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{{#Wiki_filter:}} | {{#Wiki_filter:THOMAS BASSO Senior Director, Engineering and Risk 1201 F Street, NW, Suite 1100 Washington, DC 200 P: 202.739.8049 tbb@nei.org nei.org June 23, 2023 Office of the Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff Project Number: 689 | ||
==Subject:== | |||
Supplement to NEI Comments on Proposed 10 CFR 50.55a Rule Change and Draft Regulatory Guide DG-1407, Proposed Revision 5 to RG 1.192, Operation and Maintenance Code Case Acceptability, ASME OM Code, Docket ID NRC-2018-0291. | |||
==Dear Rulemakings and Adjudications Staff,== | |||
The Nuclear Energy Institute (NEI) 1, on behalf of our members, submitted comments on the proposed 10 CFR 50.55a Rule Change, and Draft Regulatory Guide DG-1407 on proposed revisions to Regulatory Guide 1.192 on June 15, 2023. Comments were made on the change to both Sections 50.55a(y)(2)(i) and the proposed Reg Guide 1.192 condition on OM Code Case OMN-31 that require licensees to be adopt OM Code 2020 Edition. As noted in our June 15 comments, NEI was in the process of working with ASME OM to provide a detailed comparison of the ASME OM 2017 and 2020 Editions at the time our comment letter was submitted. | |||
NEI received permission from ASME OM to use the ASME OM 2020 Summary of Changes to compare the changes from OM 2017 Edition to the 2020 Edition. Attachment 1 documents the evaluation of each change from OM 2017 to OM 2020 and shows the changes are mainly administrative, clarifications, editorial, and corrections. The few technical changes are not substantive and did not remove any requirements for testing or examinations. Therefore, the changes will have no impact on safety. We respectfully request that the NRC consider the attached change evaluation as a supplement to our June 15 comments. We believe the evaluation demonstrates that there is no safety basis for the condition included in the proposed rule that requires licensees to implement the ASME OM 2020 Edition to use OM Code Case OMN-31. Making this revision would extend the application of the proposed rule change and the code case to more licensees, 1 | |||
The Nuclear Energy Institute (NEI) is responsible for establishing unified policy on behalf of its members relating to matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEIs members include entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect and engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations involved in the nuclear energy industry. | |||
Rulemakings and Adjudications Staff June 23, 2023 Page 2 without the significant and unnecessary burden of having to update their Inservice Testing Program to the OM 2020 Edition. | |||
NEI requests the NRC consider this supplemental information as part of the comments submitted in our {{letter dated|date=June 15, 2023|text=letter dated June 15, 2023}}. Please contact me at tbb@nei.org or (484) 366-7534 with any questions or comments about the content of this letter or the attachment. | |||
Sincerely, Thomas Basso Attachment c: Andrea Veil, NRR/NRC Robert Taylor, NRR/NRC Andrea Kock, NRR/NRC NRC Document Control Desk | |||
Reprinted from ASME OM-2020, by permission of The American Society of Mechanical Engineers. All rights reserved. | |||
Attachment 1: Industry Review of Summary of Changes to OM 2017 Edition Incorporated for the OM 2020 Edition Following approval by the ASME OM Committee and ASME, and after public review, ASME OM-2020 was approved by the American National Standards Institute on May 11, 2020. | |||
ASME OM-2020 includes the following changes identified by a margin note, (20). | |||
Page Location Change Type of Change 1 ISTA-1400 (1) Revised Administrative: Adds responsibility to the Owner to ensure specific revisions of standards and specifications are acceptable for use. | |||
(2) Table ISTA-1400-1 deleted Administrative: Table with specific year / | |||
revision of referenced standards and specifications was deleted based on chance in ISTA-1400 4 ISTA-3200 (1) Former subpara. (a) deleted, and Administrative: Removed requirement to file remaining subparagraphs redesignated IST Plan with regulatory authority. This requirement has been relocated to NRCs jurisdiction in 10 CFR 50.55a for the USA. | |||
(2) Subparagraph (e) added Administrative: New subparagraph which replaces previous (f)(1), (f)(2), and (f)(3) to relocate requirements for determining the code of record for preservice and inservice intervals from OM to the regulatory authority. | |||
5 ISTA-5000 Revised Administrative: New Section and language which simply points to applicable subsections of OM for the specific test requirements 5 ISTA-6000 Revised Administrative: New and language which simply points to applicable subsections of OM for the monitoring, analysis, and evaluation requirements 6 ISTB-1400 Subparagraph (d) revised Administrative: Revised language to remove refence to Appendix V which was incorporated into ISTB 6 ISTB-2000 Definitions of baseline test and pump Clarification: New definition for baseline periodic verification test test to replace the term preservice test to added clarify the test is required regardless of whether it is during the preservice period or inservice period. The test requirements (when and how) have not changed - just the name in order to eliminate confusion. | |||
