1. 1 ISTOG Position on Pre-conditioning ISTOG Input on Interpretation and Clarification Of NUREG-1482 Sections 3.5 / 3.6

2. 2 History: 1995 NUREG-1482 – Section 3.6 Section 3.6 entitled: “Testing in the As-Found Condition” Not Code required except for S&RVs No As-Found definition for S&RVs No activity that affects as-found permitted Pre-stroke or maintenance hides degradation mechanisms Position statement that most IST is performed at accident conditions NRC Recommendation: Clarification Only

3. 3 Current: 2005 NUREG-1482 – Sections 3.5 & 3.6 Section 3.5 entitled: “Pre-Conditioning of Pumps and Valves” 3.5.1 – Background 3.5.2 – NRC Guidance 3.5.3 – ASME Code Guidance 3.5.4 – NRC Recommendation Section 3.6 entitled: “Testing in the As-Found Condition” – Similar to 1995 NUREG-1482, Section 3.6

4. 4 ISTOG INPUT on 3.5.1 (Paragraph 1) 10CFR50 App. B - Criterion XI - Test Control: –Licensees must establish test program for SSCs Demonstrate satisfactory service using written procedures –Test Procedures to include provisions that ensure: Test prerequisites have been met Use of adequate test instrumentation Test performed under suitable environmental conditions –Document test and evaluate against requirements (Paragraph 1) Effective assessment of operational readiness must tie test performance to accident conditions (Paragraph 2) Discusses 1995 as-found position that IST is performed at accident conditions

5. 5 Proposed Position Statement: NUREG-1482, Section 3.5.1, Background: Paragraph 1: No clarification provided. (ISTOG INPUT NEEDED) Paragraph 2: Clarified that the NUREG-1482 statement “…IST is performed at accident conditions” is understood to mean that only some IST may be performed at accident conditions. Such testing is generally performed to meet Technical Specifications test requirements, or is performed when testing pressure relief devices in accordance with the ASME OM Code Mandatory Appendix I. Other than pressure relief devices, the ASME OM Code does not require any pump or valve testing to be performed at accident conditions. (ISTOG INPUT NEEDED) ISTOG INPUT on 3.5.1 (continued)

6. 6 ISTOG INPUT on 3.5.2 (Paragraph 1) Reiterated IN 97-16 preconditioning points –Unacceptable preconditioning –Some preconditioning is acceptable When needed to prevent equipment damage When safety benefit outweighs as-found testing (Paragraph 2) Identifies additional guidance provided by staff to NRC regional offices/inspectors (Paragraph 3) Notes that identified guidance “is instructive” for plant personnel in assuring that IST can assess operational readiness

7. 7 ISTOG INPUT on 3.5.2 (continued) (Paragraph 4) Preconditioning definition quoted as follows: “alteration, variation, manipulation, or adjustment of the physical condition of an SSC before Technical Specification surveillance or ASME Code testing” (Paragraph 4) Again addresses acceptable preconditioning –To protect personnel or equipment –To meet manufacturer’s recommendations –Based on industry-wide operating experience –Infrequent preventive maintenance (stem lub / pump venting) (Paragraph 4) Acceptable preconditioning evaluation should be documented pre-IST and include effect on ability to assess operational readiness (NEEDS CLARIFICATION)

8. 8 (Paragraph 5) Activities that constitute unacceptable preconditioning under IST Program: –Routinely conducted maintenance prior to testing performed in order to help ensure that the test is passed satisfactorily … duh –Consider activities related to several SSC’s including scheduling / timing of such activities (Paragraph 6) Inspection manual questions … any ‘yes’ answer implies unacceptable preconditioning: –(Two questions involving activities performed to pass IST) –Does the practice bypass or mask the as-found condition of the pump or valve? –Is preventive maintenance routinely performed on the pump or valve just before testing? –Is preventive maintenance on the pump or valve performed only for scheduling convenience? (Paragraph 7) Licensees should consider the above questions in evaluations ISTOG INPUT on 3.5.2 (continued)

