bcc: J.R. Buchanan,HSIC

T.B. Abernathy,TIC

ACRS (16)

Last year we sent letters to licensees of operating nuclear powerplants notifying them of a revision to 10 CFR Part 50, Section 50.55awhich was published in the Federal. Register on February 12, 1976(41 FR 6256). The ~evised regulation changed the inservice inspectionand testing requirements for nuclear power plant components containedin paragraph (g) of 550,55a. You Here also advised of this subjectlast year by the Licensing Project'Hanager, Hr. D. Allison in atelephone call to Vr. J, Hoch, Project Engineer of your staff.

Since our call to you regarding these matters, we have received anumber of inquiries from licensees regarding acceptable methods forcomplying with the regulation. In general, the inquiries have beendirected toward three major a'reas relative to compliance with theregulation:

l. The determination of which ASHE Boiler and Pressure Vessel CodeEdition and Addenda are applicable for any updated inserviceinspection or testing -program,

2. The requirement to conform the Technical Specifications to arevised program, and

3. The process of obtaining relief from ASHE Code requirementfound to be impractica'I.

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HRC PDR . IE (3)

M+ P 3 19~yLocal PDR ~ J. WetmoreLWR '1 File L. ShaoR. S. Boyd H. LevrsnR".'. DeYoung T. Hirons, Los AlamosD. B. YassalloF. J. Williams

Docket Ho. 50-275 J. Stolzand 50-323 Q D. Allison

E. HyltonR;- Heineman

Pacific Gas and Electric Company. D. RossATTN: ter. John C. Horrissey '. Knight

Vice President 8 General Counsel R. Tedesco,77 Beale Street H. DentonSan Francisco, Califoriia 94106 V- A Moore

R. H. VollmerGentlemen: M. L. Ernst

W. P. GammillSUBJEC: REgUIRENENTS OF THE ASHE BOILER AhD PRESSURE VESSEL CODE,

SECTION XI (DIABLO CANYON, UNITS 1 5 2)

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Consequently,'le are transmitting for your use, Enclosure 1, "NRC StaffGuidance For Complying «ith Certain Provisions of 10 CFR 60.55a{g),Lnservice Inspection Requirements". This enclosure descpibe~ the majorprovisions of the revised regulation, addresses the areas of licenseeconcern listed above, and provides guidance on information «hich theHRC. staff will need +o review inservice inspection and testing programsand to evaluate requests for relief from AS) lE Code requirements thatare determined to be impractical. We believe this enclosure «ill serveto clarify the proper method(s) for implementing the regulation inseveral important areas.

We request that you submit proposed Technical Specification changes toincorporate'tandard language referencing 550,56a{g), at least 6 monthsbefore the start of the next 40-month inspection period for your facility.Also, as discussed in Enclosure 1„ you should submit a description ofyour planned inservice inspection and testing programs, as «ell as anyrequest for relief from ASNE Code requirements determined to be imprac-tical for your facility, as far in advance as possible of, but at least-90 days before, the start of any 40-month inservice inspection period,or 20-month pump and valve testing period.

En order for us to make an evaluation of your request for relief pursuantto 10 CFR 50.66a(g}(6)(i) for the period of time after the start ofcomI.miercial operation, you v>ill need to provide information to supportyour determinations of those items of inspection and testing «hich aredeemed to be impractical for the facility. The specific information that«e will need is provided in Enclosu} es 1 and 2 of this letter.

In addition, «e would like to emphasize an important point regarding theASHE Code Section XI requirements to test selected pumps and valves thatare now incorporated.in 560.66a(g): The ASIDE Code Section XI requirementsapply only to selected valves and pumps that can be tested «ithout placingthe plant in an unsafe condition. You should exercise care in planningyour testing programs to ensure that no test «ill be conducted «hile theplant is in an operating mode that would make it vulnerable to a testerror or a test failure. Particular attention should be directed to«ardthe valve exercising (cycling) tests. In this regard, some basic guide»lines for excluding exercising (cycling)'tests of certain valves duringplant operation are contained in Enclosure 2. Valve leakage tests andother valve and pump tests required by the ASHE Code, should be reviewedfor each component, re'lative to each plant operating mode, to ensure thatno test «ill have an adverse impact on plant safety.

