be the appropriate IST pre-service test for check valves that will the appropriate IST pre-service test for check valves that will be included a D&I program, since it is not feasible to test the be included a D&I program, since it is not feasible to test the valves with flow with flow valves with flow with flow


Comments?Comments?

5050

ISTOG QUESTIONS –2007ISTOG QUESTIONS –200720. 20. Pressurizer PORV TestingPressurizer PORV Testing

In our Tech Specs we have the following surveillance In our Tech Specs we have the following surveillance requirement for Pressurizer PORVs:requirement for Pressurizer PORVs:

Every 18 months: Verify the nitrogen supply for each PORV is Every 18 months: Verify the nitrogen supply for each PORV is OPERABLE by:OPERABLE by:

a. Manually transferring motive power from the air a. Manually transferring motive power from the air supply to supply to the nitrogen supply,the nitrogen supply,

b. Isolating and venting the air supply, andb. Isolating and venting the air supply, and

c. Operating the PORV through one complete c. Operating the PORV through one complete cycle.cycle.

5151

ISTOG QUESTIONS –2007ISTOG QUESTIONS –200720. Pressurizer PORV Testing20. Pressurizer PORV Testing

Question: Question:

If you have a similar surveillance requirement when is it If you have a similar surveillance requirement when is it performed?performed?

a. Prior to or during shutdown for a refueling a. Prior to or during shutdown for a refueling outage, outage, oror b. Sometime during the refueling outage. b. Sometime during the refueling outage.


Comments?Comments?

5252

ISTOG QUESTIONS –2007ISTOG QUESTIONS –200721. PIV Leak Testing21. PIV Leak Testing

I would greatly appreciate answers to the following questions I would greatly appreciate answers to the following questions that could assist me with development of a Pressure Isolation that could assist me with development of a Pressure Isolation Valve (PIV) leak test designed to fully comply with the Valve (PIV) leak test designed to fully comply with the requirements of OM-10, 4.4.4.3 and/or ISTC-3630, depending requirements of OM-10, 4.4.4.3 and/or ISTC-3630, depending on the specific Code edition a plant is on. on the specific Code edition a plant is on.

My proposed test would use air as the test medium instead of My proposed test would use air as the test medium instead of water which is the case with traditional PIV seat leakage tests.water which is the case with traditional PIV seat leakage tests.

1. Has any plant implemented the guidance of OM-10 1. Has any plant implemented the guidance of OM-10 paragraph paragraph 4.2.2.3 or likewise ISTC-3630 for PIV's where air 4.2.2.3 or likewise ISTC-3630 for PIV's where air was used as the was used as the test medium in lieu of a traditional water test medium in lieu of a traditional water test? test?

5353

ISTOG QUESTIONS –2007ISTOG QUESTIONS –200721. PIV Leak Testing21. PIV Leak Testing

2. If so, is your permissible leakage rate established by your 2. If so, is your permissible leakage rate established by your own own calculation and acceptance criteria or simply based calculation and acceptance criteria or simply based upon the Code upon the Code provided formula of (7.5) (D) standard provided formula of (7.5) (D) standard cubic feet/day formula?cubic feet/day formula?

3.3. If Owner established, would you be willing to share the If Owner established, would you be willing to share the basis of basis of your calculation?your calculation?


Is it permissible to use the LLRT method of testing valves by Is it permissible to use the LLRT method of testing valves by using air as a substitute for using water?using air as a substitute for using water? (This has been an (This has been an ongoing discussion and at last we heard this was NOT an ongoing discussion and at last we heard this was NOT an acceptable method.) acceptable method.)

Can you provide further clarification or guidance?Can you provide further clarification or guidance?

5454

ISTOG QUESTIONS –2007ISTOG QUESTIONS –200722. CPT Plant Modifications22. CPT Plant Modifications

NPP Station will be committed to the ASME Code requirement NPP Station will be committed to the ASME Code requirement to perform Comprehensive Pump Testing (CPT) as part of to perform Comprehensive Pump Testing (CPT) as part of transitioning from the current 4th to 5th 10 year interval IST transitioning from the current 4th to 5th 10 year interval IST program which becomes effective on 1/1/10. program which becomes effective on 1/1/10.

The only program pumps that can not be tested at or aboveThe only program pumps that can not be tested at or above accident mitigation flow,accident mitigation flow, NPP's definition of pump "design flow NPP's definition of pump "design flow rate", are the two Containment Spray pumps. rate", are the two Containment Spray pumps.

