Transcript Document

Intro
101???
Ron says Hi!!
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 120month 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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ASME Code Case Applicability
• 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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ASME Code Case Applicability
• OMN-8, “Alternative Rules for Preservice and Inservice Testing of PowerOperated 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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ASME Code Case Applicability
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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ASME Code Case Applicability
• 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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ASME Code Case Applicability
• 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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ASME Code Case Applicability
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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ASME Code Case Applicability
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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ASME Code Case Applicability
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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ASME Code Case Applicability
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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ASME Code Case Applicability
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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ASME Code Case Applicability
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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ASME Code Case Applicability
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 OMN11 (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.

Has been approved for use in RG 1.192 without
conditions.
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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.

Has been approved for use in RG 1.192 without conditions.
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OMN-8
Control
Alternative Rules for Preservice and Inservice Testing of
Power-Operated Valves that are used for System
and Have a Safety Function Per OM-10.

Alternative to requirement for valve stroke time testing and
VPI for control valves.

Reaffirmed in 2006.

Has been approved for use in RG 1.192 without conditions.
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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 ISTA3130 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 ISTA3140 may be used after annulment for the duration of that test plan.
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Thank you for your attention.
True North Consulting, LLC
Jeff Neyhard
for
Ron Lippy
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