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OM CODE SUMMARY June 2010 (Bethesda, Md.)

OM CODE SUMMARY June 2010 (Bethesda, Md.). ISTOG Meeting December 2010 Presented by Jeff Neyhard for Ron Lippy. 2. SCOMC/SC. Discussion on going to 2 year Editions of the OM Code and the elimination of Addenda.

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OM CODE SUMMARY June 2010 (Bethesda, Md.)

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  1. OM CODE SUMMARYJune 2010(Bethesda, Md.) ISTOG Meeting December 2010 Presented by Jeff Neyhard for Ron Lippy

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  3. SCOMC/SC • Discussion on going to 2 year Editions of the OM Code and the elimination of Addenda. • OM Code and Section XI to Publish in 2011. After that OM Code will publish in 2012, 2014, 2016… and Section XI and Section III will Publish in 2013, 2015… Note this is still under discussion an will be determined in Dec. 2010 meeting. • Discussion regarding OM-16 Diesel Generators/New DG – Several of the New Reactor designs do not have a “safety related” Diesel Generators. • Discussion on ASME/NRC Symposium in August 2011 in Bethesda Md.

  4. SCOMC/SC • Discussion on NRC Liaison regarding: • Elimination of “grace” for IST tests • Elimination of NUREG 1482 and a New NUREG (1946) issues with minimal Code “recommendations”. • Discussion on Membership changes with NRC (McMurtray for McHale).

  5. SCOMC • Interfacing with the OM-19 Sub-group to “expedite” approval of Appendix IV. • Determined that the SCOMC SHALL maintain “Balance of Interest” as a result of Code Inquiries. This must also be maintained in other cases of voting (e.g. voice vote).

  6. SCOMC Code Inquiries • Process established • OM Secretary receives an inquiry. • Secretary forwards to OMMC and SCOMC Chairs (they review to determine if inquiry should be processed any further). • If additional processing is not needed, Secretary sends letter to inquirer. • If inquiry is to be processed further, Chair & V Chair of SCOMC and Chair of affected SG consult to select members of a Special Committee in accordance with Section B, 13.1.1, of the MOM.

  7. SCOMC Code Inquiries • Process established (Continued) • SG Chair coordinates response development (or determines necessary course of action, with committee member input). • Special Committee reviews and approves inquiry response. • OM Secretary sends inquiry ballot to SCOMC with a 2-week review period. • When approved, OM Secretary sends completed inquiry response to OMMC Chair for issue to inquirer.

  8. SCOMC New Reactor Seminar – Bethesda, Md. • Good attendance - 130 • Next one in Charlotte NC in June 2011 • Three Sessions: • Design • Construction/Startup • Preservice/Preoperational

  9. SCOMC Grace Period Discussion: The Current OM Code does not contain provisions for an IST “grace period” similar to that contained in Licensees Technical Specifications (TS). The Code also does not contain any provisions related to a missed IST. These issues were raised due to recent NRC concerns about the application of TS provisions for non-TS specific surveillances. The SCOMC agreed that the OM Code should include requirements for both issues and agreed to draft a proposed changed prior to the December 2010 meeting.

  10. ISTA Subgroup ISTA—General Requirements • V-08-01C (Task Item) – Determine that a code change is going to be written to clarify the remote valve position indication requirements of Table ISTC-3500-1 and ISTC-3700. Discussion on Valve Position Indication clarification. - Code change to clarify that VPI testing is required for: - Both directions for valves with remote position indication for both Active and Passive Valves.

  11. ISTA Subgroup ISTA—New Actions • ISTD changes to ISTA sections. • V07-04A (Task Item) - The Subgroup discussed the Code changes to ISTA/ISTC that were proposed by the ISTD Subgroup. The proposed changes had evolved from a Fort Calhoun informal Inquiry regarding the requirements of ISTA-3120, 3130 and 9220(b) and their applicability to ISTD. Ballot was closed on June 10, comments to be reviewed by PM. New Reactor Code Changes to ISTA and ISTC

  12. ISTA Subgroup ISTA—New Actions • Clarification and code change regarding ISTA-3200 providing that the IST plans shall be filed in accordance with the requirements of the regulatory authority having jurisdiction at the plant site.

  13. ISTA Subgroup ISTA Inquiries Inquiry 09-1312 Is it a requirement of ISTA-9220(b) to have a coversheet attached to every single documented test record? No. Still being discussed. New Reactors New Reactor Code Changes to ISTA and ISTC NROMC Ballot for White Paper and Code markups to ISTA, ISTB, ISTC, ISTE has been issued and comment review period closed. Comments received and evaluated/incorporated and Ballot for vote for NROMC is finalized . Should publish the NROMC in 2011.