These pumps are currently tested each quarter at a maximum These pumps are currently tested each quarter at a maximum attainable (using all available and measurable parallel flow attainable (using all available and measurable parallel flow paths) reference flow rate of 270 gpm. The accident paths) reference flow rate of 270 gpm. The accident mitigation flow rate for a Containment Spray pump is 1300 mitigation flow rate for a Containment Spray pump is 1300 gpm.gpm.

5555

ISTOG QUESTIONS –2007ISTOG QUESTIONS –200722. CPT Plant Modifications22. CPT Plant Modifications

To ensure an optimum technical and cost effective solution to To ensure an optimum technical and cost effective solution to this problem, NPP is seeking peer operational experience this problem, NPP is seeking peer operational experience relative to successful system piping modifications (temporary relative to successful system piping modifications (temporary or permanent in nature), additional test strategies (including or permanent in nature), additional test strategies (including cases where NRC relief requests were submitted and granted) cases where NRC relief requests were submitted and granted) or other types of compensatory measures taken which or other types of compensatory measures taken which resulted in being able to successfully perform a CPT within +/- resulted in being able to successfully perform a CPT within +/- 20 % of pump design flow (ISTB-3300, Reference Values).20 % of pump design flow (ISTB-3300, Reference Values).


Any more thoughts regarding the “design flow” and what Any more thoughts regarding the “design flow” and what would constitute acceptable alternative or a hardship?would constitute acceptable alternative or a hardship?

5656

ISTOG QUESTIONS –2007ISTOG QUESTIONS –200723. Relief to Use Tank Level Change over Time for Flow 23. Relief to Use Tank Level Change over Time for Flow RateRate

At NPP, we have vertical centrifugal Fuel Oil Transfer Pumps At NPP, we have vertical centrifugal Fuel Oil Transfer Pumps mounted over our Emergency Diesel Generator Fuel Oil mounted over our Emergency Diesel Generator Fuel Oil Storage Tanks.Storage Tanks.

We do not have flow indicators in the lines from the Storage We do not have flow indicators in the lines from the Storage Tanks to the Day Tanks, so we currently measure flow using a Tanks to the Day Tanks, so we currently measure flow using a Day Tank level change over time. Day Tank level change over time.

We currently have a relief request approved to do this, and We currently have a relief request approved to do this, and are presently updating to the 2001 Edition of the ASME OM are presently updating to the 2001 Edition of the ASME OM Code. During review of this relief request for the next 10-year Code. During review of this relief request for the next 10-year interval, the NRC stated that relief is not able to be granted interval, the NRC stated that relief is not able to be granted because NUREG-1482, Rev.1, Section 5.5.2 only applies to because NUREG-1482, Rev.1, Section 5.5.2 only applies to positive displacement pumps and we have vertical centrifugal positive displacement pumps and we have vertical centrifugal pumps, unless we can explain why this is OK for a centrifugal pumps, unless we can explain why this is OK for a centrifugal pump as well.pump as well.

5757

ISTOG QUESTIONS –2007ISTOG QUESTIONS –200723. Relief to Use Tank Level Change over Time for Flow 23. Relief to Use Tank Level Change over Time for Flow

RateRate

1. If you have centrifugal FO Transfer Pumps, do you use a 1. If you have centrifugal FO Transfer Pumps, do you use a change in Day Tank level over time to determine the flow change in Day Tank level over time to determine the flow rate?rate?

2. If so, do you have a copy of a relief request that I could 2. If so, do you have a copy of a relief request that I could use? OR do you use some other method to measure flow use? OR do you use some other method to measure flow rate?rate?


Is this an acceptable method? This appears to be allowed per Is this an acceptable method? This appears to be allowed per thethe

Code ISTB?Code ISTB?

Does the NRC consider Diesel Fuel Oil Transfer Pumps to be Does the NRC consider Diesel Fuel Oil Transfer Pumps to be “skid“skid

mounted”? mounted”?

5858

ISTOG QUESTIONS –2007ISTOG QUESTIONS –200723. Relief to Use Tank Level Change over Time for Flow 23. Relief to Use Tank Level Change over Time for Flow

RateRate

NRC Question 23 (con’t):NRC Question 23 (con’t):

General guidance is that if a component CANNOT be tested General guidance is that if a component CANNOT be tested using theusing the

IST requirements in the Code (impractical), and the component IST requirements in the Code (impractical), and the component isis

tested (justified to be tested adequately) when the primary tested (justified to be tested adequately) when the primary componentcomponent

is run, then it can be considered “skid-mounted”. is run, then it can be considered “skid-mounted”.

However, typically DG FOTPs are ABLE to be tested using ISTHowever, typically DG FOTPs are ABLE to be tested using IST

requirements and are NOT run every time the DG is operated. requirements and are NOT run every time the DG is operated.