OPPICC +SURNAME+

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We request that you provide your submittal fo) complying v>ith 550.55a(g)as soon as possible but not later than September 30, 1977, in order thatve may evaluate and approve your submittal before a decision.is maderegarding the issuance of an operating license for Diablo Canyon, Units1 5 2. Please inform us within fifteen (15) days after receipt of th]sletter of your confirmation of the schedule date or the date you siill beable to mIeet. ff you cannot meet our specified date or ifyour replyis not fully responsive to our request as stipulated above, it is highlylikely that the overall schedule for completing the licensing reviec forthis prospect v>ill have to be extended.

Please contact us ifyou have any questions regarding the matters discussedaboveB

Sincerely,OriginRI Signed by,John F. Stol

John 1:. Stolz, ChiefBLight Mater Reactors Branch Ho. 1

Division of Project management

Enclosures:l. HRC Staff Guidance for

Complying with CertainProvisions of 10 CFR 50.55i(g)

2. Guidelines for Excluding Exercising(Cycling) Tests of Certain YalvesDuring Plant Operation

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ccr Philip A. Crane, Jr., Esq.Pacific Gas and Electric Company?7 Beale StreetSan Francisco,. California 94106

Andrew J. Skaff, Esq.California Public Utilities Cori ssion350 Hchllihter StreetSan Francisco, Ca'lifornia 94102

fh'., Frederick Eissler, PresidentScenic Shoreline Preservation

Conference, Inc.4623 fSre Mesa QriveSanta Bar bara, California 93105

Ifs. Elizabeth E. Apfelberg1415 Cazader oSan Luis Obispo, California 93401

f~is. Sandra A. Silver5055 Radiord Avenue1forth Hollywood, Ca)i fornia 91607

- Hr. Gordon A. gilver5055 Radford Avenue

. North Hollywood, California 91607

Paul C. Valentine400 Charming AvenuePalo Alto, California 94301

Yale I. Jones, Esq.100 Van tress Avenue19th FloorSan Francisco, California 94102

James A. GeocarisCenter for Law in the Public

Interest10203 Santa Monica BoulevardLos Angeles, California 90067

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t$s. Raye Fleming1746 Charro StreetSan Luis Obispo, California 93401

Ur. John Forster985 Palm StreetSan Luis Obispo, California 93401

Hr. William P. CornwollP. 0. Box 453Horro Bay, California 93442

Hr. James O. Schuyler, NuclearPro5ect Manager

Pacific Gas and Electric Company77 Beale StreetSan Francisco, California 94106

ffrs. Thelma Ilil'dier811 Fair Oaks AvenueArroyo Grande, California 93420

Mr'. M. C. GangloffHestinghouse Electric CorporationP. 0. Box 355Pittsburgh, Pennsylvania 15230

OCCICC~

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EHCLOSURE 1

NRC STAFF GUIOAflCE FOR COtiPLYIHG llITMCERTAIt'ROYISIOHS

OF 10 CFR 50.55a( ) "IHSERVICE INSPECTIOH REQUIREMENTS"

I. IHTROOVCTIOH

Paragraph 50.55a(g) of 10 CFR Part 50 was revised on February 12, 1976(41 FR 6256). Since then, a number of licensees have requested that

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the HPC clarify several key provisions contained in the revised regulation.These key provisions relate to: (1) the requirements to periodicallyupdate the inservice and testing programs to comply with later editionsand addenda to the ASME Code, (2) the requirnent to conform the TechnicalSpecifications to a revised inservice inspection or testi!ig program,and (3) the procedures for requesting and ootaining relief from AS'lECode requirements that the licensee considers to be inpractical forhis facility. The purpose of thi s document is to briefly summarizethe major provisions of the revised 550.55a(g) and to provide generalguidance in thes three l ey areas. The document is in no way intendedto encompass all aspects of attaining compliance wi th 550.55a(g).

II. SUfllNRY OF REGVLATIOH

The revised 550.55a(g) contains provisions that require inservice inspec-tion and testing of A~JlE Code Class 1, 2, and 3 nuclear power plant com-ponents (including supports) to be performed in accordance with Section XIof the ASllE Boiler c" Pressure Vessel Code and applicable Addenda. Foroperating facilities ~hose Operating License (OL) was issued beforeMarch 1, 1976, these provi sions of the regulation apply at the start of thenext reqular 40-month inspection period after September 1, 1976. Thestart of the next 40-month period is determined by measuring a series of

'uch periods beginning at the star t of facility commercial ooeration. Forfacilities that received OL's on or after March 1, 1976, these provisionsof the. regulation apply at the start of commercial operation.

