ML25008A083

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AUG-MUG AOV-MOV Regulatory Activities 1-2025 (Scarbrough) Final
ML25008A083
Person / Time
Issue date: 01/08/2025
From: Thomas Scarbrough
NRC/NRR/DEX/EMIB
To:
References
Download: ML25008A083 (1)
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Text

Air-Operated Valve and Motor-Operated Valve Regulatory Activities AOV and MOV Users Group Meetings, January 2025 Thomas G. Scarbrough Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 1

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

1. IST Rulemaking Status
2. NUREG-1482 Status
3. New and Advanced Reactor IST Programs
4. MOV Backseating
5. Additional Topics 3
1. IST Rulemaking Status 4

10 CFR 50.55a Rulemaking 5

Inservice Inspection (ISI) and Inservice Testing (IST) Program Code of Record (COR) Interval and Code Case Final Rule (Revision 40)

ASME Operation and Maintenance of Nuclear Power Plants (OM Code), 2022 Edition, and ASME BPV Code, 2021 Edition, Final Rule Streamlining of 10 CFR 50.55a Rulemaking

6 ISI/IST Program COR Interval and Code Case Rule (Rev. 40) 50.55a Final Rule in Federal Register on 7-17-2024 (89 FR 58039).

Editorial correction in Federal Register on 7-29-2024 (89 FR 60795).

Update IST/ISI Program COR every two consecutive IST/ISI intervals if implementing 2017 Edition (or later) of OM Code and 2019 Edition (or later) of BPV Code.

RG 1.192, Revision 5, to accept OMN-28, 29, and 30 without conditions, and OMN-31 with conditions.

25-year maximum for same COR

7 Transition at End of Current IST Interval to 20/24-Year Interval Update COR at end of Interval 2 to begin next IST interval IST Program Interval 2 May apply same COR as Interval 1 Submit relief and alternative requests for NRC review.

Submit IST Program Plan per 10 CFR 50.55a(f)(7)

Implement ISTA 10-year interval or OMN-31 12-year interval IST Program Interval 1 (after end of current interval)

Apply 2017 or later edition of OM Code as COR.

Submit relief and alternative requests for NRC review.

Submit IST Program Plan per 10 CFR 50.55a(f)(7).

Implement ISTA-3120 10-year interval or OMN-31 12-year interval.

Transition at End of Current IST Interval to 20/24-Year Interval You are here.

You are using an earlier Code edition than 2017 Implement 1st ISTA-3120 10-year interval or OMN-31 12-year interval Implement 2nd ISTA-3120 10-year interval or OMN-31 12-year interval New COR Prior to entering Interval 2:

-No change to COR required

-Submit relief and alternatives

-Submit program plan Prior to entering Interval 1:

-Apply 2017 or later

-Submit relief and alternatives

-Submit program plan Prior to entering Interval 3:

- Update COR

-Submit relief and alternatives

-Submit program plan

Mid-Interval Transition if COR earlier than 2017 Edition 9

At end of subsequent interval, licensee must update COR.

If approved, licensee may use new COR for remainder of ISTA-3120 10-year interval and entirety of subsequent ISTA-3120 10-year or OMN-31 12-year interval.

Review previously authorized alternatives and relief, and submit program plan.

Evaluate impact of updating COR for completed and planned IST activities.

To update COR to 2017 or later edition, licensee must submit request to update OM Code per 50.55a(f)(4)(iv).

FRN Section II.F, Mid-Interval Discussion and Example (89 FR 58039, 58050) describes mid-interval transition.

Mid-Interval Transition if COR earlier than 2017 Edition 10 Use new COR for remainder of ISTA-3120 10-year interval ISTA-3120 10-year or OMN-31 12-year interval New COR Prior to entering Interval 2:

-No change to COR required

-Submit relief and alternatives

-Submit new program plan Prior to entering Interval 3:

- Update COR

-Submit relief and alternatives

-Submit new program plan

-Submit request per 50.55a(f)(4)(iv)

-Evaluate impact on IST activities (completed and planned)

-Submit new program plan

Mid-Interval Transition if COR is 2017 or later Edition Update COR at the end of subsequent ISTA-3120 or OMN-31 interval.

Licensee may remain on the current COR for the subsequent ISTA-3120 10-year or OMN-31 12-year interval.

Submit IST Program Plan per 10 CFR 50.55a(f)(7)

Submit alternative and relief requests for next IST interval.

Licensee continues to implement COR to the end of current ISTA-3120 10-year IST interval.