Would these be “skid-mounted”? Would these be “skid-mounted”?

What is the NRC bottom line position? What is the NRC bottom line position?

5959

ISTOG QUESTIONS –2007ISTOG QUESTIONS –200724. 24. Review of US PWR Pressurizer Spring Loaded Safety Review of US PWR Pressurizer Spring Loaded Safety

ReliefRelief

Valve Test Procedures, February 2004Valve Test Procedures, February 2004

We currently carry out Trevi-testing of its Pressurizer Safety We currently carry out Trevi-testing of its Pressurizer Safety Relief Valves immediately after plant shutdown for each Relief Valves immediately after plant shutdown for each refueling outage (every 18 months). This is on critical path refueling outage (every 18 months). This is on critical path and requires purging of the Pressurizer Relief Tank to remove and requires purging of the Pressurizer Relief Tank to remove gaseous radwaste. gaseous radwaste.

We are interested in rescheduling the testing and would like We are interested in rescheduling the testing and would like responses to the following questions:responses to the following questions:

1.1. At what time in the cycle/outage do you test your PZR At what time in the cycle/outage do you test your PZR SRVs?SRVs?

2. How often do you test your PZR SRVs?2. How often do you test your PZR SRVs?

6060

ISTOG QUESTIONS –2007ISTOG QUESTIONS –200724. 24. Review of US PWR Pressurizer Spring Loaded Safety Review of US PWR Pressurizer Spring Loaded Safety

Relief Valve Test Procedures, February 2004Relief Valve Test Procedures, February 2004

3. Have you ever suffered failure of a PZR SRV to 3. Have you ever suffered failure of a PZR SRV to reseat? If so, when and what action was taken?reseat? If so, when and what action was taken?

4. Have you considered rescheduling of PZR SRV 4. Have you considered rescheduling of PZR SRV testing? If so, what was the result?testing? If so, what was the result?

We are working on cooling down and borating in parallel, this We are working on cooling down and borating in parallel, this hold will obviously stop the benefit of this initiative.hold will obviously stop the benefit of this initiative.


Any comments or guidance regarding “trevitesting” or other Any comments or guidance regarding “trevitesting” or other insitu methods?insitu methods?

6161

ISTOG QUESTIONS –2007ISTOG QUESTIONS –200725. 25. Temporary Pressure GaugesTemporary Pressure Gauges

For those of you who have or are moving to a later Edition of For those of you who have or are moving to a later Edition of the Code that requires comprehensive pump testing, I am the Code that requires comprehensive pump testing, I am looking for input on how you plan on handling your looking for input on how you plan on handling your requirements for higher accuracy pressure instrumentation.requirements for higher accuracy pressure instrumentation.

1. Does your permanently installed pressure instrumentation 1. Does your permanently installed pressure instrumentation meet the meet the accuracy requirements of +/-0.5% of full scale accuracy requirements of +/-0.5% of full scale (analog) or over the (analog) or over the calibrated range (digital)?calibrated range (digital)?

2. If the above answer is no for some or all, what do you plan 2. If the above answer is no for some or all, what do you plan on on doing for your comprehensive pump testing (i.e. install doing for your comprehensive pump testing (i.e. install temporary temporary gauges or make permanent instrumentation gauges or make permanent instrumentation changes)? What is the changes)? What is the basis for your decision?basis for your decision?

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ISTOG QUESTIONS –2007ISTOG QUESTIONS –200725. 25. Temporary Pressure GaugesTemporary Pressure Gauges

3. If answer #1 is yes, what type of gauges do you use and 3. If answer #1 is yes, what type of gauges do you use and what is the what is the calibration frequency of your gauges?calibration frequency of your gauges?

3.1 Do you have concerns with the higher accuracy gauges 3.1 Do you have concerns with the higher accuracy gauges staying staying within calibration?within calibration?

3.2 Is the +3% upper operability limit a concern? 3.2 Is the +3% upper operability limit a concern?


Any comments on above?Any comments on above?

6363

ISTOG QUESTIONS –2007ISTOG QUESTIONS –200726. 26. Testing During Power AscensionTesting During Power Ascension

NUREG-1482, Rev. 1, Guidelines for Inservice Testing at Nuclear NUREG-1482, Rev. 1, Guidelines for Inservice Testing at Nuclear Power Plants, section 3.1.1.2, “Testing at a Refueling Outage Power Plants, section 3.1.1.2, “Testing at a Refueling Outage Frequency for Valves Tested During Power Ascension”, Frequency for Valves Tested During Power Ascension”, provides guidance on the testing of valves that can only be provides guidance on the testing of valves that can only be tested during power ascension or at power for valves that tested during power ascension or at power for valves that have deferred test justifications. have deferred test justifications.

