ML24155A032

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NRC Liaison Report & Updates Snubber User Group (Snug) 2024 Meeting Cleveland, Oh
ML24155A032
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Issue date: 07/17/2024
From: Gurjendra Bedi
NRC/NRR/DEX/EMIB
To:
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Download: ML24155A032 (21)
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1 NRC Liaison Report & Updates Snubber User Group (SNUG) 2024 Meeting Cleveland, OH Gurjendra S. Bedi, PE Mechanical Engineering and Inservice Testing Branch Division of Engineering and External Hazards Office of Nuclear Reactor Regulation July 15-17, 2024

2 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.

3 Topics for Discussion Current 10 of the Code of Federal Regulations (10 CFR) Section 50.55a.

Proposed Rulemaking to update 10 CFR 50.55a Code Cases-Current in 10 CR 50.55a and Regulatory Guide (RG) 1.192, - OM Code Case Acceptability Proposed Rulemaking to update Code Cases RG 1.192 Proposed Extension of Code of Record (COR) Update Intervals for IST and ISI Programs Code Case OMN-31, Alternative to Allow Extension of ISTA3120 Inservice Examination and Test Intervals From 10 Years to 12 Years General Communication

4 Current 10 CFR 50.55a Last ASME Code Rulemaking

- Issued on October 27, 2022

- Federal Register, Vol. 87, No. 207, pages 65128-65157

- Effective on November 28, 2022 Incorporates by Reference in 10 CFR 50.55a:

- 2020 Edition of ASME OM Code, Division 1, with Conditions

- 2019 Edition of ASME BPV Code,Section III, Division 1, with Conditions

- 2019 Edition of ASME BPV Code,Section XI, Division 1, with Conditions For current 10 CFR 50.55a, see www.ecfr.gov

5 Current 10 CFR 50.55a (cont.)

Specific changes to 10 CFR 50.55a regarding ASME OM Code (2020 Edition) included:

- Removed incorporation by reference of 2011 Addenda of ASME OM Code from 10 CFR 50.55a(a)(1)(iv)(B)(2) and consequently removed condition on use of 2011 Addenda specified in 10 CFR 50.55a(b)(3)(vii) as well as reference to 2011 Addenda in 10 CFR 50.55a(b)(3)(ix).

- Removed incorporation by reference of 2015 Edition of ASME OM Code from 10 CFR 50.55a(a)(1)(iv)(C)(2) and reference to 2015 Edition in 10 CFR 50.55a(b)(3)(ix).

- Removed condition on use of Subsection ISTB in 2011 Addenda of the ASME OM Code based on removal of its incorporation by reference in 10 CFR 50.55a.

6 Current 10 CFR 50.55a (cont.)

Specific 10 CFR 50.55a changes (continued):

- Modified 10 CFR 50.55a(f)(4) and (g)(4) to clarify relationship between 50.55a(f)(4) and (g)(4) regarding IST or ISI programs for snubbers.

  • When using 2006 Addenda or later edition of ASME BPV Code,Section XI, the inservice examination, testing, and service life monitoring requirements for dynamic restraints (snubbers) must meet requirements set forth in applicable ASME OM Code as specified in 10 CFR 50.55a(b)(3)(v)(B).

7 Current 10 CFR 50.55a (cont.)

Specific 10 CFR 50.55a changes (continued):

- In light of removal of IST Program Plan submittal requirement from 2020 Edition of ASME OM Code, added 10 CFR 50.55a(f)(7), Inservice testing reporting requirements.

- Inservice Testing Program Test and Examination Plans (IST Plans) for pumps, valves, and dynamic restraints (snubbers) prepared to meet requirements of ASME OM Code must be submitted.

- IST Plans must be submitted within 90 days of implementation for applicable 120-month IST Program interval. Electronic submission is preferred.

8 Current 10 CFR 50.55a (cont.)

Specific 10 CFR 50.55a changes (continued):

- In 10 CFR 50.55a(b)(3)(xi), provided additional provisions for extending the interval for position indication testing required in ISTC-3700 for valves not susceptible to stem-disk separation.

- Incorporated by reference Subsection ISTE for risk-informed IST programs in the 2020 Edition of the ASME OM Code without conditions.

9 Proposed Rulemaking Update to Incorporate by Reference New ASME Codes in 10 CFR 50.55a NRC staff issued proposed rulemaking on August 8, 2023 (88 FR 53384) to incorporate by reference the following:

- 2021 Edition of the ASME BPV Code, Division 1, Sections III and XI, with conditions as appropriate.

- 2022 Edition of the ASME OM Code with conditions as appropriate.