As a result of the February 1976 amendment, 550.55a( g) now specifiesinservice inspection and testing requirements for all operating plants,including those that received a Construction Permit (CP) before January 1,1971. Since plant designs and access provisions for inservice inspectionshave progressed over the years, the requlation provides recognition ofthis fact by grouping design requirements for component inspectabilitybased on a facility's CP issuance date. The regulation further specifiesthat new inservice inspection and testing requirements that. become effec-tive in later editions and addenda to the ASME Code, shall apply to allplants to the degree practical throughout their service lives.

2

An important part of the revised i50.55a(g) is the incorporation of the'ASHE Code Section XI requirements for testing pumps and valves for opera-tional readiness along with the inservice inspection requirements. Thismeans that in addition to a facility's inservice insection program; a

periodic testing program of selected pumps and valves must also be instituted.

There are now provisions in 550.55a(g) for continued updating of requirementsfor testing pumps and valves and for inservice inspection. The ins rviceinspection program must be updated every 40 months while the pump and val.etestinq program must be updated every 20 months. Furthermore, the regulationspecifies action to be taken by a licensee when an upoated inser vice inspec-tion or testing program conflicts wi th the Technical Specifcations, or whena requirement contained in a referenced ASl1E Code Edition or Addendum isdeemed impractical by the licensee due to design, geometry, or materialconsider ations.

Other provisions in 550.55a(g) allo« the tlRC to grant relief from ASllECode requirements that have been determined to be impractical for a facility

. and specificallv allow the HRC to require a licensee to follow an augmentedinservice inspection program on components for which added assurance ofstructural reliability is needed.

Selected provisions of the revised regulation ar e discussed below.

III. General Guidance for Compliance with 'Three Key Provisions of 50.55a(g):

A. U datin Inservice Inspection and Testinq Pro rams-——Para ranh .sea n e :

I

The inservice inspection program for a facility must be updated at 40month intervals, while the program for testinq pumps and valves foroperational readiness must be updated every 20 months. A descriptionof the updated programs should be submitted to the llRC for review andaporoval as far in advance as possible of, but at least 90 days before,—the start of each period. The information the HRC will need for itsreview of updated programs is identified in Appendix A (attached).

i

Under 550.55(g)(4), the revised inservice inspection and testingprograms must, to the extent practical, comply with the requirementsin editions and addenda to the ASllE Code that are "in effect" no morethan 6 months before the star t of the period for which the updatedprogram is applicable. The tems "in .effect" or "effective", as usedin >50.55a(g)(4), identify those editions and addenda to the ASllE Codethat have been published by the AStlE and that are al so referenced inparagraph (b) of 550.55a.

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para ra h (b) of 550.55a is amended eriodically to incor orate more recentg P P. PASHE Code Editions and Addenda. However, the regulations are not amendeduntil after the published AS"iE Code Editions and Addenda have been reviewedand endorsed by the HRC. Therefore, the AS'lE Code Edition and Addenda thatare applicable to any inspection .period are those referenced in paragraph { b)of 550,55a on the date that corresponds to 6 months before the start of theperiod in question.

If amendments to paragraph (b) of 550.55a become effective on a date thatfalls between the date that marks 6 months before the start of a inspectionperiod and the start date itself, the licensee is not required to complywi th the newly referenced AShE Code Editions and Addenda. Under the regu-lation, the licensee need only comply with the AS|K Code Editions andAddenda that were referenced in paragraph (b) of 550.55a 6 months beforethe start of the period in question. On the other hand, the regulationdoes not preclude compliance with the later referenced editions and addendaif the licensee chooses, but the document that describes each new inserviceinspection or testing program should state which ASNE Code Edition and Addendawill be used.

An inservice inspection or testing program does not comply with 550, 55a( q)(4 )if it is based on an ASllE Code Edition or Addendum which is not or has notbeen referenced in paragraph (b) of 650.55a.

B. Conformin the Technical Snecifications to an Updated Inservice Inspectionor Testin Prooram ----- Paraara h au.s a q s iiIf a revised (updated) inservice inspection or testing program conflictswith the Technical Specifications for a facility,'he licensee must proposchanges to the Technical Specifications to conform them to the updated pro-gram. This must be done at least 6 months before the start of the periodin which the program becomes applicable.

