Issue Date: 05/12/86 - 1 - 9900 ASME Section XI

NRC INSPECTION MANUAL DI

PART 9900: TECHNICAL GUIDANCE

ASMEXIB.TG

AMERICAN SOCIETY OF MECHANICAL ENGINEERS

ASME, SECTION XI

A. PURPOSE

To provide guidance on testing normally closed check valves

specified in paragraph IWV-3520 of the ASME Code Section XI, 1983

Edition, as provided by an NRR memorandum dated April 18, 1985.

B. BACKGROUND

There is no apparent requirement in Section XI of the ASME Code to

verify closure of normally closed check valves that are classified

Category C according to Subsection IWV. The majority of

safety-related check valves are Category C valves. During

evaluations of licensing actions related to pump and valve inservice

inspection (ISI) programs, it was generally found that periodic

closure testing is done only for containment isolation check valves

and check valves that protect low pressure systems outside

containment from reactor pressure. Consequently, Category C check

valves could in many cases have the valve internals entirely missing

and yet pass all preoperational and periodic tests now normally

done.

In response to a Region III request, NRR has provided the following

guidance concerning check valve testing.

C. DISCUSSION

Region III made a statement to NRR that verification of the closure

function of normally closed check valves is a generic safety concern

to the extent that surveillance testing is usually not performed

after plant construction to reverify the closure function. Guidance

was requested for testing of normally closed check valves for (1)

closure capability during preoperational testing and (2) closure

capability during plant life.

The NRR position was that normally closed check valves, that have

a safety function in the closed position, other than containment

isolation valves (CIVs) and pressure isolation valves (PIVs), should

have the closure function verified both during preoperational
9900 ASME Section XI - 2 - Issue Date: 05/12/86

testing and periodically throughout the plant life. In NRR's normal

review of the inservice testing (IST) programs, whenever a valve of

this type is identified, NRR verifies that closure verification

testing is specified in the IST program, and if not, NRR either

requires that the program
Issue Date: 05/12/86 - 3 - 9900 ASME Section XI

be revised to so specify or NRR specifies in the IST SER that

closure testing must be performed.

Even though that is the position that NRR has been implementing, NRR

does believe that there is some ambiguity within ASME Section XI

regarding closure verification testing of normally closed check

valves. Check valve testing is specified in paragraph IWV-3520 of

the 1983 Edition of Section XI. Paragraph IWV-3522, "Exercising

Procedure," requires that check valves be periodically exercised to

the position required to fulfill their function. Testing intervals

required vary from a minimum of every three months to each cold

shutdown (Earlier editions of Section XI are essentially the same).

The Code ambiguity arises from the fact that paragraph IWV-3522(b),

"Normally Closed Valves" discusses in detail the performance of

tests for periodic verification of the valve opening function but

does not specifically mention periodic closure verification tests.

In an attempt to have ASME clarify the ambiguity in the Code

paragraphs, NRR submitted a related inquiry to the ASME society;

however, the response to the inquiry was inconclusive. The NRR

inquiry was written in broad terms to cover both check and gate

valves used in applications where the valve disk in the closed

position was essential to the fulfillment of the valve's

safety-related function. The inquiry asked whether such valves

should be categorized as A or AC and leak tested in accordance with

paragraph IWV-3420.

If the ASME response was "no" to the A or AC categorization and leak

tests, it was hoped that the reply would confirm that the intent of

IWV-3522 for check valves and IWV-3412 for gate valves was that some

kind of closure verification test was to be performed. However, the

response that was received concentrated on the categorization aspect

of the inquiry and simply stated that categorization is the Owner's

(licensee's) responsibility.

Nevertheless, NRR personnel that participate in ASME Section XI

standards writing activities were present at some of the meetings

when the inquiry was discussed. The impression received at the

meetings was that the intent of the Code for check valves and gate

valves was that periodic verification of closure function is

required for valves, whether normally open or closed, if they

perform a safety function in the closed position. Verification also

would be required during preoperational testing by paragraph

IWV-3100, "Preservice Tests," which requires that all tests to be

performed periodically during plant life per IWV-3000 also be

performed after installation and prior to service.

One additional item that supports the requirement for periodic

closure verification testing is that the latest draft of ANSI/ASME

OM-10, "Inservice Testing of Valves," specifically requires that

check valves be exercised or examined in a manner which verifies

obturator travel to the closed, fully open, or partially open

position required to fulfill its function. ANSI/ASME OM-10 is

expected to be an eventual replacement for subsection IWV of ASME

Section XI.
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D. CONCLUSION

The NRR position is that normally closed check valves, that have a

safety function in the closed position, should have the closure

function verified both during preoperational testing and

periodically throughout the plant life.

E. REFERENCE

The guidance provided in this directive was extracted from a

memorandum from Hugh L. Thompson, Jr., Director, Division of

Licensing, NRR, for Richard L. Spessard, Director, Division of

Reactor Safety, Region III, dated April 18, 1985, subject: Closure

Verification of Normally Closed Check Valves During Preoperational

Testing at Callaway (TIA 83-117). The complete memorandum is in the

Document Control System (DCS microfiche #67820-200).

END