9. 9 Proposed Position Statement: NUREG-1482, Section 3.5.2, NRC Guidance: Paragraph 1: No clarification provided. (ISTOG INPUT NEEDED) Paragraph 2: No clarification provided. (ISTOG INPUT NEEDED) Paragraph 3: No clarification provided. (ISTOG INPUT NEEDED) Paragraph 4: Clarified that many industry testing procedures have been developed without any requirement or guidance to evaluate and document preconditioning activities as acceptable. See the stated position regarding when documentation is recommended. (ISTOG INPUT NEEDED) Paragraph 5: No clarification provided. (ISTOG INPUT NEEDED) Paragraph 6: No clarification provided. (ISTOG INPUT NEEDED) Paragraph 7: No clarification provided. (ISTOG INPUT NEEDED) ISTOG INPUT on 3.5.2 (continued)

10. 10 ISTOG INPUT on 3.5.3 (Paragraph 1) NRC states that the ASME Code relies on licensee to determine if pre-IST activities are acceptable or unacceptable, except: –Per App. I, Sections I-3300 and I-7300, activities are not allowed that could affect pressure relief device as- found set-pressure or seat tightness –Per OMN-1, Section 3.3, IST of MOVs in as-found condition, and no maintenance allowed that could invalidate that condition (Paragraph 1) NRC states that where the ASME Code does not specify as-found IST, the licensee determines whether activities constitute acceptable or unacceptable preconditioning

11. 11 ISTOG INPUT on 3.5.3 (continued) (Paragraph 1) NRC states that the ASME Code relies on licensee to determine if pre-IST activities are acceptable or unacceptable, except: –Per App. I, Sections I-3300 and I-7300, activities are not allowed that could affect pressure relief device as-found set-pressure or seat tightness –Per OMN-1, Section 3.3, IST of MOVs in as-found condition, and no maintenance allowed that could invalidate that condition (Paragraph 1) NRC states that where the ASME Code does not specify as-found IST, the licensee determines whether activities constitute acceptable or unacceptable preconditioning

12. 12 Proposed Position Statement: NUREG-1482, Section 3.5.3, ASME Code Guidance: Paragraph 1: No clarification provided. (ISTOG INPUT NEEDED) ISTOG INPUT on 3.5.3 (continued)

13. 13 ISTOG INPUT on 3.5.4 (Paragraph 1) IN 97-16 and NRC Inspection Manual Part 9900 provide examples of acceptable and unacceptable preconditioning in referenced documents. (Paragraph 1) Staff expects a documented evaluation of each instance of acceptable precondition and a justification for continued confidence in the capability of the IST program to assess the operational readiness of the pump or valve. (Paragraph 1) Stated acceptable preconditioning activities include: –Periodic venting of pumps, which is not routinely scheduled directly prior to testing but may occasionally be performed before testing. –Pump venting directly prior to testing, provided that the venting operation has proper controls with a technical evaluation to establish that the amount of gas vented would not adversely affect pump operation.

14. 14 ISTOG INPUT on 3.5.4 (continued) (Paragraph 1) Stated acceptable preconditioning activities include: –Occasional lubrication of a valve stem prior to testing of the valve, where stem lubrication is not typically performed prior to testing. –Unavoidable movement attributable to the setup and connection of test equipment (Paragraph 2) Stated unacceptable preconditioning activities include: –Routine lubrication of a valve stem prior to testing the valve. –Operation of a pump or valve shortly before a test, if such operation could be avoided through plant procedures with personnel and plant safety maintained. –Venting a pump immediately prior to testing without proper controls and scheduling. (Paragraph 2) Licensees encouraged to evaluate NRC staff documents and contact resident / project manager

15. 15 Proposed Position Statement: NUREG-1482, Section 3.5.4, NRC Recommendation: Paragraph 1: No clarification provided. (ISTOG INPUT NEEDED) Paragraph 2: No clarification provided. (ISTOG INPUT NEEDED) ISTOG INPUT on 3.5.4 (continued)

16. 16 Proposed Position Statement: NUREG-1482, Section 3.6, Testing in the As-Found Condition: Paragraph 1: No clarification provided. (ISTOG INPUT NEEDED) Paragraph 2: No clarification provided. (ISTOG INPUT NEEDED) ISTOG INPUT on 3.6