ML23331A296

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NRC Liaison Report December 2023 ASME OM Code Meeting Final
ML23331A296
Person / Time
Issue date: 11/27/2023
From: Thomas Scarbrough
NRC/NRR/DEX/EMIB
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Download: ML23331A296 (4)


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ADAMS Accession No. ML23331A296 STATUS OF NRC ACTIVITIES OF POTENTIAL INTEREST TO OM STANDARDS COMMITTEE Thomas G. Scarbrough, Senior Mechanical Engineer Mechanical Engineering and Inservice Testing Branch Division of Engineering and External Hazards NRC Office of Nuclear Reactor Regulation ASME OM Code Committee Meeting December 2023 Clearwater Beach, Florida 10 CFR 50.55a Code Edition Rulemaking Title 10 of the Code of Federal Regulations (10 CFR) in Section 50.55a, Codes and standards, incorporates by reference specific editions and addenda of the American Society of Mechanical Engineers (ASME) Operation and Maintenance of Nuclear Power Plants, Division 1, OM Code:

Section IST (OM Code), and the ASME Boiler and Pressure Vessel Code (BPV Code), Sections III and XI.

On October 27, 2022, the U.S. Nuclear Regulatory Commission (NRC) issued a final rulemaking to amend 10 CFR 50.55a to incorporate by reference the 2019 Edition to the ASME BPV Code,Section III, Division 1, and Section XI, Division 1, with conditions; and the 2020 Edition to Division 1 of the ASME OM Code, with conditions. See Federal Register Notice 87 FR 65128, dated October 27, 2022.

On August 8, 2023, the NRC staff issued a proposed rule to incorporate by reference the 2021 Edition of the ASME BPV Code, Division 1, Sections III and XI, and the 2022 Edition of the ASME OM Code, with conditions as appropriate.

Two proposed conditions in the rulemaking are as follows:

10 CFR 50.55a(b)(3)(vii), OM Condition: Snubber visual examination interval extension.

Proposes to clarify when implementing OM Code, Subsection ISTD, paragraph ISTD-4253, and Note 7 of Table ISTD-4252-1 in the 2022 Edition of the ASME OM Code, licensees are prohibited from applying Code Case OMN-15, Revision 2 or Revision 3, to extend snubber test interval because Section 3.4 of Code Case OMN-15 specifies that OMN-15 shall not be used in conjunction with Code Case OMN-13, which has been incorporated into the 2022 Edition of the ASME OM Code, Subsection ISTD.

10 CFR 50.55a(b)(3)(x), OM Condition: Class 1 pressure relief valve sample expansion.

Proposes to clarify that for each Class 1 Pressure Relief Valve tested per the ASME OM Code, Mandatory Appendix I, paragraph I-1320(c)(1), for which as-found set-pressure exceeds the plus/minus tolerance limit of the Owner-established design set-pressure acceptance criteria of paragraph I-1310(e) or +/- 3% of nameplate set-pressure if the Owner has not established design set-pressure acceptance criteria, two additional valves shall be tested from the same valve group.

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For licensees implementing the 2022 Edition of the ASME OM Code, the proposed rulemaking would remove the following conditions:

10 CFR 50.55a(b)(3)(ii), OM Condition: Motor-Operated Valve (MOV) testing, paragraphs (A),

(B), and (C).

10 CFR 50.55a(b)(3)(iii)(B), New Reactors OM Condition: Check valves.

10 CFR 50.55a(b)(3)(iii)(C), New Reactors OM Condition: Flow-induced vibration.

10 CFR 50.55a(b)(3)(iii)(C), New Reactors OM Condition: Flow-induced vibration.

The NRC staff is reviewing the public comments on the proposed rule with issuance of the final rule scheduled for January 2025.

10 CFR 50.55a Code Case Rulemaking In early 2022, the NRC issued a final rulemaking incorporating by reference into 10 CFR 50.55a revised NRC regulatory guides (RGs) that address the acceptability of ASME Code Cases in the Federal Register on March 3, 2022 (87 FR 11934) with an effective date of April 4, 2022. In particular, Revision 4 of RG 1.192, Revision 39 of RG 1.84, and Revision 20 of RG 1.147 address the acceptability of ASME OM Code Cases published during the similar time period as the 2020 Edition of the ASME OM Code and available on the ASME Codes & Standards (C&S) Connect Website; and specific ASME BPV Code Cases. RG 1.192, Revision 4, accepts new ASME OM Code Cases OMN-22 through OMN-27 without conditions. Other ASME OM Code Cases remain the same in Revision 4 to RG 1.192 as the previous Revision 3 to RG 1.192.