  14. ISTC Subgroup ISTC-Valves • Informal Inquiry on Reach Rods and whether or not the “reach rod” actuator requires testing with the valve. Unanimous that yes the testing of manual valves requires the testing of the “reach rod” as well, UNLESS the safety related operation of the valve does NOT include the use of the reach rod. • OMN-8 (Control Valves) is being revised for applicability and being incorporated into OM Code, ISTC-5100. OMN-8, revision 1 should be in the 2011 edition of the OM Code.

  15. ISTC Subgroup ISTC-Valves • Appendix IV (AOVs)—Should be published in 2011 • Risk Informing AOVs • Acceptance Criteria • Standardization of Requirements • HOVs will not be included initially • Methods of “evaluating” AOV condition – Stroke Timing and diagnostics. • Determination of testing for JOG Category 1 and selected Category 2 AOVs. • Periodic DB verification for Cat 1 and 2 will be required and possibly an analytical verification of DB for Cat 3 and some Cat 2.

  16. ISTB Subgroup ISTB-Pumps • Revision to ISTB-6200 to provide clarification for use of Alert Range Analysis Requirements. Approved 2010. Should be Published in 2011 edition. • Pump Design Flow Rate, being redefined as Comprehensive Pump Test Flow Rate (P03-02). Still NOT fully acceptable. Proposed use CPT Flowrate and require additional “periodic verification” test if CPT is NOT greater than “maximum design bases accident flow” • Mandatory Appendix -- How to perform Verification Test • Non-Mandatory Appendix – Historical Perspective of CPT.

  17. ISTB Subgroup ISTB-Pumps • Comprehensive Pump Test Substitution, regarding the use of an Upper Limit for Required Action for Hydraulics of 1.06 vs. 1.03. Should be approved and in the 2011 edition of the OM Code. Ballot No. 10-1121 Pending comment incorporation.

  18. ISTB Subgroup ISTB-Pumps • Question on the requirements for a Group B Pump Test? • Bump Test? • Modified Group A Test? Still being discussed. ASME and ISTOG are evaluating industry input to determine the next step. • Code Case to allow applying old Code rules associated with establishing a new reference value without having an existing pump curve.

  19. ISTB Subgroup ISTB-Pumps • First inquiry was related to calibration accuracy requirement when individual suction and discharge gages are used to determine differential pressure. Inquiry discussed fact that calibration accuracy of suction gage could be outside code requirements but differential pressure could still meet ± 2 % required accuracy. • Second inquiry was related to calibration accuracy of digital gages and potential confusion in terminology “full scale range”. “Full scale range” is not really applicable for digital instruments and “calibrated range” may be more appropriate.

  20. ISTB Subgroup ISTB-Pumps • After significant discussion, both inquiries were re-worded by ISTB members and agreed to discuss changes with inquirer and then determine course of action.

  21. ISTB Subgroup ISTB-Pumps • Variance from reference value was also discussed. The code language does not allow any variance from reference value when performing subsequent IST. NRC NUREG-1482 includes some guidance, but the NRC has developed a replacement NUREG (Draft NUREG 1946) that does not include similar guidance. This issue has been discussed numerous times with no consensus reached on a proposed code change.

  22. Appendix I Subgroup Appendix I—Safety and Relief Valves • Code Cases OMN-2, 5, and 14 being incorporated into OM Code and will be deleted. • OMN-2 — Thermal Relief Valves • OMN-5 — Testing of Liquid RVs without insulation • OMN-14 — BWR CRD Rupture Disk exclusion from Appendix I. • Code Case OMN-17 -- Extension of RV testing greater than 5 years for Class 1/MSSVs—Looking at 6 years +/- 6 months frequency. - Maintenance requirements have been added to Appendix I which will permit this.

  23. Appendix I Subgroup Appendix I—Safety and Relief Valves • Code Case OMN-xx – Alternative Rules for Ambient Temperature and Test Media Requirements in Appendix I. • Adopt the wording in the current OM Code regarding air or nitrogen substitution. • Clarification of requirements concerning normal system operating temperature (or ranges of temperatures) and what is meant by the term “designed” in certain applications. • Provide appropriate controls and alternative requirements to allow testing relief valves at temperatures below the operating range without temperature correlation being required.