Administrative: Definition for periodic verification test was relocated from Appendix V to ISTB-2000 as part of integration of Appendix V into ISTB. | |||
6 ISTB-3100 (1) First paragraph and subpara. (c) revised Clarification: Language was changed as part of the change from preservice test to baseline test to clarify that the baseline test is requirements are applicable in both preservice and inservice periods. | |||
xxiv | |||
Reprinted from ASME OM-2020, by permission of The American Society of Mechanical Engineers. All rights reserved. | |||
(2) Subparagraph (d) deleted Administrative: Deleted unnecessary subparagraph. ISTB-3100(d) is duplicate of ISTB-3100(c) since both pump types are positive displacement pumps and reference the same section, ISTB-5310 7 Table ISTB-3000-1 Second column head and Note (1) revised Administrative: Part of the larger change of preservice test to baseline test 7 ISTB-3310 Revised in its entirety Clarification and Administrative: ISTB-3310 was restructured to split requirement into two new subparagraphs ISTB-3311 and ISTB-331. These new subparagraphs clarify when a baseline test (previously designated as a preservice test) is required. The new language reflects the original intent of when a preservice test was required and is consistent with how the industry has implemented the previous editions of OM with respect to preservice testing. This clarification is part of the larger change of preservice test to baseline test 8 Table ISTB-3400-1 Note (1) revised Administrative: Part of the change which integrated the requirements from Mandatory Appendix V from the 2017 Edition into Subsection ISTB and deleted Appendix V 8 ISTB-3400 Revised Administrative: Part of the change which integrated the requirements from Mandatory Appendix V from the 2017 Edition into Subsection ISTB and deleted Appendix V 9 Table ISTB-3510-1 (1) Third column head revised Administrative: Part of the larger change from preservice test to baseline test (2) Fourth column added Administrative: Part of the change which integrated the requirements from Mandatory Appendix V from the 2017 Edition into Subsection ISTB and deleted Appendix V 9 ISTB-5000 Revised Administrative: Part of the larger change from preservice test to baseline test 10 ISTB-5110 Title and subpara. (a) revised Administrative: Part of the larger change from preservice test to baseline test 10 ISTB-5122 First paragraph and subparas. (c) and (d) Correction: Corrected language from an revised earlier code change which allowed variance from the fixed reference value. The variance language was inadvertently included in the section for Group B pump tests although it should not have been applicable since only one hydraulic parameter is required to be measured. | |||
11 ISTB-5124 Added Administrative: Part of the change which integrated the requirements from Mandatory Appendix V from the 2017 Edition into Subsection ISTB and deleted Appendix V 12 ISTB-5210 Title and subpara. (a) revised Administrative: Part of the larger change from preservice test to baseline test, and Administrative: Part of the change which integrated the requirements from Mandatory Appendix V from the 2017 Edition into Subsection ISTB and deleted Appendix V xxiv | |||
Reprinted from ASME OM-2020, by permission of The American Society of Mechanical Engineers. All rights reserved. | |||
12 ISTB-5222 First paragraph and subparas. (c) and (d) Correction: Corrected language from an revised earlier code change which allowed variance from the fixed reference value. The variance language was inadvertently included in the section for Group B pump tests although it should not have been applicable since only one hydraulic parameter is required to be measured. | |||
13 ISTB-5224 Added Administrative: Part of the change which integrated the requirements from Mandatory Appendix V from the 2017 Edition into Subsection ISTB and deleted Appendix V 13 ISTB-5310 Title revised Administrative: Part of the larger change from preservice test to baseline test 14 ISTB-5322 First paragraph and subparas. (c) and (d) Correction: Corrected language from an revised earlier code change which allowed variance from the fixed reference value. The variance language was inadvertently included in the section for Group B pump tests although it should not have been applicable since only one hydraulic parameter is required to be measured. | |||