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Mid-Interval Transition to if COR is 2017 or later Edition 12 You are 2017 or later Code edition.

Continue to the end ISTA-3120 10-year interval ISTA-3120 10-year or OMN-31 12-year interval New COR Prior to entering Interval 2:

-No change to COR required

-Submit relief and alternatives

-Submit program plan Prior to entering Interval 3:

- Update COR

-Submit relief and alternatives

-Submit program plan

ASME OM Code (2022 Edition)

  • Final rule includes changes to 10 CFR 50.55a to reflect 2022 Edition of OM Code and clarifications.
  • Changes to specific IST conditions indicated on next slides.

13

New Conditions

  • Clarifies when implementing ISTD-4253, and Note 7 of Table ISTD-4252-1 in 2022 Edition, licensees prohibited from applying OMN-15, Revision 2 or Revision 3.
  • Clarifies implementing I-1320(c)(1) requirement for sample expansion of Class 1 Pressure Relief Valves.

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Removed Conditions

  • 10 CFR 50.55a(b)(3)(ii), OM Condition: Motor-Operated Valve (MOV) testing, paragraphs (A), (B),and (C), for licensees implementing 2022 Edition of OM Code.

Streamlining 10 CFR 50.55a Rulemaking

  • Direct final rule (DFR) planned to incorporate by reference acceptance of uncontested and unconditionally-approved Code Cases in 10 CFR 50.55a.
  • Proposed/final rule process will continue for biennial incorporation by reference of ASME Code editions and conditionally-approved Code Cases in 10 CFR 50.55a.
  • First DFR for Code Cases being considered for 2025.

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2. NUREG-1482 Status 17

Draft Revision 4 to NUREG-1482

  • NRC staff held a public meeting on May 7, 2024, to discuss plans to prepare Revision 4 to NUREG-1482, Guidelines for Inservice Testing at Nuclear Power Plants
  • NRC staff reviewed suggestions for updating NUREG-1482 provided by stakeholders.
  • NRC staff has drafted Revision 4 to NUREG-1482 with internal review underway.
  • Draft Revision 4 to NUREG-1482 should be issued soon.

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NUREG-1482 AOV and MOV Updates

  • Updated to reflect 2020 ASME OM Code, specific OM Code Cases, and associated regulatory requirements.
  • Classification of valves as Active or Passive in performing their safety function.
  • Categorization of valves as Category A or B with respect to leakage.

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NUREG-1482 Updates (continued)

  • ASME OM Code requirements for skid-mounted component testing.
  • ASME OM Code requirements for MOV backseating.

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NUREG-1482 Updates (continued)

  • Clarification that 10 CFR 50.55a(b)(3)(ii)(D) applies to MOVs that are referenced in plant technical specifications for stroke-time verification during exercising.

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3. New and Advanced Reactor IST Programs 22

ASME OM-2-2024 Code

  • ASME has issued OM-2-2024 Code for PST/IST programs for new and advanced reactors.
  • Scope includes components that control the movement of fluid (e.g., pumps and valves), and dynamic restraints.
  • NRC referenced planned OM-2 Code in guidance for risk-informed IST programs for new and advanced reactors.
  • Developers of new and advanced reactors are interested in OM-2 Code for their nuclear facilities.
  • NRC has prepared a draft regulatory guide DG-1424 to accept OM-2 Code with regulatory positions (similar to RG 1.246 for Inservice inspection).
  • DG-1424 should be issued for public comment soon.

23

ASME QME-1 Standard

  • ASME updated QME-1 Standard in 2023 for qualification of active mechanical equipment in nuclear facilities.
  • ASME completed Reformatted QME-1 Standard for qualification of mechanical equipment in water-cooled and non-water-cooled nuclear facilities.
  • Revision 4 to RG 1.100 accepts QME-1-2017 with regulatory positions.
  • NRC staff is preparing proposed Revision 5 to RG 1.100 to accept QME 2023 and Reformatted QME-1 with regulatory positions.
  • Proposed Revision 5 to RG 1.100 will be issued for public comment when Reformatted QME-1 is available.

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7. MOV Backseating 25

ASME OM Code ISTC-3310 Effects of Valve Repair, Replacement, or Maintenance on Reference Values.

When a valve or its control system has been replaced, repaired, or has undergone maintenance1 that could affect the valves performance, a new reference value shall be determined or the previous value reconfirmed by an Inservice test run before the time it is returned to service or immediately if not removed from service.

This test is to demonstrate that performance parameters that could be affected by the replacement, repair, or maintenance are within acceptable limits. Deviations between the previous and new reference values shall be identified and analyzed. Verification that the new values represent acceptable operation shall be documented in the record of tests (see ISTC-9120).