On March 6, 2023 (88 FR 13717), the NRC issued a proposed rule to address the acceptability of recent ASME BPV Code Cases and OM Code Cases by updating the applicable RGs. The proposed rule also requested public comments on a possible extension of the Code of Record (COR) update requirement in 10 CFR 50.55a from 10 years to 20 or 24 years for those licensees that are implementing (as their IST and Inservice Inspection (ISI) CORs) the 2020 Edition of the ASME OM Code and 2019 Edition of the ASME BPV Code, or later editions and addenda, as incorporated by reference in 10 CFR 50.55a. For a licensee implementing this recent Code edition or later edition as its IST/ISI Program COR, the rule proposes a 20-year or 24-year COR update interval requirement depending on whether the licensee is implementing a 10-year or 12-year OM Examination and Test interval and Section XI Inspection interval as applicable to the ASME OM and BPV Codes. For background information, see NRC Commission Paper SECY-21-0029 (March 15, 2021), Rulemaking Plan on Revision of Inservice Testing and Inservice Inspection Program Update Frequencies Required in 10 CFR 50.55a (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20273A286); Staff Requirements Memorandum SRM-SECY-21-0029 (November 8, 2021) (Accession No. ML21312A490); and Commission Paper SECY-22-0075 (August 10, 2022), Staff Requirements SECY-21-0029 Inservice Testing and Inservice Inspection Program Rulemakings Update (Accession No. ML22124A178). Draft RG 1.192, Revision 5 (DG-1407) accepts new ASME OM Code Cases OMN-28 through OMN-30 without conditions, and OMN-31 with conditions. Based on a public request, the NRC extended the public comment period for the proposed rule to June 16, 2023.

The NRC staff is reviewing the public comments with issuance of the final rule scheduled for October 2024.

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ASME Code on Component Testing Requirements at Nuclear Facilities (OM-2) Project ASME is preparing a new Code (referred to as OM-2) for inservice testing of pumps, valves, and dynamic restraints to be used in new and advanced nuclear power plants that will include water-cooled and non-water-cooled reactors. The NRC staff plans to review the new OM-2 Code for acceptance with applicable conditions in a new regulatory guide when the OM-2 is available as a public document. The NRC staff considers it important to have the new code available for nuclear power plant applicants for planning their IST programs when interacting with the NRC.

Reformatted ASME QME-1, Qualification of Active Mechanical Equipment Used in Nuclear Facilities, Project ASME is preparing a reformatted version of ASME Standard QME-1 to provide qualification provisions for active mechanical equipment to be used in new and advanced nuclear power plants.

The reformatted QME-1 Standard will allow its more effective use by applicants for the construction and licensing of non-water-cooled reactors. The NRC staff plans to revise RG 1.100, Seismic Qualification of Electrical and Active Mechanical Equipment and Functional Qualification of Active Mechanical Equipment for Nuclear Power Plants, to accept with applicable conditions ASME QME 2023 and the reformatted QME-1 (when available as a public document).

NRC Staff Review of Technical Specification Task Force (TSTF) Proposals The NRC staff is reviewing several draft TSTF documents with coordination between the NRC IST staff and the Technical Specifications staff. For example, the NRC staff is reviewing TSTF-576, Revise Safety/Relief Valve Requirements, that would allow the consideration of the safety relief valves in boiling water reactors as a group rather than individually for meeting Technical Specification requirements. The implementation of TSTF documents might result in the need for additional attention to ensure that both the ASME OM Code and the Technical Specifications continue to be met.

Extended Operating Cycles for Pressurized Water Reactor (PWR) Nuclear Power Plants Fuel enrichment improvements might allow PWR nuclear power plants to implement longer operating cycles. In preparation for these extended operating cycles, PWR licensees should ensure that performance data are available for IST components to provide confidence in extending the test intervals for those components. In addition, PWR licensees should ensure that the plant-specific IST Program is updated to reflect this interval change for the applicable components.