10 Proposed Rulemaking Update to Incorporate by Reference New ASME Codes in 10 CFR 50.55a (cont.)

IST proposed changes:

Remove conditions (b)(3)(ii)(A), (B), and (C) for 2022 Edition because incorporated in that edition Remove condition (b)(3)(iii)(B) for check valve bidirectional testing for new reactors because required in recent code editions used by new reactors Remove condition (b)(3)(iii)(C) for flow-induced vibration monitoring for new reactors because required by other regulations New condition (b)(3)(vii) to clarify use of snubber code cases New condition (b)(3)(x) to clarify sample expansion of Class 1 pressure relief valve testing based on setpoint testing

11 Proposed Rulemaking Update to Incorporate by Reference New ASME Codes in 10 CFR 50.55a (cont.)

New condition (b)(3)(vii) to clarify use of Code Case OMN-15 :

(vii) OM condition: Snubber visual examination interval extension.

When implementing Subsection ISTD, paragraph ISTD-4253, and Note 7 of Table ISTD-4252-1, in the 2022 Edition of the ASME OM Code, incorporated by reference in paragraph (a)(1)(iv) of this section, to extend snubber visual examination beyond 2 refueling cycles (48 months), the licensee is prohibited from applying OM Code Case OMN-15, Revision 2, to extend the operational readiness testing interval of snubbers.

NRC staff reviewing public comments Final rule scheduled to be issued in January 2025.

12 Code Cases in Current 10 CFR 50.55a 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 OMN-22 to 27 available on the ASME Codes & Standard (C&S) Connect Website. Other OM Code Cases remain the same in Revision 4 as in Revision 3 to RG 1.192.

- Code Cases from ASME BPV Code, Sections III and XI, listed in Supplement 0 through 7 to 2015 Edition of ASME BPV Code,Section XI, and Supplement 1 to 2019 Edition of ASME BPV Code.

- Current NRC regulations in 10 CFR 50.55a incorporate by reference these specific revisions to RGs 1.192, 1.84, and 1.147.

13 10 CFR 50.55a Proposed Rulemaking Update -

Code Cases and Extension of IST/ISI COR Update Interval Proposed Rulemaking for New Code Cases and IST/ISI COR Update Interval Extension:

- Issued on March 6, 2023, for public comments in Federal Register, Vol. 88, No. 43, pages 13717-13735

- Address acceptability of recent ASME BPV Code Cases and OM Code Cases by updating the applicable RGs.

- 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.

14 10 CFR 50.55a Proposed Rulemaking Update -

Code Cases and Extension of IST/ISI COR Update Interval (cont.)

Proposed rule also extends ISI and IST Code Of Record (COR) update requirements in 10 CFR 50.55a from 10 years to 20 or 24 years for licensees that are implementing (as their IST and ISI COR) 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 ASME OM 2020 Edition and BPV 2019 Edition or later edition as its IST/ISI Program COR, the rule proposed 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.

15 10 CFR 50.55a Proposed Rulemaking Update -

Code Cases and Extension of IST/ISI COR Update Interval (cont.)

Based on a 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.

16 ASME OM Code Case OMN-31 Code Case OMN-31 available on ASME C&S Connect website.

ASME Code Case OMN-31 allows extension of ISTA3120 Inservice Examination and Test Intervals from 10 Years to 12 Years provided all other requirements of ISTA-3120 are satisfied.

ASME Code Case Index specifies applicability of Code Case OMN-31 as 2001 Edition through 2020 Edition of ASME OM Code.

In RG 1.192 (Revision 5), NRC proposed a condition that use of Code Case OMN-31 is limited to licensees implementing the 2020 Edition through the latest edition of the ASME OM Code incorporated by reference in 10 CFR 50.55a as the COR for their IST Program.

17 NUREG-1482 Update NRC Staff is preparing NUREG-1482, Revision 4, Inservice Testing of Pumps and Valves and Inservice Examination and Testing of Dynamic Restraints (Snubbers) at Nuclear Power Plants, to provide additional information on the proposed new Code of Record update requirements and other recent developments and lessons learned for implementation of IST Programs.

18 Proposed ASME OM-2 Code ASME has prepared a proposed IST Code for pumps, valves, and dynamic restraints (or components that perform similar functions) in new and advanced reactors.

The new IST Code is referred to as the OM-2 Code.

ASME has distributed the proposed OM-2 Code for review by ASME OM Code committee members.

ASME plans to issue the OM-2 Code in 2024.

NRC staff is considering a new RG for acceptance of the OM-2 Code with applicable conditions.

19 ASME QME-1-2023 and Reformatting QME-1

  • ASME Standard Committee updated QME-1 in 2023
  • ASME is reformatting QME-1 standard to be more applicable for new and advanced reactors that might not use water-cooled systems
  • NRC staff plans to revise RG 1.100 to accept QME 2023 and reformatted QME-1 with conditions when available

20 NRC/ASME O&M Code and IST Symposium NRC/ASME O&M (formally Pumps, Valves, and Snubbers)

Fifteenth Symposium is being planned for July 28 and 29, 2025, with ASME OM Code committee meetings on July 30, 31, and August 1, 2025.

Symposium and ASME OM meetings are planned to be held in person at Bethesda North Marriott (across from NRC Headquarters While Flint building) in Washington, DC.

Call for papers will be issued soon.

21 QUESTIONS?

Future Questions Gurjendra. Bedi@nrc.gov

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