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ASME OM Code Meeting Notes – July 2006

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Introduction

Prepared By:  Ron Lippy

Company:  True North Consulting

Meeting Dates:  July 19 – 21, 2006

Meeting Location:  Washington, DC

Meeting Notes

Symposium Feedback

 

ASME Symposium Feedback

 

Ø      The two-year interval seems to be appropriate.

Ø      It is a positive event for the industry and a good medium to interface with industry

Ø      personnel.

Ø      It was somewhat harder to collect papers this year.  All papers are welcome, especially those regarding operating experiences/innovation.  The more papers, the better.

Ø      Need more marketing for papers, and sooner on the timeline.

Ø      The OM should submit more papers, as it is our Symposium.

Ø      Scheduling two parallel breakout sessions instead of three was better.

Ø      The technical aspects of the papers were better than in past years.

Ø      White papers for Code changes could be presented as Symposium papers.

Ø      User-group updates were appreciated.

Ø      Q&A Session was lacking.  Need panel members to better prepare.

Ø      Need to stick to the session agendas/paper orders.

Ø      Presentation-only submittals would be accepted.

 

Publication Schedules - Joanna Berger - See Below.

 

Ø      Discussion on the publication of OM S/G:

Ø      It was suggested to bundle/sell the OM S/G with the OM Code.

Ø      It was suggested to index/refer to the OM S/G in the OM Code in order to increase awareness for the document.

Ø      It was suggested to turn the standards and guides into nonmandatory appendixes.

Ø      Comment: From a business perspective, the OM S/G is not a profitable document.  However, we must serve our customers in the best way possible.

Publication Schedule

OM Code

Edition/Addenda

2006 OMb

Addenda

2007 Edition

2008 OMa

Addenda

2009 OMb

Addenda

Standards

Committee

Approval

2/2006

2/2007

2/2008

2/2009

BNCS

Procedural

Review

3/2006

3/2007

3/2008

3/2009

Manuscript

provided to

ASME

Editors/BSR-8

Issued

4/2006

4/2007

4/2008

4/2009

Public Review

Period Ends:

BSR-9 Issued

7/2006

7/2007

7/2008

7/2009

ANSI Approval

8/2006

8/2007

8/2008

8/2009

Issue Date

10/2006

9/2007

9/2008

9/2009

Publication Schedule

OM-S/G

Edition/Addenda

2006 Edition

2007 OMa-

2008 OMb-

2009

 

 

S/G

S/G

Edition

 

 

Addenda

Addenda

 

Standards

2/2006

2/2007

2/2008

2/2009

Committee

 

 

 

 

Approval

 

 

 

 

BNCS

3/2006

3/2007

3/2008

3/2009

Procedural

 

 

 

 

Review

 

 

 

 

Manuscript

provided to

4/2006

4/2007

4/2008

4/2009

ASME

Actual:

 

 

 

Editors/BSR-8

6/2006

 

 

 

Issued

 

 

 

 

Public Review

7/2006

7/2007

7/2008

7/2009

Period Ends:

 

 

 

 

BSR-9 Issued

Actual:

 

 

 

 

8/2006

 

 

 

ANSI Approval

8/2006

8/2007

8/2008

8/2009

 

9/2006

 

 

 

Issue Date

10/2006

9/2007

9/2008

9/2009

 

11/2006

 

 

 

 

OM Subcommittee

 

The SCOMC met on Thursday morning from 8:00 – 11:00 am

The purpose of the meeting was an open discussion by all in attendance, members and guests, on the future of the subcommittee.  The SCOMC had not met since December, 2004 primarily due to the lack of major initiatives requiring discussion and the new ballot process which begins with a “world” review.

 

Provided below are some of the major issues discussed.

 

Ø      The majority of current subcommittee members favored retention of the subcommittee stating that technical benefit was provided during review of code additions and changes.

Ø      Several members indicated that the SCOMC was their only place to gain information on other committee’s activities.

Ø      The current version of the Management and Operations Manual (MOM) places responsibility for inquiry resolution on the SCOMC.

Ø      Members believe that with resurgence in nuclear plant construction that there will be a need for a significant revamping of the OM Code and that the subcommittee would provide benefit.

 

The meeting adjourned at 11:00 am with no decisions or recommendations finalized.  The below actions were assigned for future discussion and follow-up.

 

Ø      Develop a proposal for responding to Code Inquiries by the SCOMC

Ø      Other members/guests were requested to submit proposals related to future SCOMC responsibilities prior to the December 2006 meeting.

Ø      Arrange for meeting space and time for December, 2006 OM Committee Meetings.

