Federal Regulations, Codes, & Standards
Users Group ©
Prepared By: Ron Lippy
Company: True North Consulting
Meeting Dates: July 19 – 21, 2006
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 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 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.
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.
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
of OMN-1 into ISTC. V-97-01. OMN-1 Revision 1 should go for ballot NLT
December 2006. Once Approved—then to
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.
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 188.8.131.52).
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. 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.
1. Code Case OMN-12 being submitted for Comments.—December 2006.
2. Code Case to be incorporated into OM Code as Appendix IV. 2007?
The ISTD Subgroup met in
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.
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.
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.
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.
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.
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”.
meeting is January 22, 2007 in conjunction with NIC and ISTOG in
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
Discussion on incorporating Appendix J requirements into OM Code, as a standard to the OM Code. Discussions ensued involving ANSI reaction.
Discussion regarding adoption of ASME/OM Codes in the world (
Next OM Code meeting in December 2006 to be in St. Pete Fla. At the