This guidance identifies that for valves that can only be tested This guidance identifies that for valves that can only be tested during power ascension or at power the licensees may test during power ascension or at power the licensees may test valves designated as “refueling” or “cold” shutdown frequency valves designated as “refueling” or “cold” shutdown frequency tests during power ascension or at power following an outage tests during power ascension or at power following an outage without the need for requesting relief. without the need for requesting relief.

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Have you applied this guidance to valves tested on a quarterly Have you applied this guidance to valves tested on a quarterly frequency and if so how was this documented/justified? frequency and if so how was this documented/justified?


Does the NRC have any requirements or guidance on when Does the NRC have any requirements or guidance on when (during RFOs or CSJs) that the component should be tested (during RFOs or CSJs) that the component should be tested and, can the frequency be changed from Quarterly to CSJ as a and, can the frequency be changed from Quarterly to CSJ as a result of maintenance?result of maintenance?

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Clarification:Clarification:

I have received some feedback on my question and I I have received some feedback on my question and I apologize for the confusion I may have caused. apologize for the confusion I may have caused.

To be more specific about my situation is we are in an To be more specific about my situation is we are in an unplanned cold shutdown and the surveillance interval grace unplanned cold shutdown and the surveillance interval grace period for some turbine driven AFW train check valve tests period for some turbine driven AFW train check valve tests may expire. may expire.

ISTB has an allowance for not performing the pump test in ISTB has an allowance for not performing the pump test in this situation but there is no similar guidance in ISTC. I was this situation but there is no similar guidance in ISTC. I was wondering if any of you have encountered a similar situation.wondering if any of you have encountered a similar situation.

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Exercising Testing of RCIC/HPCI Pump Discharge Check ValvesExercising Testing of RCIC/HPCI Pump Discharge Check Valves

What testing methods do other BWRs employ satisfy the What testing methods do other BWRs employ satisfy the exerciser test in the closed direction for their RCIC and/or HPCI exerciser test in the closed direction for their RCIC and/or HPCI discharge check valves?discharge check valves?


Any additional comments?Any additional comments?

6767

ISTOG QUESTIONS –2007ISTOG QUESTIONS –200727. 27. Timing of Rapid Closure ValvesTiming of Rapid Closure Valves

98 Edition of O&M Code w/ 99 & 2000 addenda CE PWR 98 Edition of O&M Code w/ 99 & 2000 addenda CE PWR

At NPP we have certain containment isolation solenoid valves At NPP we have certain containment isolation solenoid valves which have a 1 sec MAXIMUM stroke time per our Licensee which have a 1 sec MAXIMUM stroke time per our Licensee Controlled Specification (LCS). Relative to these valves: Controlled Specification (LCS). Relative to these valves:

1. Do you have valves within your IST program which are 1. Do you have valves within your IST program which are required to stroke faster than 2 seconds per required to stroke faster than 2 seconds per

your Tech Specs or your Tech Specs or LCS? LCS?

2. If so, how do you time them? (what timing mechanism 2. If so, how do you time them? (what timing mechanism do do you use, stop watch, chart recorder, etc,)you use, stop watch, chart recorder, etc,)


Any additional comments? Any additional comments?

6868

ISTOG QUESTIONS –2007ISTOG QUESTIONS –200728. 28. IST Question on Trip Valve TestingIST Question on Trip Valve Testing

During a recent inspection NPP’s methodology for testing its During a recent inspection NPP’s methodology for testing its Turbine Driven Auxiliary Feedwater Pumps and associated Turbine Driven Auxiliary Feedwater Pumps and associated valves was questioned. valves was questioned.

The concern was that we are unacceptably pre-conditioning The concern was that we are unacceptably pre-conditioning our Overspeed Trip Valve. At NPP our Overspeed Trip Valve is our Overspeed Trip Valve. At NPP our Overspeed Trip Valve is Motor Operated to allow re-latching and opening the valve Motor Operated to allow re-latching and opening the valve from the control room. from the control room.

The current testing sequence is:The current testing sequence is:

Manually trip the Overspeed Trip Valve locally at the Manually trip the Overspeed Trip Valve locally at the pump. This is pump. This is done first to ensure that should we get done first to ensure that should we get an auto pump start while an auto pump start while stroke timing the pump stroke timing the pump discharge/throttle MOVs the pump would discharge/throttle MOVs the pump would not be damage as not be damage as a result of run out. a result of run out.

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With the Overspeed Trip Valve tripped the two discharge With the Overspeed Trip Valve tripped the two discharge MOVs are MOVs are stroked timed both open and closed. The MOVs stroked timed both open and closed. The MOVs are then placed in are then placed in their proper throttle position. their proper throttle position.