 

ISTA—General Requirements

 

  1. Code Cases are going to be incorporated into OM Code ASAP.
  2. Discussion regarding “practical” and “practicable”.  NRC was concerned that in many instances “practical” constitutes “minor inconvenience” such as placing a ladder to perform the activity.  Ongoing discussions.
  3. Determined that individual subgroups would be responsible for updating/standardizing Code Cases in lieu of ISTA being solely responsible for the updating/standardization of the Code Cases.
  4. Discussion regarding typos and errata and that ISTA would look at correcting the errors identified.

 

ISTC—Valves

 

1.      Discussion regarding Valve Categorization and whether or NOT Code action is needed.  ISTOG is working on paper which may clarify.

Revise Categories of Valves (Cat A vs. Cat AC)—Recent regulatory inquiries regarding the determination of Cat A and AC valves.  Will be evaluated prior to next OM Code meeting (Dec 2006).—V-96-03

2.      Incorporation of OMN-1 into ISTC.  V-97-01.  OMN-1 Revision 1 should go for ballot NLT December 2006.  Once Approved—then to OM Code, ISTC as an Appendix III.  OMN-11 will be included in the Appendix.  Probably in 2007 Edition of OM Code. 

3.      Appendix I and ADS valve test schemes is working.

4.      OMN-8 has been revised for applicability and being incorporated into OM Code, ISTC-5100.  OMN-8 has been approved by ASME in early 2006.  Should be in 2006 addenda. 

5.      Initiated SG action to consider deleting valve position indication verification for passive valves.

6.      Initiated action to consider clarification on the intent of all cold shutdown valve tests if testing is not started within 48 hours of achieving CSD.

 

ISTB—Pumps

 

1.      OMN-6, Revision 1, Digital Instrument Range of 90%, approved should be approved in December 2005.  Should be in 2006 Addenda of OM Code.  Revision was primarily for “applicability statement”.

2.      OMN-6 should be incorporated into 2006 addenda of OM Code.

3.      Revision to ISTB-6200 to provide clarification for use of Alert Range Analysis Requirements.  Should be approved 2006. (P00-02)

4.      OMN-9, Code case for use of pump curves being revised for “applicability (and to resolve NRC concerns regarding the required measurements).  Should be approved in 2006.

5.      P98-06, regarding changes to Inaccessible upper motor bearing housings (Question 3.4.4 Workshop Summary).  Awaiting comments from NRC.  May 2006.

 

3.4.4* Could the fact that the upper motor bearing housing is not accessible on many vertical shaft pumps be addressed on a generic basis, so a relief request would not be necessary?

If this issue is a generic concern, the Code committees could consider revising the Code to address these pumps.  As discussed previously, the staff has no plans to supplement GL 89-04 to provide generic relief.  Specific relief has been granted from the Code vibration requirements where access to the upper motor bearing housing is inaccessible (e.g., Hatch Safety Evaluation dated June 13, 1994, Section 3.1.3.1).

 

6.      P98-03, regarding instrumentation test failures (Question 3.3.1 Workshop Summary).  Closed.  No Code change required.

 

3.3.1* If a pump fails a test, and it is obvious that the failure was due to an instrument problem, can the pump be declared operable when the failed instrument is identified?  What is the Code requirement regarding the time allowed for retest when the instruments involved are recalibrated?

The pump may be declared operable; provided that it is clear the failed instrument is the overwhelming cause of the failed test.  The failed instrument should be recalibrated, and data promptly taken with the new equipment.  There is no Code requirement for the timing of the retest, beyond satisfying the pump surveillance interval.  However, the licensee should redo the test promptly to verify that the cause was indeed the instrumentation.  If the cause of anomalous data cannot clearly be attributed to the malfunctioning gauge, then it should be attributed to pump failure.  The licensee would then declare the pump inoperable and evaluate the condition of the pump in accordance with the applicable technical specification. See NUREG-1482, Appendix A, Question Group 45 and 46.

 

7.      P00-04, regarding Temporary Reference Values and Repair, Replacement and Maintenance of Pumps.  In particular, can you use a Group A Pump Test in lieu of a Comprehensive Pump test, when a Group B pump has had “major maintenance” which could affect the Hydraulic Profile of the pump, return the pump to operability, in part based on the results of the “mini-flow” test, and then perform a Comprehensive Pump test as soon as practicable?—this was CLOSED without any further action being taken.

8.      Pump Design Flow Rate, being redefined as Comprehensive Pump Test Flow Rate (P03-02).  Still NOT fully acceptable.  Working.

9.      Comprehensive Pump Test Substitution, regarding the use of a Group A test in lieu of CPT, using ONLY installed instruments (provided that the instruments satisfy the IST requirements for 2% tolerance and 3 times ref value or less for Range.  The proposal is to permit the pressure instruments for CPT to continue to use the instrument tolerance of +/- 2% in lieu of the requirement to use instrument tolerance of +/- 0.5% for pressure instruments.  To change the 103% upper limit for the pump acceptance criteria from “required action” to “alert”, implement the more restrictive acceptance criteria for the lower limits (Alert and Required Action).—ROM 04-04.

