Guidance on Developing Acceptable Inservice Testing Programs (Generic Letter 89-04, Supplement 1)

				                 UNITED STATES
                         NUCLEAR REGULATORY COMMISSION
                     OFFICE OF NUCLEAR REACTOR REGULATION
                            WASHINGTON, D.C.  20555

                                 April 4, 1995


NRC GENERIC LETTER 89-04, SUPPLEMENT 1:  GUIDANCE ON DEVELOPING ACCEPTABLE
                                         INSERVICE TESTING PROGRAMS


Addressees 

All holders of operating licenses or construction permits for nuclear power
reactors.

Purpose

The U.S. Nuclear Regulatory Commission (NRC) is issuing this generic letter to
notify addressees that it is issuing NUREG-1482, "Guidelines for Inservice
Testing Programs at Nuclear Power Plants."  NUREG-1482 contains
recommendations that addressees may follow in developing and implementing
inservice testing programs and includes the positions from Generic Letter (GL)
89-04, "Guidance on Developing Acceptable Inservice Testing Programs,"
supplemented with current considerations for using these positions.  

Description of Circumstances

NUREG-1482 describes historical and current perspectives on the regulatory
requirements for inservice testing of pumps and valves in nuclear power
plants.  It includes information on the format and content for inservice
testing programs and relief requests, examples of relief requests,
clarification of issues described in information notices or other NRC letters
on inservice testing, and current considerations for positions in GL 89-04. 
Many of the recommendations relate to issues that either are not addressed in
the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel
Code (the Code), were not considered in the development of the Code
requirements, or have been identified at a group of plants that were built
prior to the promulgation of requirements for inservice testing.  Because the
staff has received a number of similar relief requests, the general guidance
will allow for greater efficiency in licensee preparation and the staff review
of these submittals.

In Appendix G to the NUREG report, the staff responds to public comments
received on the draft NUREG-1482 published in 1993.  The information has also
been incorporated into the text of the final NUREG as appropriate.  Addressees
may obtain copies of NUREG-1482 from the Superintendent of Documents, U.S.
Government Printing Office, P.O. Box 37802, Washington, D.C. 20013-7082.





9503280042.                                               GL 89-04, Supp. 1
                                                            April 4, 1995
                                                            Page 2 of 3


Discussion

Addressees may use NUREG-1482 as guidance for developing IST programs.  The
intent of the guidelines document is, in part, to provide the required
"Commission approval" pursuant to 10 CFR 50.55a(f)(4)(iv) to allow licensees
to implement portions, as listed in Attachment 1, of the 1989 Edition of the
ASME Code incorporated in 10 CFR 50.55a(b) without further submittals of
formal "relief requests."  Other portions may be used in IST programs subject
to receipt of specific Commission approval.  No new staff interpretations are
imposed on licensees.  The remaining recommendations provide guidance on the
information that should be included in relief requests and provide specific
details for those requests that have generic applications.

Requested Information

Licensees who voluntarily choose to use the guidance in NUREG-1482 to make
changes to their inservice testing programs may need to submit revised relief
requests or program documents to NRC if such documents are affected.  Use of
the guidance does not necessarily require any information to be submitted.

Licensees who do not modify their inservice testing programs are not expected
to submit any response to this generic letter.

Required Response

All addressees who voluntarily choose to use the guidance in NUREG-1482 to
make changes to their inservice testing programs are required to submit a
response to the previously requested information, if appropriate.  

Address the required written reports to the U.S. Nuclear Regulatory
Commission, ATTN:  Document Control Desk, Washington, D.C. 20555, under oath
or affirmation under the provisions of Section 182a, Atomic Energy Act of
1954, as amended, and Section 50.54(f) of Title 10 of the Code of Federal
Regulations (10 CFR 50.54(f)).

Backfit Discussion

This generic letter only requests applicable information under the provisions
of 10 CFR 50.54(f) from addressees who voluntarily choose to use the guidance
in NUREG-1482 to make changes to their inservice testing programs.  Therefore,
the staff has not performed a backfit analysis.  The information requested is
needed to evaluate voluntary changes to the inservice testing programs in
response to the information in this generic letter.

The evaluation required by 10 CFR 50.54(f) to justify this information request
is included in the preceding discussion.

Federal Register Notification

A notice of opportunity for public comment on this generic letter and the
draft NUREG-1482 was published in the Federal Register (58 FR 65738) on .  
                                                          
                                                           GL 89-04, Supp. 1
                                                            April 4, 1995
                                                            Page 3 of 3


December 16, 1993.  In Appendix G to the NUREG report, the staff responds to
public comments received.  The information has also been incorporated into the
text of the final NUREG as appropriate.  

