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Federal Regulations, Codes, &
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Introduction Prepared By: Ron Lippy Company: True North Consulting Meeting Dates: July 19 – 21, 2006 Meeting Location: 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 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
Publication
Schedule
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
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 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, 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
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 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 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
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 ( 2.
Next OM Code meeting in December 2006 to be in St. Pete Fla. At the |
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