asme om code cases presented by jeff neyhard for ron lippy

ASME OM CODE CASES

Presented by Jeff Neyhard for Ron Lippy

Intro 101???

Ron says Hi!!

Inservice Testing Program Training

ASME Code Case Applicability

In incorporating the OM Code by reference in 10 CFR 50.55a, the NRC staff recognized the need for a new regulatory guide that would approve OM Code cases.

Such a regulatory guide would perform a function similar to that of existing Regulatory Guide (RG) 1.147, which approves ASME Code cases applicable to Section XI of the ASME Boiler and Pressure Vessel Code.” NRC RG 1.192 and 1.193

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Operation and Maintenance of Nuclear Power Plants Code Cases.

Licensees may apply the ASME Operation and Maintenance Nuclear Power Plants Code cases listed in Regulatory Guide 1.192 without prior NRC approval subject to the following:

(i) When a licensee initially applies a listed Code case, the licensee shall apply the most recent version of that Code case incorporated by reference in this paragraph.

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(ii) If a licensee has previously applied a Code case and a later version of the Code case is incorporated by reference in this paragraph, the licensee may continue to apply, to the end of the current 120-month interval, the previous version of the Code case as authorized or may apply the later version of the Code case, including any NRC-specified conditions placed on its’ use.

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(iii) Application of an annulled Code case is prohibited unless a licensee previously applied the listed Code case prior to it being listed as annulled in Regulatory Guide 1.192.

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If a licensee has applied a listed Code case that is later listed as annulled in Regulatory Guide 1.192, the licensee may continue to apply the Code case to the end of the current 120-month interval.

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RG 1.193, for code cases not approved for use. RG 1.193 R2 is issued in mid-Oct. 2010.

OMN-10 is STILL NOT Approved for use.

Issuance of Revision 2 is a Major Achievement

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The NRC may authorize the use of a code case that it has not yet approved for use in RG 1.192 if a licensee requests the use of the code case under 10 CFR 50.55a(a)(3).

The NRC may authorize the use of such a code case until a future revision to RG 1.192 publishes the ASME code case.

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At that time, if the licensee intends to continue implementing the code case, it must follow all the provisions of the code case with the conditions specified in RG 1.192, if any.

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The authorization for a specific licensee to use a code case that is not listed in RG 1.192 does not authorize any other licensee to use the code case without it submitting an alternative under 10 CFR 50.55a(a)(3).

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• OMN-2, “Thermal Relief Valve Code Case.”

• OMN-5, “Testing of Liquid Service Relief Valves Without Insulation.”

• OMN-6, “Alternate Rules for Digital Instruments.”

• OMN-7, “Alternative Requirements for Pump Testing.”

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• OMN-8, “Alternative Rules for Preservice and Inservice Testing of Power-Operated Valves That Are Used for System Control and Have a Safety Function per OM-10.”

• OMN-13, “Requirements for Extending Snubber Inservice Visual Examination Interval at LWR Power Plants.”

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In addition, RG 1.192 lists the following OM Code cases as being “conditionally acceptable,” meaning that they are acceptable to the NRC for application in licensees’ OM IST programs within the limitations described in RG 1.192:

• OMN-1, “Alternative Rules for Preservice and Inservice Testing of Certain Motor-Operated Valve Assemblies in Light-Water Reactor Power Plants.”

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• OMN-3, “Requirements for Safety Significance Categorization of Components Using Risk Insights for Inservice Testing of LWR Power Plants.”

• OMN-4, “Requirements for Risk Insights for Inservice Testing of Check Valves at LWR Power Plants.”

• OMN-9, “Use of a Pump Curve for Testing.”

• OMN-11, “Motor-Operated Valve Risk-Based Inspection Code Case.”

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• OMN-12, “Alternative Requirements for Inservice Testing Using Risk Insights for Pneumatically and Hydraulically Operated Valve Assemblies in Light-Water Reactor Power Plants.”

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Unacceptable OM Code Cases

The following OM Code Cases were determined to be unacceptable for use by licensees in their Inservice Testing Programs:

OMN-10

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Summary of Basis for Exclusion

OMN-10, Rev. 0 Requirements for Safety Significance Categorization of Snubbers Using Risk Insights and Testing Strategies for Inservice Testing of LWR Power Plants. July 1, 2000A

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The method used for categorizing snubbers could result in certain snubbers being inappropriately categorized as having low safety significance.

These snubbers would not be adequately tested or inspected to provide assurance of their operational readiness.

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In addition, unexpected extensive degradation in feedwater piping has occurred which would necessitate a more rigorous approach to snubber categorization than presently contained in this Code Case.

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Code Cases are typically formatted in terms of an Inquiry [as from a licensee] and Reply [by the applicable ASME Code Committee].

Oftentimes the Inquiry and Reply are accompanied by an Applicability statement that identifies the specific Editions an Addenda of the ASME Code to which the Reply applies.