Paperwork Reduction Act Statement

The voluntary information collections contained in this request are covered by
the Office of Management and Budget clearance number 3150-0011, which expires
July 31, 1997.  The public reporting burden for this voluntary collection of
information is estimated to average 40 hours per response, including the time
for reviewing instructions, searching existing data sources, gathering and
maintaining the data needed, and completing and reviewing the collection of
information.  Send comments regarding this burden estimate or any other aspect
of this voluntary collection of information, including suggestions for
reducing this burden, to the Information and Records Management Branch 
(T-6 F33), U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, and to
the Desk Officer, Office of Information and Regulatory Affairs, NEOB-10202,
(3150-0011), Office of Management and Budget, Washington, D.C. 20503.

Compliance with the following request for information is purely voluntary. 
The information would assist NRC in evaluating the cost and benefits of
inservice testing program changes associated with this generic letter:

(1)   the licensee staff time and costs to prepare any changes to the
      inservice testing program and 

(2)   an estimate of the long-term costs or savings accruing as a result of
      implementing any changes to the inservice testing program

If you have any questions about this matter, please contact the technical
contact listed below or the appropriate Office of Nuclear Reactor Regulation
(NRR) project manager.

                                    /s/'d by BKGrimes/for


                                    Roy P. Zimmerman
                                    Associate Director for Projects
                                    Office of Nuclear Reactor Regulation


Technical contact:      Patricia Campbell, NRR
                        301-415-1311

Lead Project Manager:   Jacob Zimmerman, NRR
                        301-415-2426


Attachments:
1.  Approved Code Editions, Addenda,
      or Portions Thereof.                                  Attachment 1
                                                            GL 89-04, Supp. 1
                                                            April 4, 1995
                                                            Page 1 of 2


             Approved Code Editions, Addenda, or Portions Thereof


Section 50.55a of Title 10 of the Code of Federal Regulations (10 CFR 50.55a)
defines the requirements for applying industry codes and standards to boiling
or pressurized water-cooled nuclear power facilities.  Each of these
facilities is subject to the conditions in paragraphs (a), (f), and (g) of
10 CFR 50.55a for inservice inspection and inservice testing (IST).  By
rulemaking effective September 8, 1992 (see Federal Register Vol. 57, 34666),
the U.S. Nuclear Regulatory Commission (NRC) established paragraph (f) to
separate the IST requirements from the inservice inspection requirements in
paragraph (g).  The American Society of Mechanical Engineers (ASME) Boiler and
Pressure Vessel Code (the Code), Section XI, Subsections IWP and IWV, specify
the IST requirements for pumps and valves.  The 1989 edition of Section XI was
incorporated by reference into paragraph 50.55a(b) by the rulemaking effective
September 8, 1992.  The 1989 edition specifies that the rules for the IST of
pumps and valves are stated in the ASME/ANSI Operations and Maintenance (OM)
Standards, Part 6, "Inservice Testing of Pumps in Light-Water Reactor Power
Plants," and Part 10, "Inservice Testing of Valves in Light-Water Reactor
Power Plants."  An exception to OM-10 was taken in the regulation related to
leakage testing of containment isolation valves (see 10 CFR 50.55a
(b)(2)(vii).  

NUREG-1482, "Guidelines for Inservice Testing at Nuclear Power Plants,"
discusses OM-6 and OM-10, which may be implemented by licensees pursuant to
10 CFR 50.55a (f)(4)(iv).  NUREG-1482, through the staff's endorsement in the
generic letter supplement, gives the requisite approval for 10 CFR 50.55a
(f)(4)(iv) for updating an IST program to the requirements of OM-6 and OM-10
(and OM-1 through reference in OM-10) provided the licensee documents the use
of OM-6 and OM-10 in the IST program.  The NUREG, through the generic letter
supplement per (f)(4)(iv), also gives approval to implement selected portions
of OM-6 and OM-10 as discussed in the following sections of NUREG-1482:  

      3.1.1 Deferring Valve Testing to Cold Shutdown or Refueling Outage

      3.3.2 Concurrent Intervals (in part)

      4.1.4 Extension of Test Interval to Refueling Outage for Check Valves
            Verified Closed by Leak Testing

      4.2.5 Verification of Remote Position Indication for Valves by Methods
            Other Than Direct Observation

      4.2.7 Stroke Time Measurements Using Reference Values

      4.3.3 Test Supervisor Qualifications
.                                                            Attachment 1
                                                            GL 89-04, Supp. 1
                                                            April 4, 1995
                                                            Page 2 of 2


      4.3.4 Frequency and Method of Testing Automatic Depressurization Valves
            in Boiling Water Reactors

      4.4.3 Multiple Containment Isolation Valve Leak-Rate Testing

      4.4.5 Leak-Rate Testing Using OM-10 Requirements

      5.1.2 Continued Measurement of Parameters Deleted from OM-6

      5.3   Allowable Variance from Reference (for fixed resistance systems)

      5.4   Monitoring Pump Vibration Per OM-6

      5.7   Use of OM-6 Table 3b Ranges for Hydraulic Parameters

      5.8   Duration of Tests