 

Appendix I—Safety and Relief Valves

 

  1. The Subgroup Relief Valves met as scheduled. Item 04-1085 was discussed and it was re-affirmed that we will go forward with the negative that cannot be withdrawn.  The person who issued the negative is no longer an ASME OM Committee member and his comment has been addressed in the C&S system.
  2. A Code Case proposal for an alternative to accommodate plants with a 24 month fuel cycle for Class 1 valves was considered.  The current requirement for these sites necessitates that 50% of the full complement be removed for testing each refueling outage in order to accommodate the 5 year test frequency.  Plants on 18 month cycles only have to remove about 33% of their valves to accomplish 100% of the required testing over a 5 year period.  After a discussion of the proposal that was presented, it was decided that a team would be formed to create a version that was more palatable to everyone in the membership.
  3. A Code Case proposal that eliminates grouping and requires performance tracking by serial number was presented.  This Code Case would also require periodic maintenance.  Test frequencies would be determined based upon the performance of an individual valve and would vary from the minimum of one refueling cycle to a maximum of 10 years.  Suggestions for improvement in the version presented were recorded and work on this proposal will continue.
  4. Inquiry OMI-05-01, regarding testing 1 RV in a group every 10 years.  No.  Code requires 20% every 48 months…..
  5. Code Cases OMN-2, 5, and 14 being incorporated into OM Code and will be allowed to “expire”.
  6. Extension of RV testing greater than 5/10 years for Class 1/Class 2 & 3 RVs.  Maintenance requirements will be added to Appendix I which will permit this.

 

OM-8—MOVs

 

1.      Working on issuing OMN-1 and then incorporating OMN-1 into ISTC as Appendix III.

2.      7 sites currently implementing OMN-1, Revision 0.

3.      18 sites pending for implementation of OMN-1, Revision 1.

 

OM-19—AOVs

 

1.      Code Case OMN-12 being submitted for Comments.—December 2006.

2.      Code Case to be incorporated into OM Code as Appendix IV.  2007?

 

ISTD—Snubbers

 

The ISTD Subgroup met in Blue Springs, MO in conjunction with the SNUG group.  The meeting was well attended. Significant business issues are listed below.

Ø      OMI 06-01 An inquiry was received from Exelon, Byron Station on July 11, 2006.  A response is attached.

Ø      There was a discussion about the proposed elimination of the Subcommittees.  The consensus of the ISTD Subgroup was that this would not be in the best interests of the development and maintenance of our Codes and Standards.

Ø      A revision to the OMN-13 Code Case was proposed, discussed and approved to be sent forward for ballot.  This revision provides a feed back loop in case there are visual failures and the program has to revert to the previous interval. This revision will be out for ballot shortly.

Ø      ISTD table 4252-1 notes are being revised for clarity regarding ± 25% examination interval.  A white paper was also written to explain how the notes would be applied to various examination scenarios.  These were presented and approved to go to ballot. This will become a ballot shortly.

Ø      Since Section XI is deleting the requirements of IWF-5000, ISTD is proposing a revision to ISTD 4231 to ensure the entire snubber assembly is evaluated during visual examination.  It was voted to submit the following change to 4231 for ballot.

§         ISTD - 4231 Restrained Movement. Snubber assemblies shall be installed so they are capable of restraining movement when activated. Examinations shall include observations for the following and the conditions shall be evaluated when found:

·        loose fasteners, or members that are corroded or deformed; and

·        disconnected components or other conditions that might affect structural integrity or interfere with the proper restraint of movement.

Snubbers evaluated to be incapable of restraining movement shall be classified unacceptable.

Ø      Code Case OMN-15 still needs some work to satisfy some comments that have been received informally from the Regulator. The Subgroup will continue to work on a potential revision to this Code Case.

 

Code Inquiry:

 

Background: ISTD-5312 states "When additional samples are required by ISTD-5320, they shall be at least one-half the size of the initial sample from that DTPG." ISTD-5331 states that testing shall satisfy the mathematical expressions of ISTD-5331. In some scenarios it is possible to satisfy the mathematical expressions of ISTD-5331using an additional sample size smaller than that required in ISTD-5312.

 

Explanatory Scenario:

Original DTPG = 70 snubbers.

Initial sample = 7 snubbers

One unacceptable snubber in original sample.

Additional DTPG or FMG sample of 4 snubbers (1/2 original sample size, 3.5 - rounded up)

One unacceptable snubber in additional sample.

Additional sample of 3 snubbers will satisfy ISTD-5331, but one-half of the original sample as required by ISTD-5312 is four snubbers.  The overall amount of additional snubbers tested meets the statistical requirements for establishing the assurance that the DTPG or FMG is operational.

