ML23157A108

From kanterella
Jump to navigation Jump to search
Nuclear Industry Check Valve Regulatory Activities
ML23157A108
Person / Time
Issue date: 06/06/2023
From: Chandran N
NRC/NRR/DEX/EMIB
To:
References
Download: ML23157A108 (18)
v • d • e


Text

Nuclear Industry Check Valve Regulatory Activities Nachiketh (Nach) Chandran Mechanical Engineering and Inservice Testing Branch Division of Engineering & External Hazards Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission NIC Meeting June 2023

Disclaimer

  • This presentation was prepared by staff of the U.S. Nuclear Regulatory Commission (NRC). It may present information that does not currently represent an agreed upon NRC staff position. NRC has neither approved nor disapproved the technical content.

2

Topics

  • Lessons Learned to Improve Check Valve (CV) Condition Monitoring 3

10 CFR 50.55a IST Rulemaking Activities

  • ASME Operation and Maintenance of Nuclear Power Plants (OM Code), 2020 Edition, Final Rule
  • Inservice Testing (IST)/Inservice Inspection (ISI) Program Code of Record (COR) Interval and ASME OM Code Case Proposed Rule (Revision 40)
  • ASME OM Code, 2022 Edition, Proposed Rule 4

ASME OM Code Cases (Rev. 39 rule)

  • Final Rule issued March 3, 2022, in Federal Register (87 FR 11934).

5

ASME OM Code 2020 Edition Final Rule

  • Final rule issued on October 27, 2022 (effective 11-28-2022) in 87 FR 65128
  • 50.55a changes include:

- Incorporated by reference 2020 Edition of ASME OM Code.

- Removed 2011 Addenda and 2015 Edition of OM Code.

- Accepted Subsection ISTE (2020 Edition) without conditions.

- Clarified 50.55a(f)(4) and (g)(4) for snubbers.

- Added 50.55a(f)(7) to require IST Program Plan submittals.

- Revised 50.55a(b)(3)(xi) to allow increased flexibility for the valve position verification schedule for valves not susceptible to stem-disk separation by directly accepting Code Case OMN-28; and to allow schedule flexibility for initial implementation of ISTC-3700 as supplemented by (b)(3)(xi) where justification available for review.

6

IST/ISI Program Code of Record (COR) Interval and ASME OM Code Case Proposed Rule (Revision 40) 7

SECY-21-0029

  • In SECY-21-0029 dated March 15, 2021 (ML20273A286), the NRC staff requested Commission approval to initiate a proposed rulemaking plan that would amend 10 CFR 50.55a to extend the COR interval for IST and ISI programs.
  • The proposed rulemaking plan included the following:

- Prepare a proposed rule to increase from 10-year COR interval to 20-year COR interval for licensees that have updated their IST/ISI Programs to the 2019 Edition of the ASME BPV Code and the 2020 Edition of the ASME OM Code

- Prepare a proposed rule to extend the COR interval from 20 years to 24 years in the future if ASME increases ISI interval to 12 years

- Request delegation of signature authority for these rulemakings to the Executive Director for Operations (EDO)

  • Provided other information on 10 CFR 50.55a streamlining efforts.

8

SRM-21-0029

  • Commission issued Staff Requirements Memorandum SRM-21-0029 on November 8, 2021 (ML21312A490) approving both proposed rulemakings.
  • Commission approved delegation of the signature authority for these two rulemakings to the EDO.
  • Commission stated that the NRC staff should move expeditiously to implement the remaining EMBARK 10 CFR 50.55a streamlining recommendations.

9

Changes to SECY-21-0029 Plan

  • NRC staff proposed to combine IST/ISI COR interval rulemaking with ASME Code Case Revision 40 rulemaking.
  • With certain conditions, the inclusion of these code cases would create an option for a licensee to implement either a 10-year or a 12-year IST/ISI program interval. To be consistent and aligned, the same option needed to be in place for the COR interval.
  • Therefore, the NRC staff determined the need to inform the Commission of the planned rulemaking changes from the original plan described in SECY-21-0029.

10

SECY-22-0075

  • In SECY-22-0075, the NRC staff explained the changes to the plan described in SECY-21-0029 and how the staff planned to develop the proposed rule.
  • Three major changes were:

- Combine the two proposed rulemakings into one rulemaking

- Make conforming changes to 10 CFR Part 50, Appendix J

- Propose conforming and clarifying changes to address issues encountered during the development of the proposed rule 11

Proposed COR Rule (Revision 40)

  • NRC issued proposed COR rule on March 6, 2023 (88 FR 13717)
  • NRC held a public meeting on March 20, 2023, to discuss the proposed rule (meeting summary ML23083B303).
  • Public comment period extended to June 16, 2023.
  • NRC presentation slides (ML23068A026) and unofficial redline version of the proposed rule (ML23073A279) are available to the public.
  • Proposed rule includes NRC regulatory guides that accept ASME Code Cases, including OM Code Cases OMN-28 through 31, with applicable conditions.
  • NRC staff are reviewing public comments on the proposed rule.
  • Issuance of the final rule is planned for mid-2024.

12

ASME OM Code (2022 Edition)

Proposed Rule

  • NRC staff has initiated preparation of a proposed rule to incorporate by reference the 2022 Edition of the ASME OM Code into 10 CFR 50.55a.
  • Proposed rule planned to be issued in 2023.

13

Lessons Learned to Improve Check Valve (CV)

Condition Monitoring 14

ASME OM Code, Appendix II

  • ASME OM Code, Appendix II, establishes high-level requirements for implementing and maintaining CV condition monitoring (CM) program.
  • Owner shall perform Appendix II analysis of test and maintenance history of CVs or groups of CVs in order to establish a basis for specifying IST, examination, and preventive maintenance activities.
  • Analysis (II-3000) shall include:

- Identify any common failure or maintenance patterns

- Analyze patterns to determine significance and identify potential failure mechanisms

  • Appendix II includes requirements for condition monitoring activities (II-4000), corrective maintenance (II-5000), and documentation (II-6000). 15

Check Valve CM Lessons Learned

  • ASME OM Code, Appendix II, allows significant flexibility in developing a check valve CM program in lieu of specific ASME OM Code IST requirements.
  • Safety significance of check valves should be considered when establishing the CM program.
  • Operating experience has revealed that the general requirements in Appendix II need to be carefully addressed when developing a check valve CM program that will be effective in assessing the CV operational readiness. For example, CM programs with only seat leakage testing for high-risk CVs might be re-evaluated to determine if additional monitoring is advisable.

16

Conclusion

  • NRC has issued a proposed rule to consider extension of IST/ISI Code of record intervals, and update RGs to accept recent ASME Code Cases.
  • ASME OM Code, Appendix II, allows flexibility in developing a condition monitoring program for check valves, but care must be taken to provide reasonable assurance of the operational readiness of check valves to perform their safety functions.
  • ASME OM Code committee for check valves should review Appendix II for additional condition monitoring provisions where appropriate.

17

QUESTIONS?

and an announcement that the NRC is HIRING!

Openings are available here:

Nachiketh.Chandran@nrc.gov Thomas.Scarbrough@nrc.gov 18

Retrieved from "https://kanterella.com/w/index.php?title=ML23157A108&oldid=3567320"