  24. Appendix I Subgroup Appendix I—Safety and Relief Valves – • Code Case XX –Alternate rules to I-1350 to treat Alternative to IST Plan “grouping” of RVs to track by serial number. • Consolidate PWR and BWR under Appendix I

  25. Appendix I Subgroup Appendix I—Safety and Relief Valves – • Inquiry: When a full complement of relief valves is replaced using the provision of I-1320(b)(2), does this satisfy the testing requirements of I-1320(a) with respect to the minimum required test interval of 20% within a 24 month period? • Reply: Yes

  26. Appendix I Subgroup Appendix I—Safety and Relief Valves – • A proposal was brought forth to allow the use of water in place of fuel oil for relief valves in this application. Both ASME PTC 25 and ASME Section III allow the use of water for testing relief valves that are used in liquid service. The manufacturers use water to test all relief valves used in liquid service applications.

  27. Appendix I Subgroup Appendix I—Safety and Relief Valves – • There was also a consensus that the end users are all using water instead of fuel oil due to personnel safety and environmental concerns. It appears that this area was not thoroughly researched in the past when the rules for compressible fluids was created. Following debate, a vote was initiated to approve the change. It was accepted with one abstention due to a lack of test data about performance with fuel oil in comparison with performance with water. This item is ready to proceed for balloting.

  28. Appendix I Subgroup Appendix I—Safety and Relief Valves – • Two new members were added to the group. Mr. Craig Shepard from Fermi, who is the present Chair of PRDIG and Mr. Robert O'Neil from EPRI, who is the technical lead for relief valves.

  29. Appendix I Subgroup Appendix I—Safety and Relief Valves – • A request for information was obtained regarding the application of test requirements for Pilot operated Relief Valves that do not use an auxiliary actuating device powered by an external energy source. The Pilot in the valves under question utilize process fluid pressure to function.

  30. Appendix I Subgroup Appendix I—Safety and Relief Valves – • Following a discussion about the design of the safety valve, it was concluded that the rules for testing valves without auxiliary actuating devices apply. Since the pilot is integral to the valve's function to relieve pressure, it is not considered an external device that can perform auxiliary functions.

  31. MOV/AOV Subgroups OM-8 MOVs • OMN-1 incorporation into Appendix III of the OM Code is approved. – Published in the 2009 Edition of the Code. • 16 sites currently implementing OMN-1, Revision 0 or Revision 1. • 11 sites pending/implementing OMN-1, Revision 1.

  32. MOV/AOV Subgroups OM-8 MOVs • Discussed feedback from OMN-1 CC incorporating and a couple of key areas • Grouping Clarification • Acceptance Criteria • Maximum intervals to greater than 10 for MOVs with “very large margin”

  33. MOV/AOV Subgroups OM-8 MOVs • SG discussed OMN-1/Appendix III feedback and enhancements. During the final balloting of Appendix III, SG received a comment suggesting that the word “electric” be removed from “Active Electric Motor Operated Valve Assemblies” wherever it appears. The comment further states that some advanced design plants may use pneumatic motor driven MOVs which should be handled under Appendix III. SG discussed this comment and concluded that we do not know enough about this component. Subgroup members will gather additional information for future consideration.

  34. MOV/AOV Subgroups OM-8 MOVs • A first draft of a strawman Code Case for grouping/interval extension to challenge the 10-year IST limit is near completion. This draft will be sent to Subgroup members for comment and iteration as necessary. We hope to have a document for comment

  35. MOV/AOV Subgroups OM-8 MOVs • SG discussed the idea of producing an Implementation Guide for Code Case OMN-1 and Appendix III. This was an item from the SCOMC “Brain Storming” exercise during the Dec 2009 meeting. The IST Owners Group has issued a guide and members do not think that an OM document is valuable at this time.

  36. MOV/AOV Subgroups OM-19 AOVs • It was determined to have the OM SC “assist” the OM-19 group in this endeavor. • Code Case to be incorporated into OM Code as Appendix IV. 2011? -- Areas of scope, acceptance criteria, guidance and risk sited as concerns. • Stroke Time testing to continue to be used for AOVs • Address LSSC components in IST • Use of analysis for DB verification for high margin/low risk • Ballot for approval by 12/10 • Appendix IV issued by 2011

  37. Check Valve Subgroup OM-22 Check Valves • Training/Qualification for NIT for CVs will be incorporated into Code as a Mandatory Appendix.

  38. Check Valve Subgroup OM-22 Check Valves • Code change for clarification of new requirement for establishing initial intervals for CV CMP. • Initial Condition monitoring test intervals may be established using Appendix II-4000(b) provided that the condition monitoring test intervals are supported by trending and evaluation. Trending and evaluation shall be used to support the conclusion that the valve(s) is (are) capable of performing its intended function(s) over the entire interval.