16 ISTB-5324 Added Administrative: Part of the change which integrated the requirements from Mandatory Appendix V from the 2017 Edition into Subsection ISTB and deleted Appendix V 16 ISTB-6000 First paragraph added Clarification: Added language to better differentiate when systematic error (ISTB-6300) can be used versus corrective action (ISTB-6200) 16 ISTB-6200 Subparagraph (b) revised Administrative: Part of the change which integrated the requirements from Mandatory Appendix V from the 2017 Edition into Subsection ISTB and deleted Appendix V 16 ISTB-9100 Subparagraph (e) added Administrative: Part of the change which integrated the requirements from Mandatory Appendix V from the 2017 Edition into Subsection ISTB and deleted Appendix V 18 ISTC-1200 Subparagraph (d) revised Administrative: Removed reference to Category A and Category B as it was determined to be unnecessary to distinguish different possible categories of safety and relief valves 19 ISTC-3000 ISTC-3800 deleted Administrative: ISTC-3800 was renumbered to ISTC-4000. The actual text of the paragraph did not change. Title of ISTC-4000 was revised accordingly 20 Table ISTC-3500-1 (1) Third entry in first column and fifth entry Clarification: Added Note 4 to provide a in last column revised pointer to Mandatory Appendix I for PORVs (2) Note (4) added, and subsequent Notes Clarification: Added Note 4 to provide a redesignated pointer to Mandatory Appendix I for PORVs. | |||
The language of the referenced Appendix I paragraphs did not change. | |||
22 ISTC-4000 Revised Administrative: ISTC-3800 was renumbered to ISTC-4000. The actual text of the paragraph did not change. Title of ISTC-4000 was revised accordingly 23 ISTC-5112 Revised Clarification: Added reference to specific paragraphs of Mandatory Appendix I xxiv | |||
Reprinted from ASME OM-2020, by permission of The American Society of Mechanical Engineers. All rights reserved. | |||
28 Subsection ISTD Title revised Administrative: Title change only. Changed words Examination and Testing of to Requirements for 28 ISTD-1110 Revised Clarification: Added language to refer to ISTD-1800 28 ISTD-1400 (1) First paragraph and subpara. (b) Clarification: Revised language to clarify revised emphasize the requirements of Subsection ISTA must be met. Technically, this is redundant since you cant get to Subsection ISTD without going through ISTA. | |||
(2) Subparagraph (d) added Administrative: Change to be consistent with the title change of Subsection ISTD 28 ISTD-1600 Revised Clarification: Added repair and to better reflect the title of ISTD-1600, Snubber Modification and Replacement 29 ISTD-1800 Revised Clarification: Language changed to better clarify when the evaluation requirements of ISTD-1800 apply. The evaluation requirement itself is unchanged. | |||
29 ISTD-2000 (1) Definition of service life revised Clarification: Changed an item to a snubber and added clarification at its installed location. | |||
(2) Definition of service life monitoring Clarification: New definition to better added describe the overall intent of service life monitoring required by ISTD-6200. Note that the requirements of ISTD-6200 have not changed. | |||
30 ISTD-3240 Revised Clarification: Added language to clarify intent which includes newly identified design difference. | |||
30 ISTD-4110 Revised Clarification: Minor change in language to replace the term supported system with affected systems, structures, or components to reduce confusing terms 33 ISTD-5240 Revised Technical: Relaxed timeframe for start of pre-outage activities from 60 days to 92 days. | |||
While this is technically a relaxation in requirements, it is intended to provide flexibility for implementation of ISTD requirements. It doesnt change the actual testing or examination requirements. | |||
35 ISTD-5331 Revised Editorial: Revised formula by replacing mathematical expressions with defined terms, then defining those terms using the previous mathematical expressions. Overall, there was no change to the math or results - the only thing that change is how it is written. | |||
37 ISTD-6000 (1) Title revised Administrative: Revised title to better represent the subordinate requirements (2) ISTD-6100 and ISTD-6200 revised in Clarification: Revised language to better their entirety reflect original intent. While the language was changed considerably, the revised language doesnt add or remove requirements that werent originally intended to be performed 38 ISTD-9500 Added Technical: Added new requirement for maintaining service life records. While this changed is identified as Technical it only adds administrative requirements for record keeping. It doesnt change actual test or examination requirements. | |||
xxiv | |||
Reprinted from ASME OM-2020, by permission of The American Society of Mechanical Engineers. All rights reserved. | |||
42 ISTE-4160 Revised Technical: Add a new requirement to provide a basis if the PRA model is not updated to address added risk from a failure of a component that is not modeled. This is a documentation requirement which does not affect testing or examination requirements. | |||
Therefore, it is inconsequential from a safety benefit perspective. | |||
44 ISTE-5121 Subparagraphs (b) and (c) revised Correction: Changed wording for the comprehensive test to reflect the change in flow rate which was first made to ISTB in the 2017 Edition, but the change in flow rate terms was inadvertently missed for ISTE in the 2017 Edition. This change corrects that error. | |||