However, the ASME Code Committees do not always 1) include an Applicability statement or 2) identify all of the editions and addenda to which the Reply applies.

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As a result, several licensees have questioned whether they could use certain ASME Code Cases without additional interaction with the regulatory authority having jurisdiction at the plant site.

If a licensee would like to use an ASME Code Case with a Edition or Addendum of the ASME Code to which it is not applicable, the licensee has the following options:

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a. Have the alternative to use the Code Case, beyond its’ stated applicability, authorized by the NRC pursuant to 10 CFR 50.55a(a)(3), or

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b. If the Code Case is applicable to an Edition or Addendum of the ASME Code later than the version of the Code being used by the licensee, the licensee could update to the later version of the Code pursuant to 10 CFR 50.55a(f)(4)(iv) or (g)(4)(iv) and then use the Code Case, provided the Code Case has been approved for use in the appropriate Regulatory Guide and incorporated by reference into 10CFR 50.55a.

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Note that the later version of the ASME Code must also have been incorporated by reference into 10 CFR 50.55a, the licensee must update all related requirements of the respective Edition or Addenda, and the update must be specifically approved by the Commission.

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Licensee should not use ASME Code Cases with Editions and Addenda of the ASME Code to which they do not apply and that are not specifically approved for use by the NRC.

More specifically, licensees should not “reconcile” the Applicability of Code Cases without consulting with the applicable ASME Code Committee.

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Similar to the NUREG 1482 regarding Code Case Incorporation and Applicability

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General Requirements

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Application of Code Cases (ISTA-3130)

Identified in the IST Test Plan

Applicable to the edition/addenda specified in the IST Test Plan, or Relief from NRC is required

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Application of Code Cases

Shall be in effect at the time the IST Test Plan is filed with the NRC (Approved per RG 1.192), or

Shall be requested for use via Relief Request

Use of Code Case is subject to NRC approval

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Application of Code Cases

Superseded Code Cases approved for use may continue to be used.

Revisions to previously approved Code Cases may be substituted for that Code Case upon NRC approval.

Annulled Code Cases approved for use may be used for the duration of the interval.

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OMN-1 Alternative Rules for Preservice and Inservice Testing of Certain Electric Motor Operated Valve Assemblies in Light Water Reactor Power Plants OM Code 1995, Subsection ISTC.

No Expiration Date

Is a Mandatory Appendix to ISTC (Appendix III) 2009 Edition.

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OMN-1

Provides for Alternate testing using diagnostics and test/examinations as alternatives to ISTC

Allows Stroke time to be extended to diagnostic frequency in lieu of ISTC requirements.

Allows Remote Valve Position Indication Verification to be extended to diagnostic frequency in lieu of ISTC requirements.

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OMN-1

Consider Expert Panel Approval for Implementation/Changes if Program established using Risk criteria.

Approved for use in RG 1.192 with conditions.

Revision 1 has been approved and has been included in OM Code 2009 edition as well as Appendix III, along with OMN-11 (RI-IST for MOVs).

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• OMN-2 Thermal Relief Valve Code Case, OM-1995, Appendix I.

Alternative to Thermal Relief Devices to allow testing or replacement of the TRVs once every 10 years.

Incorporated into 1998 edition of Code.

Incorporated into 2004 Edition of OM Code

Approved for use in RG 1.192 w/o conditions

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OMN-3 Requirements for Safety Significance Categorization of Components Using Risk Insights for Inservice Testing.

Alternative to IST using RI-IST methodology similar to RG 1.175.

Will be incorporated into Appendix/Subsection in Future.

Was Incorporated into OM Code as Subsection ISTE.

Has been approved for use in RG 1.192 with Conditions.

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OMN-4 Requirements for Risk Insights for Inservice Testing of Check Valves at LWR Power Plants.

Alternative to ISTC Testing

Reaffirmed in 2007

Has been approved for use in RG 1.192 with Conditions.

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OMN-5 Testing of Liquid Service Relief Valves Without Insulation.

Alternative to requirement for installing insulation during testing.

Alternative to Appendix I- requirements which requires insulation to be installed for testing.

Reaffirmed in 2007.

Has been approved for use in RG 1.192 without conditions.

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OMN-6 Alternate Rules for Digital Instruments.

Alternative to requirement for Instrument Range for Digital instruments in ISTB-which limits range to 70%.

This Code Case extends the maximum full scale range of digital instruments used in ISTB to 90%.

Expired on March 30, 2007. Incorporated into OM Code in 2006 Addenda.


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OMN-7 Alternate Requirements for Pump Testing.

Alternative to requirement for pump testing in conjunction with OMN-3 (RI-IST), which permits extended frequencies for Group A, B and CPT.

Reaffirmed in 2007.


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OMN-8 Alternative Rules for Preservice and Inservice Testing of Power-Operated Valves that are used for System

Control and Have a Safety Function Per OM-10.

Alternative to requirement for valve stroke time testing and VPI for control valves.