Focused Engineering Inspections for Power-Operated Valves The NRC staff has completed the focused engineering inspections for power-operated valves (POVs) at nuclear power plants by implementing NRC Inspection Procedure 71111.21N.02, Design- Basis Capability of Power-Operated Valves under 10 CFR 50.55a Requirements.

These inspections evaluated POV capability as it relates to valve/actuator design and safety function, design-basis conditions, uncertainties applied, diagnostics, weak link evaluations, design-basis capability tests, and design-basis capability evaluations. The POV inspections focused on motor-operated valves (MOVs), air-operated valves, hydraulic-operated valves, solenoid- operated valves, and pyrotechnic-actuated (squib) valves. The selection process for the POV inspection sample included risk, historical performance, and various valve sizes, types, and manufacturers. The POV inspections commenced in early 2020 and were completed at the end of 2022. On May 6, 2021, the NRC issued Information Notice (IN) 2021-01, Lessons Learned from U.S. Nuclear Regulatory Commission Inspections of Design-Basis Capability of Power- Operated Valves at Nuclear Power Plants, based on lessons learned from the initial POV inspections. The NRC staff discussed lessons learned from POV inspections performed up 3

to that time at a public meeting with the Boiling Water Reactor Owners Group (BWROG) on December 1, 2021 (ADAMS Accession No. ML21334A168). The NRC staff discussed more recent POV inspection lessons learned during the IST Owners Group (ISTOG) meeting in December 2022 (Accession No. ML22333A728). The NRC staff discussed all of the lessons learned from the POV inspections at the MOV Users Group meeting in January 2023 (ADAMS Accession No. ML23018A081). On July 24, 2023, the NRC staff issued Supplement 1 to IN 2021-01 to provide a summary of all of the lessons learned from the POV inspection program.

Example Lesson Learned from IP 71111.21N.02 Inspection Report In April 2022, the NRC staff completed an inspection at the Shearon Harris Nuclear Power Plant for Design Basis Assurance Inspection (Programs) documented in Inspection Report 05000400/202210 (ADAMS Accession No. ML22161A979). The NRC inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with NRC rules and regulations, license conditions, site procedures, and standards. Harris Final Safey Analysis Report (FSAR), Section 6.2.4.2.3, Valve Operability, states, in part, that, The valve types utilized for containment isolation service are designs which provide rapid closure and near zero leakage. Therefore, essentially no leakage is anticipated through the containment isolation valves when in closed position. The licensing basis for the plant excluded approximately 36 containment isolation valves (CIVs) from 10 CFR Part 50, Appendix J, testing requirements, based on the application of a water seal for 30 days after a design basis event. However, these CIVs were not exempt from the rapid closure and near zero leakage requirement. The licensee program did not ensure that the valve seat stresses necessary for near zero leakage were determined and met. In addition, test control documents and subsequent corrective action documents that identified degradation of the disc and seat did not evaluate the CIVs for leakage degradation. The documents specified that the CIVs did not need to meet the leak rate requirements because of their exemption from 10 CFR Part 50, Appendix J, testing requirements. The inspectors identified that the degradation could affect the valve leakage. The inspectors noted that not ensuring that near zero leakage requirements were addressed in the valve program allowed degradation affecting leakage requirements to be unaddressed.

10 CFR 50.36, Technical specifications, and 10 CFR 50.55a, Codes and standards The NRC regulations in 10 CFR 50.36 and 10 CFR 50.55a specify separate requirements for a licensee of a nuclear power plant. For example, if the ASME OM Code as incorporated by reference in 10 CFR 50.55a requires specific actions to be taken by a licensee (such as actions to be taken following an IST failure), the licensee is required to take those actions or must submit a relief or alternative request in accordance with the regulatory process specified in 10 CFR 50.55a.

In addition, many surveillance requirements in technical specifications refer to the IST Program under 10 CFR 50.55a(f) for the specific frequency in performing the surveillance requirement.

Therefore, it is important to consider the potential impact on the surveillance requirement frequency in technical specifications when revising the testing requirements in the ASME OM Code as incorporated by reference in 10 CFR 50.55a.

ASME-Related Generic Communications and Regulatory Guides No ASME-related generic communications or regulatory guides have been issued by the NRC since the last report (June 2023) to the ASME OM Standards Committee.

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