The pump mini-recirc control valve is stroke timed both The pump mini-recirc control valve is stroke timed both open and open and shut.shut.

The Overspeed Trip Valve motor operator is then shut (and The Overspeed Trip Valve motor operator is then shut (and timed) timed) to re-latch the valve. to re-latch the valve.

The Overspeed Trip Valve motor operator is then opened The Overspeed Trip Valve motor operator is then opened (and (and timed) to place the pump in a ready condition. timed) to place the pump in a ready condition.

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The pump is started by opening (and timing) the steam The pump is started by opening (and timing) the steam inlet MOVs inlet MOVs and the pump is tested. and the pump is tested.

The concern was raised that by tripping and resetting the The concern was raised that by tripping and resetting the Overspeed Trip Valve before running the pump we could be Overspeed Trip Valve before running the pump we could be masking a condition where the valve would trip on a pump masking a condition where the valve would trip on a pump start.start.

1. When testing your turbine driven pumps do you first trip 1. When testing your turbine driven pumps do you first trip the the overspeed trip valve? Would you consider this practice overspeed trip valve? Would you consider this practice

unacceptable pre-conditioning?unacceptable pre-conditioning?

2. If not, do you isolate steam the turbine well stroke timing 2. If not, do you isolate steam the turbine well stroke timing the the pump’s discharge throttle valves? pump’s discharge throttle valves?

7171



Would the NRC consider this Unacceptable Preconditioning? Would the NRC consider this Unacceptable Preconditioning?

NRC SSEI Response to Item No. 180NRC SSEI Response to Item No. 180

Question:Question:

Procedure 3808.01, step 8.2, directs operations personnel to Procedure 3808.01, step 8.2, directs operations personnel to check the check the

overspeed trip linkage by manually tripping the overspeed trip overspeed trip linkage by manually tripping the overspeed trip linkage. linkage.

This step is a commitment in response to RICSIL 037. RICSIL This step is a commitment in response to RICSIL 037. RICSIL 037037

states that the check should be performed following each states that the check should be performed following each surveillancesurveillance

test, however, you perform the check prior to performing atest, however, you perform the check prior to performing a

surveillance. Is this pre-conditioning? If not, why not?surveillance. Is this pre-conditioning? If not, why not?

7272

ISTOG QUESTIONS –2007ISTOG QUESTIONS –200729. 29. IST Question On Turbine Driven PumpsIST Question On Turbine Driven Pumps

During Inservice Testing of NPP’s Turbine Driven Auxiliary During Inservice Testing of NPP’s Turbine Driven Auxiliary Feedwater Pumps both turbine and pump bearing Feedwater Pumps both turbine and pump bearing temperatures are record in addition to the ASME OM Code temperatures are record in addition to the ASME OM Code (95E/96A) required parameters of flow rate, differential (95E/96A) required parameters of flow rate, differential pressure, pump speed and pump vibration.pressure, pump speed and pump vibration.

Turbine bearing vibration is also recorded but IST acceptance Turbine bearing vibration is also recorded but IST acceptance criteria is not applied. The pumps are run on recirculation at a criteria is not applied. The pumps are run on recirculation at a flow rate of about 120 gpm for about a half hour, and then flow rate of about 120 gpm for about a half hour, and then flow is set to 400 gpm (the IST flow rate). After a two minute flow is set to 400 gpm (the IST flow rate). After a two minute stabilization period the IST data is collected and pump and stabilization period the IST data is collected and pump and turbine bearing temperatures are recorded.turbine bearing temperatures are recorded.

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We have discovered that the bearing temperatures are not We have discovered that the bearing temperatures are not necessarily stabilized at the time they are normally recorded necessarily stabilized at the time they are normally recorded (after approximately 35 minutes). (after approximately 35 minutes).

During an extended pump run this week the outboard turbine During an extended pump run this week the outboard turbine bearing temperature was taken a second time after about two bearing temperature was taken a second time after about two hour running at 400 gpm. The temperature was found to be hour running at 400 gpm. The temperature was found to be significantly higher than when originally recorded after 35 significantly higher than when originally recorded after 35 minutes. minutes.

NPP request that you answer the following questions related to NPP request that you answer the following questions related to this issue:this issue:

1. Do you routinely monitor bearing temperatures on your 1. Do you routinely monitor bearing temperatures on your turbine turbine driven pumps (turbine and pump bearings)? driven pumps (turbine and pump bearings)?