Footnote 1: Adjustment of stem packing, limit switches, or control system valves, and removal of the bonnet, stem assembly, actuator, obturator, or control system components are examples of maintenance that could affect valve performance parameters.

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Code Case OMN-1 3.4 Effect of MOV Replacement, Repair, or Maintenance When an MOV or its control system is replaced, repaired, or undergoes maintenance that could affect the valves performance, new Inservice test values shall be determined, or the previously established Inservice test values shall be confirmed before the MOV is returned to service. If the MOV was not removed from service, Inservice test values shall be immediately determined or confirmed.

This testing is intended to demonstrate that performance parameters, which could be affected by the replacement, repair, or maintenance, are within acceptable limits.

The Owners program shall define the level of testing required after replacement, repair, or maintenance. Deviations between the previous and new inservice test values shall be identified and analyzed. Verification that the new values represent acceptable operation shall be documented as described in section 9, Records and Reports.

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NUREG-1482 Guidance on MOV Backseating

  • If necessary to backseat a valve to stop packing leakage and full-stroke test or leak rate test is not practical in current plant mode, justify that: (1) stem, backseat, and bonnet not damaged, (2) stem will not stick in backseat, (3) valve parameters not adversely affected, and (4) evaluate previous backseating.
  • Move valve stem briefly away from backseat after initial backseating to demonstrate that stem is not bound in the backseat.
  • Perform confirmatory test at first available opportunity when plant conditions allow testing.
  • Using this guidance complies with ISTC-3310 such that a 10 CFR 50.55a(z) alternative request is not necessary. Guidance may also be applied to Section 3.4 in Code Case OMN-1.

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10. Additional Topics 29

EPRI MOV PPM, Version 4.1

  • On June 14, 2023, EPRI submitted MOV Performance Prediction Program, Addendum 11 to TR-103237-R2, including Version 4.1 of the MOV Performance Prediction Methodology (PPM) (ML23180A012).
  • EPRI includes several enhancements for evaluating MOV operating requirements.
  • NRC conducted regulatory audit on October 10 to 13, 2023, with audit report issued on November 16, 2023 (ML23293A264).
  • EPRI issued Motor-Operated Valve Performance Prediction Program, Revision A, Addendum 11 to TR-103237-R2, Changes to Performance Prediction Methodology Software, Version 4.1, April 2024 (ML24313A061).

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decaBDE Wiring Insulation

  • In response to an initial EPA rule on decabromodiphenyl ether (decaBDE), NRC staff alerted EPA to safety information regarding electrical equipment (such as MOV actuators) that use decaBDE wiring insulation (see NRC Vendor Presentation at ML23158A084 public).
  • EPA proposed a rule revision to avoid safety issues from the unavailability of safety-related electrical equipment, or potential shutdown of nuclear power plants.
  • EPA received public comments on extension of compliance date to allow time for qualification of new cable/wire insulation, allowable use of currently available cable and wire, and broad definition of nuclear power reactors.
  • Concerns with EPA rule appear to be on track for resolution.

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MOV Anomalous Behavior

  • ASME OM Code, Appendix III, and Code Case OMN-1 specify that anomalous behavior observed during testing must be evaluated.
  • Anomalous behavior could involve such aspects of MOV performance as stroke time, stroke smoothness, or change in MOV parameters (such as seat coefficient of friction (COF), stem COF, or motor current).
  • For example, if the stem COF increases above the assumed value in MOV calculations during the valve stroke (such as at flow cutoff), this anomalous behavior must be evaluated to determine if stem lubrication activities need to be adjusted to ensure that the MOV can perform its safety function to close the valve.

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QUESTIONS?

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Acronyms

  • ASME: American Society of Mechanical Engineers
  • BPV: Boiler and Pressure Vessel
  • CFR: Code of Federal Regulations
  • COR: Code of Record
  • decaBDE: Decabromodiphenyl Ether
  • EPRI: Electric Power Research Institute
  • FRN: Federal Register Notice
  • FSAR: Final Safety Analysis Report
  • GL: Generic Letter
  • IST: Inservice Testing
  • LER: Licensee Event Report
  • MOV: motor-operated valve
  • M&TE: Measuring and Test Equipment
  • NRC: U.S. Nuclear Regulatory Commission
  • OM: Operation and Maintenance
  • PM: Preventive Maintenance
  • PST: Preservice Testing
  • RFO: Refueling Outage
  • RG: Regulatory Guide 34
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