Reaffirmed in 2006.


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OMN-9 Use of a Pump Curve for Testing.

Alternative for pump testing using a pump curve vs. a single point as a reference value.

Typically used for CCW or SW pumps

Reaffirmed in 2007.

Has been approved for use in RG 1.192 with certain conditions.

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OMN-10 Requirements for Safety Significance Categorization of Snubbers Using Risk Insights and Testing Strategies for Inservice Testing of LWR Power Plants

Reaffirmed Code Case in December 2007.

Has NOT been Approved for use in RG 1.192.

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OMN-11 Risk Informed Testing for Motor Operated Valves.

Reaffirmed Code Case in December 2007.

No Expiration Date.

Has been Approved for use in RG 1.192 with certain conditions.

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OMN-12 Alternative Requirements for Inservice Testing Using Risk Insights for Pneumatically and Hydraulically Operated Valve Assemblies in LWR Power Plants.

Reaffirmed in 2007

Has been Approved for use in RG 1.192 with certain conditions.

Is being incorporated into Code as Appendix IV.

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OMN-13 Requirements for Extending Snubber Inservice Visual Examination Interval at LWR Power Plants.

Re-affirmed in 2007.

Has been Approved for use in RG 1.192 without conditions.

Revision 1 issued in 2007

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OMN-14 Alternative Rules for Valve Testing Operations and Maintenance, Appendix I: BWR CRD Rupture Disk Exclusion.

Expired on February 10, 2006.

Incorporated into the 2004 Edition of OM Code, ISTC -1200 Exclusion.

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OMN-15 Requirements for Extending the Snubber Operational Readiness Testing Interval at LWR

Power Plants.

Expired on February 9, 2007.

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OMN-16 Use of a Pump Curve for Testing.

Alternative for pump testing using a pump curve vs. a single point as a reference value.

Typically used for CCW or SW pumps

Issued in 2007.

Has not yet been approved for use in RG 1.192

Being evaluated at present for incorporation into Code.

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OMN-17 Alternative Rules for Testing ASME Class 1 Pressure Relief/Safety Valves

Alternative for testing Class 1 SRVs at 72 months vs. 5 years as required by present Code.

Issued in 2007

Flexibility of +/- 6 months

Has not yet been approved for use in RG 1.192

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OMN-17

Being evaluated at present for incorporation into Code.

Requires additional maintenance/rebuild to be performed on SRVs

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OMN-17

The Owner shall disassemble and inspect each valve after as found set-pressure testing to verify that parts are free of defects resulting from time related degradation or service induced wear.

Based upon this inspection, the owner shall determine the need for additional inspections or testing to address any generic concerns.

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OMN-17

As-left set pressure testing shall be performed following maintenance and prior to returning the valve to service.

Each valve shall have been disassembled and inspected prior to the start of the 72 month test interval.

Disassembly and inspection performed prior to the implementation of this Code Case may be used.

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OMN-18 Alternate Testing Requirements for Pumps Tested Quarterly within ± 20% of Design Flow

Issued in 2007.

May be incorporated into the OM Code (2008 addenda).

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OMN-18 Alternate Testing Requirements for Pumps Tested Quarterly within ± 20% of Design Flow

This Code Case allows the Owner to not perform the Comprehensive Test with the associated acceptance criteria, if the quarterly test is performed at the flow rate and with the instrumentation required for the comprehensive test.

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OMN-XX Alternative Rules for Ambient Temperature and Test Media Requirements in ASME/ANSI OM-1987, Part 1, Requirements for Inservice Performance Testing of Nuclear Power Plant Pressure Relief Devices.

Expected in 2010.

Is being incorporated into the OM Code (2009 Edition).

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OMN-XX Alternative Upper Limit for the Comprehensive Pump Test

• Expected in 2010.

Is being incorporated into the OM Code (2009 Edition).

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ISTA-3130 Application of Code Cases

(a) Code Cases to be used during a preservice or inservice test or examination shall be identified in the test plan.

(b) Code Cases shall be applicable to the edition and addenda specified in the test plan.

(c) Code Cases shall be in effect at the time the test plan is filed, except as provided in ISTA-3130(d).

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ISTA-3130 Application of Code Cases

(d) Code Cases issued subsequent to filing the test plan may be proposed for use in amendments to the test plan.

ISTA-3140 Application of Revised Code Cases.

Superseded Code Cases approved for use in accordance with ISTA-3130 may continue to be used.

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ISTA-3150 Application of Annulled Code Cases.

Code Cases approved for use in accordance with ISTA-3130 or ISTA-3140 may be used after annulment for the duration of that test plan.

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Inservice Testing (IST) Program Training 61

Thank you for your attention.Thank you for your attention.

True North Consulting, LLCTrue North Consulting, LLC

Jeff NeyhardJeff Neyhardforfor

Ron LippyRon Lippy

asme om code cases presented by jeff neyhard for ron lippy

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