7474


2. If question 1 is yes, do you monitor these temperatures 2. If question 1 is yes, do you monitor these temperatures under under you Inservice Testing Program implementing you Inservice Testing Program implementing procedures?procedures?

3. If question 1 is yes, what type of stabilization criteria do 3. If question 1 is yes, what type of stabilization criteria do you use you use (a set time, a set change in temperature (a set time, a set change in temperature over a given time over a given time period, or other).period, or other).

4. Do you assign acceptance criteria to these temperature 4. Do you assign acceptance criteria to these temperature readings readings that if exceeded require the pump to be that if exceeded require the pump to be declared OOS?declared OOS?


Any comments to the above?Any comments to the above?

7575

ISTOG QUESTIONS –2007ISTOG QUESTIONS –200730. Use of Calibrated Gauges30. Use of Calibrated Gauges

ASME OM 1998 Code, 2000 Addendum.ASME OM 1998 Code, 2000 Addendum.

When performing a check valve test in the CLOSED direction When performing a check valve test in the CLOSED direction by observing a gross dP across the check valve, does the by observing a gross dP across the check valve, does the gauge used for this test need to be calibrated?gauge used for this test need to be calibrated?

I believe it does per 10CFR50 App B I believe it does per 10CFR50 App B andand ISTC-3800 ISTC-3800 ‘Instrumentation’ even through we are looking for a gross dP. ‘Instrumentation’ even through we are looking for a gross dP. I don’t see any leeway in the Code, though common sense I don’t see any leeway in the Code, though common sense would say it wouldn’t matter.would say it wouldn’t matter.


In general, what is the NRC’s position on when a valve is a In general, what is the NRC’s position on when a valve is a Category A valve and when is a valve just a Category B or C Category A valve and when is a valve just a Category B or C valve? Specific Leakage range? Safety function? System valve? Specific Leakage range? Safety function? System leakage? Radiological concern?leakage? Radiological concern?

7676

ISTOG QUESTIONS –2007ISTOG QUESTIONS –200731. Valve Testing Questions31. Valve Testing Questions

Two questions on how we are testing certain types of valves Two questions on how we are testing certain types of valves have been asked at my plant and I would like input from have been asked at my plant and I would like input from other plants on what you are currently doing to test these other plants on what you are currently doing to test these valves:valves:

1. Rapid Acting Valves - NPP currently use stroke time testing 1. Rapid Acting Valves - NPP currently use stroke time testing (using a (using a

stopwatch, measuring the time the valve opens to it when it stopwatch, measuring the time the valve opens to it when it closes by watching the indicator lights off the control closes by watching the indicator lights off the control board) to prove operability and to trend for degradation (we board) to prove operability and to trend for degradation (we established a reference value of 1 second which is not established a reference value of 1 second which is not required by the code for trending).required by the code for trending).

There are concerns (from my operations group) that this There are concerns (from my operations group) that this may not be an accurate representation of the actual time may not be an accurate representation of the actual time the valve strokes. the valve strokes.

What type of testing are you performing for rapid acting What type of testing are you performing for rapid acting valves that satisfies the code?valves that satisfies the code?

7777


Clarification for question #1Clarification for question #1

The reference value of 1 second (we use here at NPP) is for The reference value of 1 second (we use here at NPP) is for trending purposes ( the code leaves it up to the owner on how trending purposes ( the code leaves it up to the owner on how to trend for degradation but does give option of use of to trend for degradation but does give option of use of diagnostic equipment). diagnostic equipment).

My question pertains to how do you trend for degradation for My question pertains to how do you trend for degradation for rapid acting valves, if you do at all.rapid acting valves, if you do at all.

7878


2. I have been requested to evaluate the frequency of testing 2. I have been requested to evaluate the frequency of testing our Core Spray and Residual Heat Remove injection valves. our Core Spray and Residual Heat Remove injection valves. Currently, we test these valves quarterly.Currently, we test these valves quarterly.

We are experiencing frequent rising system pressures and We are experiencing frequent rising system pressures and the belief is that this condition is cause by the wear of the belief is that this condition is cause by the wear of these valves due to frequent cycling of this valve for IST these valves due to frequent cycling of this valve for IST testing. testing.

a. On what frequency are you testing these valves?a. On what frequency are you testing these valves?

b. What was your justification if deferred to a cold shutdown b. What was your justification if deferred to a cold shutdown or or

refueling outage?refueling outage?


What is the NRC’s position regarding the above response? Is What is the NRC’s position regarding the above response? Is itit

acceptable to time as stated above? acceptable to time as stated above?

