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ISTOG Meeting December 2010

Presented by Jeff Neyhard for Ron Lippy

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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.

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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).

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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).

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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.

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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.

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New Reactor Seminar – Bethesda, Md.

Good attendance - 130

Next one in Charlotte NC in June 2011

Three Sessions:

Design

Construction/Startup

Preservice/Preoperational

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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 concernsabout the application of TS provisions for non-TS specificsurveillances.

The SCOMC agreed that the OM Code should includerequirements for both issues and agreed to draft a proposed changed prior to the December 2010meeting.

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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.

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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

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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.

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ISTA InquiriesInquiry 09-1312Is 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.

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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.

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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.

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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.

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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.

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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.

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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.

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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.

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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.

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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.

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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.

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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

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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

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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.

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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.

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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.

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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.

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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.

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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.

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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”

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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.

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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

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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.

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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 201136

OM-22 Check Valves

Training/Qualification for NIT for CVs will be incorporated into Code as a Mandatory Appendix.

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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.

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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.

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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.

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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.

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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

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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.

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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.

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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.

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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.

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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.

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New Reactors Task GroupTwo 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 Code48

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?

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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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Liaisons—NRC

RG 1.192 will be revised on an “as required” basis when Code Cases have been revised or changes to “applicability” have been made and approved by ASME…and included in the revised ASME OM Codes.

– Possible revision to RG 1.192 in 2010.

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Liaisons—NRC

10 CFR 50.69 – Risk-Informing Special Treatment Requirements – Approved:

– Reg Guide 1.201 – Guidelines for Categorizing SSCs – January 2006.

– One Pilot Plant (WC)

– No FLCs submitted to NRC to implement

– RISC-3 Treatment Issue is still a problem

– DRAFT Inspection Procedure for 10 CFR 50.69 out in mid-2010 Most focus is on Cat 1 and 2 components and may use implementation of OM-29

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Liaisons—NRC

Generic Communications: IN 2008-13, Main Feedwater System Issues and Related 2007

Reactor Trip Data.

IN 2008-20, Failures of MOV Actuator Motors with Magnesium Alloy Rotors.

IN 2010-003, Failure of MOVs due to Lubricant Degradation.

IN 2010-04, DG Voltage Regulator System Component due to latent mfg. defect.

RIS 2010-01 Process for Scheduling Acceptance Reviews of New Rx. Licensing Applications.

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Liaisons—NRC

Generic Communications: RIS 2010-006, ISI and IST Requirements of Snubbers

Task Interface Agreement (TIA) 2010-001 – Evaluation of Application of Technical Specification (TS) Surveillance Requirement 3.0.3, Surveillance Requirement Applicability: The NRC issued TIA 2010-001 on April 19, 2010 to explain that

invoking SR 3.0.3 for an inservice test that is not a TSSR is inappropriate because there has been no surveillance that was not performed within the specified Frequency, which is necessary to invoke SR 3.0.3.

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Liaisons—NRC

For example, by applying the guidance to the preferred format of TS in NUREG 1434, TSs do not include SRs to periodically test excess flow check valves, therefore, there is no regulatory basis for applying SR 3.0.3 to excess flow check valves – This is discussion regarding the 25% “grace” that most of us use routinely for STs <2 years in the IST Program.

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Liaisons—NRC

Instead the regulatory requirements for testing excess flow check valves are included in the IST program IAW 10 CFR 50.55a).

Current State: At the April 28 TSTF/NRC public meeting, the TSTF expressed disagreement with an April 19, 2010 Task Interface Agreement (TIA) response on Clinton which stated that SR 3.0.3 cannot be applied to most Inservice Testing. The TSTF and NRC have held teleconferences in May and June and continue to work to resolve the issue.

The TSTF and NRC discussed the topic at the July 15 TSTF/NRC public meeting. The NRC will not withdraw or modify the TIA and is considering generic communication on the issue.

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Liaisons—NRC

At the 11/4/2010 TSTF/NRC public meeting, the NRC stated that the NRC Component Branch is considering a revision to the Regulatory Guides referenced in 10 CFR 50.55a to allow the missed Surveillance and Frequency extension provisions currently in the Technical Specification.

However, a revision to 10 CFR 50.55a isn't scheduled for two years, as a revision was just published. The TSTF suggested that the NRC investigate a Notice of Enforcement Discretion to allow licensees to use the provision currently in the Tech Specs until the rule is revised.

The NRC agreed to consider that approach.

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Liaisons—NRC

IN 2008-13, Main Feedwater System Issues and Related 2007 Reactor Trip Data.

IN 2008-20, Failures of MOV Actuator Motors with Magnesium Alloy Rotors.

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Liaisons—NRC

11th ASME/NRC P&V Symposium

August 15 – 16, 2011 (Listed earlier as September 2011)

Bethesda Md.

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Pump Performance

Looking at moving pump testing to 6 months using more comprehensive tests/exams (e.g. oil analyses, spectral analysis for vibration).

Various discussions on pump performance testing which may eventually be incorporated into the Code (ISTB).

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RISC 3—Low Safety Significant

Discussions on testing/examinations required to be performed on Low Safety Significant Components/Systems.

Trying to satisfy the requirements of 10 CFR 50.69 regarding test/examinations required for RISC-3 components (Low Safety Significant components).

Discussion on applicability of various tests/examinations. Expect first deliverables in 2010 edition of OM Code.

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Discussion regarding adoption of ASME/OM Codes in the world (Japan, Spain, China, Europe, UK).

Presentation from Japan regarding implementation of IST in Japan and update to the Earthquake in Niigata-Chuetsu-Oki July 16, 2007

Kashiwazaki-Kariwa NPS

7 Units 8,212 MWe

Units 1-5 – 1100MWe BWRs

Units 6, 7 – 1356 MWe ABWRs

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6.8 on Richter Scale

Distance from Plants – 17Km

Maximum acceleration exceeded Design Value

Off site power was maintained

Fire in Unit 3 House Transformer

No Containment Damage

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All Units back online

Exceeded DBE analyses –Caused several fires, minimum radioactive leakage, foundational damage observed, No damage identified in SSCs.

Impact on Capacity Factor – Original for FY 2007 – 72% After quake – 45%

Tokyo Electric Website for information is www.tepco.co.jp/en/index-e.html

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Next OM Code meeting in June 2011 in either Colorado Springs Co. or Boston Mass.

Winter 2011 Code meeting to be in Clearwater in December (12/6 – 12/09) 2011.

ASME/NRC P&V Symposium to be in August 2011 in Bethesda Md.

Summer OM Code Meeting to be held with the SNUG in June/July 2012

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