  39. Check Valve Subgroup OM-22 Check Valves • Appendix II can be interpreted such that a group of 4 valves has nothing done to them for 16 years, then all 4 are disassembled during the same outage. This is not the intent of CVCM, which is to do each valve periodically during the 16-year period. • Item 10-03 was initiated to develop Code guidance to address cases like this in Appendix II.

  40. Check Valve Subgroup OM-22 Check Valves • ISTC-5224 says to declare a check valve inoperable if it fails to exhibit the “required change in obturator position”. People at the meeting agreed that the phrase “required change” means either open or closed, because both are required by ISTC. To some people, “required change” means going to the position required for the valve to perform its accident function.

  41. Check Valve Subgroup OM-22 Check Valves • In other words, it only needs to be declared Inoperable when it fails to go to its’ required accident position. • Action Item 10-04 was initiated to initiate a Code Inquiry to clarify the intent of this requirement.

  42. ISTD Subgroup ISTD Snubbers • Ballot for R&C for Snubber test plans -and extensions and clarification to delete ISTD-5123, ISTD-5243 • OMN-15 CC (Performance Based snubber for alternate requirement testing) revision 2, to be issued • Code Case OMN-13 -- Approved

  43. ISTD Subgroup ISTD Snubbers • Discussion on “promotion” of the use of the ISTD and Code Cases for snubber testing. NRC exhibited “favorable” position of stations using ISTD and Code Cases, in lieu of Technical Specifications. • Final Rule out by early 2011 for transition of snubber testing to ISTD from Section XI IWF. 43

  44. ISTD Subgroup ISTD Snubbers • NRC has published RIS 2010-6 on June 1, 2010 which discusses snubber inservice inspection and testing requirements. The RIS does not present new requirements; it is a review of existing requirements although there are those that may disagree. • In addition EGM-10-001 (Enforcement Guidance Memorandum) has also been issued which is an enforcement guidance memorandum. 44

  45. ISTE Subgroup ISTE RI-IST • Essentially ISTE is a new subsection of the Code. ISTE essentially will provide a “pointer” to the Code Cases (Appendices) regarding RI-IST methodology, as the sections and Code Cases are approved and endorsed by the NRC. • Based upon comments received will probably be incorporated into 2011 edition of the OM Code.

  46. ISTE Subgroup ISTE RI-IST • White paper for Revision 1 of Subsection ISTE • Inquiry on ISTE applicability “Clarification to Subsection ISTE-1100 Applicability” • Revision 1 of Subsection ISTE - SG will review the above documents for one final round and remove “HOVs” from all applicable documents before the next O&M meetings in December 2010. The reason for this last change is lack of expertise from the HOV user group in the current Subgroup AOV membership.

  47. ISTE Subgroup ISTE RI-IST • Working on Revision 1. Should be approved and Published in 2011. • Emphasis on Scope being NOT limited to Class 1, 2 or 3.

  48. Sub Group Functional Systems New Reactors Task Group Two Actions • Design Guide DRAFT is completed and submitted for initial review • New Code Development is out for Ballot (10/10) • Discussion on how to incorporate into existing Code • ISTA Pointer Paragraphs and changes ONLY to affected Subsections (ISTA, ISTB, ISTC) • Mandatory Appendix with specifics regarding New Reactors • New division separate from existing Code • Code Case • New Code

  49. Liaison Reports Liaisons—NRC • Tony McMurtray has taken over for Jack McHale • Steve Tingen is no longer with the NRC • 10 CFR 50.53—RI-IST Final Rule out for Public Comment. • OM Code 2004 endorsed in FR in October 2008. • RG 1.192 Rev. 1 working – early 2011 • RG 1.193 Rev. 2 issued in October 2007. • 1.193 revision 3 working – early 2011?

  50. Liaison Reports • Liaisons—NRC • NRC has begun a Lean Six Sigma Project to improve timeliness of rulemaking to incorporate future editions/addenda of ASME Codes in 50.55a. • 2 years • Working on 2005/2006 addenda for OM Code • Working on 2005 addenda thru 2007 edition of Section XI and III. • Next rulemaking schedule to complete in Fall 2010 • 50.55a final rule out for public comment in early 2010 (Section III, XI for 2007 edition of Code, OM Code for 2005, 2006 addenda) • Expect 2009 edition of OM Code to be endorsed by NRC 2013.

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