7979

ISTOG QUESTIONS –2007ISTOG QUESTIONS –200732. Operable but Degraded Question32. Operable but Degraded Question

I have a question coming from our Nuclear Oversite people I have a question coming from our Nuclear Oversite people asking the IST Program Owner, “Should the IST Program asking the IST Program Owner, “Should the IST Program directdirect Operations to consider a valve that times outside the Operations to consider a valve that times outside the reference range (but less than its Limiting Stroke Time) as reference range (but less than its Limiting Stroke Time) as ‘Operable but Degraded’?”‘Operable but Degraded’?”

1. Do other plants do ‘Operability Assessments’ for all 1. Do other plants do ‘Operability Assessments’ for all valves that valves that time outside the reference range (but time outside the reference range (but <LST)? Is the valve <LST)? Is the valve considered fully Operable as long as it considered fully Operable as long as it is less than the LST?is less than the LST?

2. Is the purpose of the 96 hour evaluation meant to be 2. Is the purpose of the 96 hour evaluation meant to be considered an Operability assessment? considered an Operability assessment?

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ISTOG QUESTIONS –2007ISTOG QUESTIONS –200732. Operable but Degraded Question32. Operable but Degraded Question

3.3. If YES to #2, do other plants use the plant guidance for If YES to #2, do other plants use the plant guidance for Operability Operability Determinations when performing the 96 hour Determinations when performing the 96 hour eval?eval?


Any comments on the above?Any comments on the above?

8181

ISTOG QUESTIONS –2007ISTOG QUESTIONS –2007NRC Question 33:NRC Question 33:

What is the NRC’s position regarding testing of PORVs What is the NRC’s position regarding testing of PORVs that are used for LTOP? that are used for LTOP?

For example, can you perform ONLY an exercise test on the For example, can you perform ONLY an exercise test on the PORV and NOT be required to perform a Stroke Time, Valve PORV and NOT be required to perform a Stroke Time, Valve Position Indication, and Fail Safe tests?Position Indication, and Fail Safe tests?


Is it the NRC’s position that a valve ONLY requires Fail Safe Is it the NRC’s position that a valve ONLY requires Fail Safe testing if, the Fail position is a safety related position?testing if, the Fail position is a safety related position?

8282


What is the NRC’s position regarding a pump being tested What is the NRC’s position regarding a pump being tested during refueling and the pump enters the ALERT range? during refueling and the pump enters the ALERT range? Typically, the requirements are to double the test frequency Typically, the requirements are to double the test frequency UNTIL the cause of the condition is determined and the UNTIL the cause of the condition is determined and the condition corrected. condition corrected.

However, as can be plainly seen, to double the frequency However, as can be plainly seen, to double the frequency would require the plant to shutdown mid-cycle. Would it be would require the plant to shutdown mid-cycle. Would it be acceptable to the NRC to perform an analysis and based on acceptable to the NRC to perform an analysis and based on the determination that the pump would be able to perform its the determination that the pump would be able to perform its safety function until the next RFO, to provide written safety function until the next RFO, to provide written justification and documentation and to continue with the justification and documentation and to continue with the normal test frequency or, would this require some type of normal test frequency or, would this require some type of exigent relief?exigent relief?

8383


What is the NRC’s position regarding extension of frequencies What is the NRC’s position regarding extension of frequencies for CV Condition Monitoring and initial frequency? for CV Condition Monitoring and initial frequency?

Is it a requirement based on NRC position that you must NOT Is it a requirement based on NRC position that you must NOT exceed 1 cycle extension at a time UNTIL several years have exceed 1 cycle extension at a time UNTIL several years have passed with the Initial or can you use previous CV test history passed with the Initial or can you use previous CV test history to determine the FINAL interval initially?to determine the FINAL interval initially?


If a relief request has been denied by the NRC, is it If a relief request has been denied by the NRC, is it acceptable to “pull back” the relief request and continue on acceptable to “pull back” the relief request and continue on with the proposed test method?with the proposed test method?

8484


What is the requirement if the NRC has NOT approved the What is the requirement if the NRC has NOT approved the relief request submitted for the start of the next ten-year relief request submitted for the start of the next ten-year interval for IST? interval for IST?

Can you implement the relief requested alternative? Can you implement the relief requested alternative?

Must you continue to test per the previous method? Exigent Must you continue to test per the previous method? Exigent relief?relief?


Is it the NRC’s requirement that should “major maintenance” Is it the NRC’s requirement that should “major maintenance” be required to be performed online for a Group B pump that be required to be performed online for a Group B pump that Exigent Relief be requested to restore the pump to Operable Exigent Relief be requested to restore the pump to Operable status or, can you use a Group A test?status or, can you use a Group A test?