Technical Specifications are considered to be "in conflict" only in caseswhere the requirements of the regulation ( thus the requirements of theupdated program) are more restrictive than the requirements of the Tech-nical Specifications. In such cases the licensee must propose changes toconform the Technical Specifications to the revised program. In cases wherethe updated progam is less restrictive than a particular Technical Specifi-cation requirement, the licensee must continue to comply with the TechnicalSpecifications until he requests and is issued a Technical Specificationchange. The flRC staff will review such a proposed technical Specificationchange to determine if it is acceptable or whether the existing reqire-ment should be retained as an augmented requirement pursuant to550.55a(g)(6)(ii).

In the tJRC Staff's view, the most efficient way to eliminate existing orpotential conflicts from the Technical Specifications is for licensees topropose Technical Specification changes that would substitute standardlanguage referencing 50.55a(g) in the place of existinq inserviceinspection and testing requirments. This should be done at least6 months before the start of the first 40-month inspection periodfor which 50. 55a( g) is applicable. Sample language for this purposewas sent to licensees earlier this year.

The lJRC strongly recommends that licensees adopt the apnroach of referenc-ing 50.55a(g), because such referencing will simplify the TechnicalSpecifications by deleting any requirements that are duplicated in theregulation. It will also alleviate the need for changes whenever an

inservice inspection or testing program is updated. This approach has

the added advantage of eliminating the scheduling pressures associatedwith n eting the 6 months submittal tine reouirement for Technical Sp.c-ification changes proposals of 50. 55a( g)(2 )(ii). It will also simplifythe process by which licensees request, and the JJRC grants, relieffrom ASiJE Code requirements that have been determined to be impractical.This is because license amendments (i.e., Technical Specificationchanges) will not be necessary to grant relief.

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Relief from ASNE Code requirements that are deemed impractical for a facilityis further discussed below.

C. Obtaininc Relief from ASIDE Code Renuire~ents Determined to be Imnractical --—-Para ra h 50.55a a) 5 (iii and 6 i

If certain AS!JE Code requirements are found to be impractical by the licensee,the regulation requires him to notify the NRC and submit information to suoporthis findings. The licensee should submit requests for relief from ASl1E Code

requirements that he has determined to he impractical at least 90 days beforethe start of the applicable inspection period. The information that is needed

by the JJRC Staff to evaluate requests for relief from requirements found to be

impractical is identified in Appendix 8 (attached).

The NRC Staff will evaluate licensee requests for relief and will grant relief,if appropriate, pursuant to 50.55a(g)(6)(i). Unless a licensee is otherwisenotified bv the JJRC, relief from ASJJE Code requirements will remain aoplicabluntil the end of each 120-month period. At that time, the HRC will re-evaluatethe basis for the determination that the requirement is impractical, pursuantto 50.55a(g)(5)(iv). This re-evaluation will take into account any advancesin the state-of-the-art of inservice inspection techniques that may haveoccurred since the relief was originally qranted.

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Generally, the licensee will know well in advance of the beginning of anyinspection period, whether or not a particular AWE Code requirement willbe impractical for his facility. Thus, the licensee should request relieffrom ASl<E Code requirenents as far as possible in advance of, but notless than 90 days before, the start of the inspection period. Earlysubmittals are particularly important for the first 40-month inserviceinspection and 20-month pump and valve testing period because they willenable the t>RC staff to evaluate the information received from all licenseesand determin which AS lE Code requirements may be generally impracticalfor various classes of plants. Early submittals will thereby facilitateearlier feedback to licensees regarding the acceptability of their requests.

The HRC Staff recognizes that it will not be possible in all cases for alicensee to determine in advance that any particular AShE Code require-ment will be inpractical for his facility. In cases where, during theprocess of inspection of testing, certain requirements are found to beimpractical due to unforseen circumstances, the licensee may request reliefat that time. These occurrences are not expected to be many and are expectedto result in only minor changes to an inservice inspection or testing progran.

All relief from ASHE Code requirements that are determined to be impracticalfor a facility will be granted in the form of a letter within the provisionsof 550.55a( g)(6 )(i). This written'elief should be incorporated into thedocument describing the inservice inspection and testing pr ogran retainedby .the licensee. f~otice of the granting of relief from ASHE Code requi re-

... ments will be published in the FEOERAL RcGISTER, but the written relief..itself will not become an 'explicit part of the facility license or the

Technical Specifications.