 

Question (1). Must the requirements of ISTD – 5312 be satisfied in cases where an additional sample less than one-half the original sample size, satisfies the mathematical expression of 5331(a)?

 

Reply (1). Yes.

 

Background: While performing functional testing to a DTPG snubber, a functional failure is identified and evaluated to be an installation induced failure.  An appropriate FMG is established and defined, but the FMG is smaller in size than the required additional sample per ISTD-5312.  Additionally, due to the small size of the FMG the mathematical expression of ISTD-5331(b) can not be satisfied.

 

Explanatory scenario:

DTPG = 134 snubbers

Initial sample = 14 snubbers

One test is unacceptable, the installation induced FMG is established to be 6 snubbers, including the original failure (1 "failed snubber" plus 5 additional snubbers for testing).

FMG = 6 snubbers, but one-half the initial sample size is 7 snubbers.

Per ISTD-5331(b) NF must be greater than or equal to 7, but there are only 6 snubbers in the FMG.

 

Question (2).  Must the requirements of ISTD-5312 and ISTD-5331(b) be satisfied when the size of an FMG is less than one-half of the initial sample size of the DTPG?

 

Reply (2). No. ISTD-5330 states "Testing is complete when the mathematical expressions of ISTD-5331 are satisfied, or all snubbers in the DTPG or FMG have been tested."

 

Background: While performing testing in a DTPG, a snubber is found to be unacceptable.  The snubber is evaluated and assigned to a FMG and actions as required in ISTD-5320 are performed.  No other unacceptable snubbers are found in the DTPG.  ISTD-5331(a) defines the values of C as the total number of unacceptable snubbers found in the DTPG (excluding those counted for FMG tests).  Does the original unacceptable snubber count towards the value of C in determining the total number of tests required from the DTPG?

 

Question (3). Are unacceptable snubbers found in DTPG testing to be included in the value “C” of ISTD-5331(a), when those snubbers are used to define an FMG for which additional actions per ISTD-5320 are completed?

 

Reply (3). No. Reference ISTD - 5273(a)

 

Question (4). Are isolated failures per ISTD-5322 to be included in the value “C” in ISTD-5331(a)?

 

Reply (4). No.

 

ISTE—RI-IST

 

1.      Essentially ISTE will become 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.  ISTE is being submitted for Comment. 2006?

2.      Based upon comments received will probably be incorporated into 2007 edition of the OM Code.

 

OM-22—Check Valves

 

1.      Work on On-Line CV D&I has been discontinued due to:

a.      Limited number of potential beneficiaries

b.      On line disassembly is still available through CV CMP or by regulatory relief.

c.      NRC recently stated that on-line disassembly shuld only be considered for groups of one valve.

d.      SGCV doesn’t want to tempt owners to subdivide CV groups into groups of one by codifying a “group of one” restriction.

2.      SGCV is preparing a position paper on use of past results to determine CV CMP Intervals—Will be either an Inquiry or a Code Change.

3.      SGCV to look at revising CC OMN-4 to remove “applicability issues”.

4.      Next SGCV meeting is January 22, 2007 in conjunction with NIC and ISTOG in Orlando Fla.

 

Liasons—NRC

 

1.      A proposed Rule to amend 10 CFR 50.55a to incorporate by reference the 2004 Edition of the ASME B&PV Code (Sections III and XI) and the OM Code, is proceeding.—Should be issued by end of 2006.

2.      Draft Revision 34 to RG 1.84, revision 15 to RG 1.147 and revision 2 to RG 1.193 have been developed.

3.      Discussion on converting NUREG 1482, Revision 1 to a Regulatory Guide.  More Regulatory “footprint”.

4.      Discussion on “removing” RIS-2004-012 requirements regarding use of later Code editions/addenda.  Pending NRC evaluation of “benefit” or “value added”..

5.      SRP 3.9.6 (IST) to be revised in 2006.

6.      10 CFR 50.69 Approved.

7.      RG 1.193 Rev. 1 issued in October 2005.  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.

 

Pump Performance Group

 

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

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

 

RISC 3 Group

 

  1. Discussions on testing/examinations required to be performed on Low Safety Significant Components/Systems.
  2. Trying to satisfy the requirements of 10 CFR 50.69 regarding test/examinations required for RISC-3 components (Low Safety Significant components).
  3. Discussion on applicability of various tests/examinations.  Expect first deliverables in 2007 edition of OM Code.

 

Miscellaneous

 

Discussion on incorporating Appendix J requirements into OM Code, as a standard to the OM Code.  Discussions ensued involving ANSI reaction.

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

    2.  Next OM Code meeting in December 2006 to be in St. Pete Fla.  At the Island Grand.


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