Nuclear Power Plant Pump and Valve, and Dynamic Restraint (Snubber) Inservice Testing Issues

Gurjendra S. Bedi, P. E. Division of Component Integrity Office of Nuclear Reactor Regulation July 14-15, 2008
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Introduction
Pump, valve, and snubber inservice testing (IST) issues have occurred since Ninth NRC/ASME Symposium on Pump and Valve Testing, July 2006: Smooth-running pump vibration issues Safety relief valve (SRV) testing frequency issues Check valve sample disassembly and inspection on-line Use of 10 CFR 50.59 processes to change the NRC authorized relief requests related to inservice inspection and testing
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Smooth-Running Pump Issues

Background Licensees prefer to use smooth-running pump vibration criteria in inservice testing (IST) to reduce unnecessary corrective action. Informally, when vibration reference values are below 0.05 inch/second, pumps are called smooth-running pumps. Licensees have submitted relief requests to use alternative vibration acceptance criteria on a case by case basis when vibration reference value is below 0.05 in/sec.

Smooth-Running Pump Issues (continued)

The ASME OM Code Requirements ISTB-5121(e) and ISTB-5123(e) require the measured vibration shall meet the applicable acceptance criteria as specified in Tables ISTB-5100-1, ISTB-5200-1 or ISTB-5300-1. The acceptable vibration criteria of ISTB Tables require that, if during an IST test, vibration exceeds 2.5 times the previously established reference value (Vr), the pump is considered in the alert range. ISTB-6200(a), Alert Range Criteria, states that the pump IST frequency is doubled until cause of the deviation is determined and condition is corrected. Pumps with vibration values > 6Vr are considered in the required action range & must be declared inoperable until corrected.
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Smooth-Running Pump Issues (continued)

Discussion NRC staff has authorized alternative vibration acceptance criteria for smooth-running pumps on case by case basis. Recently, some licensees have are submitted a generic relief request for all the pumps at their plant. NRC is not in position to authorize general relief for all pumps, should they be determined to be smooth-running pumps. Relief will considered on a pump-specific case by case basis.
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Safety Relief Valve (SRV) Testing Frequency Issues

Background Some licensees are performing IST of SRVs beyond the 5 year testing requirement of the Code. Some licensees are using an SRV installation-to-test time duration of 5 years to meet the Code requirement. Some licensees are not including SRV storage time in the test-to-test duration time, resulting in elapsed time between two consecutive tests of more than 5 years.

SRVs Testing Frequency Issues (continued)

The ASME OM Code Requirements Appendix I, Paragraph I-1320 requires that Class 1 pressure relief valves to be tested at least once every 5 years. This means SRV test-to-test time duration is limited to 5 years. ASME OM-1-1989, Section 1.3.1, requires that Class 1 pressure relief valves be tested at least once every 5 years. The test interval for any individual valve must not exceed 5 years. ASME Code Interpretation 01-18, ASME OM Code -1995 with OMa Code-1996 Addenda, Appendix I, dated June 26, 2003, clarifies the start of the 5-year test interval. The ASME OM Code Committee position is that the 5 year test interval starts when the valve is tested, not when the valve is installed.
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SRVs Testing Frequency Issues (continued) Discussion

NRC staff has authorized extension of the SRVs IST beyond 5 years on a case by case basis, with the following justification: SRVs are routinely refurbished, which provides reasonable assurance that setpoint drift is minimum. SRVs are stored in a controlled environment, which has minimum effect on the set point; and SRVs have satisfactory past performance for meeting the set point acceptance criteria.
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SRVs Testing Frequency Issues (continued)

Discussion (cont.) Licensees are requested to carefully examine the interval or frequency of the IST of SRVs, keeping in mind the ASME Code requirement that Class 1 valve be tested at least once every 5 years. This means that the SRV test-to-test interval shall not exceed 5 years. Technical Specification (TS) may allow plant owner to operate the plant when 5 year surveillance is missed, provided certain TS conditions are met.
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Check Valve On-line Disassembly and Inspection