:0APPENDIX A

IHFORNTIOH REQUIRED FOR ttRC REVI W

I

OF IHSERVICE IWSPECTIOH AttD TESTI ttG PROGRAMS

'1. Inservice Inspection Programs:

The information submitted for HRC review should include*, as a minimum:

a. Identification of the applicable ASNE Boiler and Pressure VesselCode Edition and Addenda

b. The period for which the program is applicable

c. Identification of all of the specific components and parts to beexamined for each ASME Code Class {i.e., each Quality Group as definedin Regulatory Guide 1.26, "Quality Group Classifications and Standardsfor Water -, Steam -, and Radioactive-ltaste-Containing Components ofHuclear Power Plants" ), and the inspection intervals for each Classor Quality Group

d. For each specific component and part; specification of:

i) The examination category as defined in ASME Section XI

ii) The examination method to be used

iii) The repair requirements

2. 'ump and Valve Testing Programs

The information submitted for HRC review should include*, as a minimum:

a. Identification of the applicable ASNE Code Edition and Addenda

b. The period for which the prograra is applicable

c. For Pump Testing: identify:

i) each pump to be tested (name and number)

ii) the test parameters that will be measured

$ ii) the test intervals, i.e., monthly during operation, only duringcold shutdown, etc,

*Specific written relief from the HRC is required to exclude any'ASME Section XICode requirements,

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d., For Valve Testing; identify:

i) each valve in ASHE Section XI Categories A h 8 that will beexercised every 3 months during normal plant operation (indicatewhether partial or full stroke exercise).

ii)

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each valve in AStiE Section XI Category A that will be leak testedduring refueling outages.

all valves in ASliE Section XI Categories C, D, and E, that willbe tested, the type of test and the test frequency. For checkvalves, identify those that will be exercised every 3 months andthose. that will only be exercised during cold shutdown.

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: ~APPEWDIX B

IHFORtlATION REOUIRED FOR tlRC REYIEM OF REQUESTS FOR RELIEF FROtlASHE CODE SECTIGtl Xl REQUIREl1EHTS DETERllltKD TO BE If'PRACTICAL

l. Identify component for which relief is requested:

a. Name and number as given in FSAR

b. Function

c. ASliE Section III Code Class

d, For valve testing, also specify the AStlE Section XI valve category asdefined in I'rlY-2000.

2. Specifically identify the AS)lE Code requirement that has been determined tobe impractical for component.

3. Provide information to support the determination that the requirement in (2)is impractical; i.e., state and explain the basis for requesting relief.

4. Specify the inservice inspection (or testing) that will be performed in lieuof the ASNE Code Section XI requirements that have been determined to beimpractical.

5. Provide the schedule for implementation of the procedure(s) in (4 ) above.

Enclosure 2

HRC STAFFGUIOELIHES FOR EXCLUOIHG EXERCISIHG

CYCLIHG TESTS OF CERTAIH VALVESDURIHG PLAflT OPERATIOH

Any valve which when exercised (cycled) could put the plant in an unsafe conditionshould not be tested. Below are some examples of the types of valves that shouldbe specifically excluded from exercising (cycling) tests during plant operation:

l. All valves whose failure in a non-conservative position during the cyclingtest would cause a loss of system function should not be exercised. Valvesin this category would typically include all non-redundant valves in linessuch as a single discharge line from the refueling ~ater storage tank,or accumulator discharge lines in PMR's and the HPCI turbine steam supplyand the HPCI pump discharge in BHR's. Other valves may fall into thiscategory under certain system configurations or plant operating modes. Forexample, when one train of a redundant system such as ECCS is inoperable,non-redundant valves in the remaining train should not be cycled since theirfailure would cause a loss of total system function.

2. All valves, whose failure to close during a cycling test would result in 'a

loss of containment integrity. Valves in this category would tvpicallyinclude all valves in containment penetrations where the redundant valveis open and inoperable.

3. All valves, which when cycled, 'could subject a system to pressures in excess, of their design pressures. It is assumed for the purpose of a c'ycling test,

that one or more of the upstream check valves has failed unless positive .methods are available for determining the pressure or lack thereof on thehigh pressure side of the valve to be cycled. Valves in this categorywould typically include the isolation valves of the residual heat removal/shutdown cooling system and, in some cases certain ECCS valves;

*All ASt)E Section XI Category A and 8 valves should be cycled, as practicable,at each cold shutdown, but need not be cycled more often than once every 3months.

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