8585


Is it the NRC’s position that Group B pump tests must be Is it the NRC’s position that Group B pump tests must be performed with the same methodology as Group A regarding performed with the same methodology as Group A regarding fixing a parameter (flow or dp) and then measuring the other fixing a parameter (flow or dp) and then measuring the other parameter or, can you ONLY measure one parameter and then parameter or, can you ONLY measure one parameter and then determine acceptability by ensuring that the measured determine acceptability by ensuring that the measured parameter is within 10% of the reference value?parameter is within 10% of the reference value?


Is relief required to use a Code Case which has an Is relief required to use a Code Case which has an applicability of Code which is NOT the Code of Record for the applicability of Code which is NOT the Code of Record for the plant?plant?


Is it the NRC’s position that subsection ISTB-6200 (c) is able to Is it the NRC’s position that subsection ISTB-6200 (c) is able to be used WITHOUT prior NRC approval?be used WITHOUT prior NRC approval?

8686


Can MOVs, CVs, AOVs, etc., be included in alternative test Can MOVs, CVs, AOVs, etc., be included in alternative test methods such as OMN-1, Appendix II, OMN-12…etc., methods such as OMN-1, Appendix II, OMN-12…etc., individually (i.e. cherry picking) or, must ALL valves being individually (i.e. cherry picking) or, must ALL valves being included in the applicable alternatives should the alternative included in the applicable alternatives should the alternative be chosen?be chosen?


Is it the NRC’s position that Atmospheric Dump Valves and Is it the NRC’s position that Atmospheric Dump Valves and Auto Depress. Valves ONLY require exercising in lieu of Stroke Auto Depress. Valves ONLY require exercising in lieu of Stroke Time testing and fail safe testing IF the valves are designated Time testing and fail safe testing IF the valves are designated as Category A and B safety relief valves?as Category A and B safety relief valves?

8787

ISTOG QUESTIONS –2007ISTOG QUESTIONS –200745. Regulatory Interface Section Question45. Regulatory Interface Section Question

NUREG 1482, Rev. 1, Section 5.9, Pump Testing Using NUREG 1482, Rev. 1, Section 5.9, Pump Testing Using Minimum Flow Return Lines With or Without Flow Measuring Minimum Flow Return Lines With or Without Flow Measuring Devices, identifies that pump parameters shown in ISTB-3000-Devices, identifies that pump parameters shown in ISTB-3000-1 must be measured and evaluated to determine pump 1 must be measured and evaluated to determine pump condition and detect degradation.condition and detect degradation.

The following sentence in the NUREG states that pump The following sentence in the NUREG states that pump differential pressure and flow rate are two parameters that are differential pressure and flow rate are two parameters that are measured and evaluated together to determine hydraulic measured and evaluated together to determine hydraulic performance.performance.

Table ISTB-3000-1, Note 1 for the Group B Test, states Table ISTB-3000-1, Note 1 for the Group B Test, states differential pressure or flow rate shall be measured and differential pressure or flow rate shall be measured and determined for all pumps, except positive displacement. This determined for all pumps, except positive displacement. This note appears to contradict the above statement.note appears to contradict the above statement.

8888


Given a group B centrifugal pump, where the group B test is Given a group B centrifugal pump, where the group B test is performed on a non-instrumented, fixed resistance minimum performed on a non-instrumented, fixed resistance minimum flow bypass line, per the Code recording and evaluating flow bypass line, per the Code recording and evaluating differential pressure only appears to be acceptable.differential pressure only appears to be acceptable.

While on the 1989 Code we had an approved relief request to While on the 1989 Code we had an approved relief request to perform testing in this fashion provided a full flow test was perform testing in this fashion provided a full flow test was performed each refueling outage. When updating to the 1998 performed each refueling outage. When updating to the 1998 Code relief was not requested as the Code changes were in Code relief was not requested as the Code changes were in essence implementing the requirements of the relief.essence implementing the requirements of the relief.

8989


Based upon recent discussions it appears as if the NRC still Based upon recent discussions it appears as if the NRC still expects both flow and differential pressure to be recorded for expects both flow and differential pressure to be recorded for group B pump tests.group B pump tests.

Please comment if this is an expectation and if so when Please comment if this is an expectation and if so when requesting relief since all Code requirements are met, what is requesting relief since all Code requirements are met, what is the basis for the relief request?the basis for the relief request?


Any comments on the above?Any comments on the above?

1 ISTOG QUESTIONS –2007 1. 5-YR Frequency of Class 1 Relief Valves A Nuclear Station has three class 1 safety valves. A Nuclear Station has three class.

Documents

afw flow instrumentation

istog questions

relief valves1

relief valve testing

relief exigent

outage frequency

orifice flow curve

safety valves