DECEMBER 2010 ISTOG MEETING NEW Q & A CARD DISCUSSION

QUESTION 1 A recent ISTOG Forum question: Q: When is the need to use electrical jumpers (to satisfy permissive or interlock signals) sufficient basis for deferring quarterly stroke time test to cold shutdown and/or refueling? A: It is a case-by-case situation. Some guidance is in NUREG 1482 R1. Risk considerations could be used to justify a written practicability justification for cold shutdown. It was noted that if this is being performed already, precedent has been set and it would be hard to justify not doing the test anymore.

QUESTION 2 Q: Considering the following ISTC-1200 statement, what is meant by the term “specific function”? For example, most vent and drain valves in safety related systems have a function to remain closed for system pressure boundary/inventory purposes. Does this mean they are NOT exempt? A: No, specific function refers to an active or passive function to perform the function described by ISTA An example presented 2 MOV’s used only for maintenance in a pipeline that cause the system to be declared inoperable if they are closed for use. They fail open unless the system is inoperable. No consensus could be reached to say these are exempt or passive (50% to 50% answers). ISTC-1200 Exemptions The following are excluded from this Subsection, provided that the valves are not required to perform a specific function as described in ISTA-1100: (a) valves used only for operating convenience such as vent, drain, instrument, and test valves; (b) valves used only for system control, such as pressure regulating valves; and (c) valves used only for system or component maintenance. Excerpt from ISTA-1100 (a) pumps and valves that are required to perform a specific function in shutting down a reactor to the safe shutdown condition, in maintaining the safe shutdown condition, or in mitigating the consequences of a accident

QUESTION 3 Poll: Does your plant treat IST related pump and valve tests as Tech Spec surveillances (e.g., Tech Spec scheduling, failure to meet acceptance criteria renders component inoperable and LCO actions are considered)? Only 1 site answered no. Site answering no uses Improved Standard Technical Specifications (TS 5.5.8). Only SR required items referencing the IST Program are in the Surveillance Program.

QUESTION 4 Q: Can vibration measuring equipment be set up with a built-in averaging process (like display of total inches/sec. as averaged over last 20 readings 5mSec. apart) and still meet Code instrument requirements? A: No vibration averaging techniques are allowed by the ASME Code (Peak for velocity, Peak to Peak for displacement).

QUESTION 5 Q: Would a full stroke prior to a timed stroke of an MOV or AOV be considered unacceptable preconditioning? AC or DC? A: If the valve has to be exercised quarterly, it is stroked 3 months prior to the stroke time test, which is acceptable. If it is part of the same Inservice test procedure before conducting the stroke time test, it is unacceptable. Everything in between must be considered on a case-by-case basis.

QUESTION 6 Q: Is there some Nominal time frame for IST or CV engineer to update Check Valve Condition Monitoring Programs (add new “history” work, inspections) monthly – yearly – 10 years? A: One example used a 1 year PM. No requirement exists. Evaluation after failure is required. Poll was about 50% to 50% in terms of formal requirement existing.

QUESTION 7 Q: Is a PIT test required for a control valve with position indication and is not required to be fail safe? A: It is exempt ISTC-1200(b), assuming there is not safety function to go from fully open to close or close to open.

QUESTION 8 Q: Can analysis be performed to determine operability to next refueling outage when a pump exceeds alert limit and can only be tested during refueling outage? A: Yes, but the test frequency must be doubled. Relief would be required if it is a comprehensive pump test to justify not shutting down to perform the pump test unless the analysis section could be used to justify the pump is not degraded and new reference values established.

QUESTION 9 Preconditioning: (a)Q: How many plants have a defined process to review and evaluate preconditioning? A: 75% of attendees. (b)Q: What do most sites use as a definition of “immediately prior”? A: Needs a survey. (c)Q: CM work orders w/o declaring component in- op? A: Needs a survey.

QUESTION 10 Q: NUREG 1482 Section scheduling of inservice tests indicates it is acceptable to extend a test interval for safety and relief valves to coincide with the refueling outage. Is this a capability that sites would find valuable to retain? A: Would be useful for the 20% sample requirement. Proposed ISTA change for 25% grace with 6 month max will address other areas.