Background Licensees often prefer check valve on-line IST to reduce refueling outage time. Licensees have submitted relief requests to perform IST of check valves to disassemble and inspect on-line. Some licensees have submitted relief requests to use a sample disassembly examination program for a group of check valves on-line.
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Check Valve On-line Disassembly and Inspection (continued)

The ASME Code Requirements ISTC-3510 requires that check valves be exercised nominally every 3 months. ISTC-3522(c) allows check valves exercising during refueling outages, where exercising is not practicable during operation at power. ISTC-5221(c) allows disassembly of sample check valves from a group of identical valves in similar application. ISTC-5221(c)(3) states that all valves in each group shall be disassembled and examined at least once every 8 years.

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Check Valve On-line Disassembly and Inspection (continued)

Discussion NRC staff has authorized on-line testing of check valves on a case by case basis. On-line check valve disassembly and examination will be performed at least once each operating cycle on a refueling outage frequency. ISTC-5224 requires that, if a check valve fails in sample disassembly program, all check valves in sample group are to be examined during the same refueling outage. Licensees can not defer disassembly and inspection of other check valves in the group.
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Check Valve On-line Disassembly and Inspection (continued)

Discussion (cont.) On-line sample disassembly and inspection IST activities for check valves in a group is not recommended unless the allowed outage time (AOT) provides sufficient time to permit the inspection of all valves in the group, if needed. NRC staff has found on-line disassembly and inspection of check valve groups containing one valve acceptable.
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Use of 10 CFR 50.59 Process to Change the NRC Authorized IST Relief Request (RR)
Background In accordance with 10 CFR 50.55a, the NRC has approved alternatives and granted numerous reliefs from the ASME Code requirements related to inservice examination and testing of various components including pumps, valves & snubbers. The use of an alternative as authorized by the NRC becomes a regulatory requirement. NRC has learned that at least one licensee used the 10 CFR 50.59 process to revise an NRC approved alternative related to snubber inservice examination and testing.
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Use of 10 CFR 50.59 Process to Change the NRC Authorized IST RR (continued)
Regulations 10 CFR 50.59 requires licensees To evaluate proposed changes to their facilities for their effects on the licensing basis of the plant, as described in the Final Safety Analysis Report (as updated), and To obtain prior NRC approval for changes that meet specified criteria (10 CFR 50.59) as having a potential impact upon the basis for issuance of the operating license. NEI-96-07, Revision 1, Guidelines for 10 CFR 50.59 Implementation, requires that the licensees activities controlled by regulation 10 CFR 50.55a, take precedence over 10 CFR 50.59. NEI-96-07 is endorsed by Regulatory Guide 1.187, Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments.
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Use of 10 CFR 50.59 Process to Change the NRC Authorized IST RR (continued)
Discussion The licensees are encouraged to be cautious when revising or changing programs or procedures referenced in an approved relief request. Any change or updates that supersedes or overwrites an alternative authorized in a relief request must be approved by the NRC.
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Use of 10 CFR 50.59 Process to Change the NRC Authorized IST RR (continued)
Discussion (cont.) 10 CFR 50.59 process can not be used to revise an alternative as authorized by the NRC. Licensees are requested to resubmit their relief request with revised alternative to NRC for review. 10 CFR 50.59 process can not be used to revise portions of licensee controlled documents such as Technical Requirement Manual (TRM) for snubbers examination and testing, which were authorized by NRC as an alternative in lieu of the Code requirements.
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Conclusions
The purpose of this paper is to make licensees aware of a number of pump, valve and snubber issues that staff has encountered since the Ninth NRC/ASME Symposium on Pump and Valve Testing in July 2006. Licensees who believe that some of the items discussed are applicable to their facilities may wish to review their current IST program and modify their program as appropriate.

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