44 ISTE-5122 Subparagraph (b) revised Correction: Changed wording for the comprehensive test to reflect the change in flow rate which was first made to ISTB in the 2017 Edition, but the change in flow rate terms was inadvertently missed for ISTE in the 2017 Edition. This change corrects that error. | |||
45 ISTE-5220 Revised Administrative: Simplified language to refer to ISTC for check valve testing rather than specific sections or Appendix II. The general reference to ISTC is more correct and covers all scenarios for check valve testing. | |||
46 ISTE-6110 Revised Clarification: Added the word testable to clarify those attributes which are selected for monitoring. This change clarifies the original intent. | |||
47 ISTF-2000 Definition of baseline test added Administrative: Part of the larger change from preservice test to baseline test 47 ISTF-3100 (1) First paragraph revised Administrative: Part of the larger change from preservice test to baseline test (2) Subparagraph (d) deleted Administrative: Eliminated differentiation between positive displacement pumps and reciprocation pumps since both are positive displacement pumps. The deleted paragraph referenced the same paragraph that is also referenced in the remaining requirement for positive displacement pumps. | |||
48 Table ISTF-3000-1 Second column head revised Editorial: No discernable change other than format. | |||
48 ISTF-3310 Revised in its entirety Clarification and Administrative: ISTF-3310 was restructured to split requirement into two new subparagraphs ISTF-3311 and ISTF-331. These new subparagraphs clarify when a baseline test (previously designated as a preservice test) is required. The new language reflects the original intent of when a preservice test was required and is consistent with how the industry has implemented the previous editions of OM with respect to preservice testing. This clarification is part of the larger change of preservice test to baseline test 49 Table ISTF-3510-1 Second column head revised Administrative: Part of the larger change from preservice test to baseline test 50 ISTF-5000 Revised Administrative: Part of the larger change from preservice test to baseline test 50 ISTF-5110 Title revised Administrative: Part of the larger change from preservice test to baseline test xxiv | |||
Reprinted from ASME OM-2020, by permission of The American Society of Mechanical Engineers. All rights reserved. | |||
51 ISTF-5210 Title revised Administrative: Part of the larger change from preservice test to baseline test 52 ISTF-5310 Title revised Administrative: Part of the larger change from preservice test to baseline test 52 ISTF-6000 First paragraph added Clarification: Added language to better differentiate when systematic error (ISTF-6300) can be used versus corrective action (ISTF-6200) 55 I-1200 First paragraph revised Correction: Corrected reference to ASME PTC 25 by elimination mention of Mandatory Appendix I. | |||
56 I-1320 Subparagraphs (a) and (c)(3) revised Administrative: Change related to integration of Code Case OMN-25 into Mandatory Appendix I 56 I-1350 Subparagraph (a)(3) revised Administrative: Change related to integration of Code Case OMN-25 into Mandatory Appendix I 58 I-3220 Revised Technical: Removed the requirement to determine set-pressure when installed in the system and raising system pressure up to the setpoint. The requirement was simplified to just require set pressure testing within 6 months. This change was made to address difficulties in performing set pressure testing using the installed system pressure which have been subject of previous requests for alternatives. Although this is a technical change with respect to the use of the installed system, it does not change the requirement to perform set pressure testing. | |||
65 II-4000 Subparagraph (b)(5) revised Editorial: Revision to incorporate Errata from 2017 Edition (reference OM Record 16-424) 68 III-3500 Subparagraph (a) revised Clarification: Added language to clarify the original intent that each valve in the group is required to be tested. | |||
78 Division 1, Mandatory Deleted Administrative: Part of the change which Appendix V integrated the requirements from Mandatory Appendix V from the 2017 Edition into Subsection ISTB and deleted Appendix V Reprinted from ASME OM-2020, by permission of The American Society of Mechanical Engineers. All rights reserved. | |||
xxiv}} | |||
Revision as of 09:59, 17 July 2023
| ML23177A249 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 06/23/2023 |
| From: | Basso T Nuclear Energy Institute |
| To: | NRC/SECY/RAS |
| References | |
| NRC-2018-0291, 88FR13717 00012, 88FR27712 00012, RG-1.192, Rev 5, DG-1407, PR-50 | |
| Download: ML23177A249 (1) | |
Text
THOMAS BASSO Senior Director, Engineering and Risk 1201 F Street, NW, Suite 1100 Washington, DC 200 P: 202.739.8049 tbb@nei.org nei.org June 23, 2023 Office of the Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff Project Number: 689
Subject:
Supplement to NEI Comments on Proposed 10 CFR 50.55a Rule Change and Draft Regulatory Guide DG-1407, Proposed Revision 5 to RG 1.192, Operation and Maintenance Code Case Acceptability, ASME OM Code, Docket ID NRC-2018-0291.
Dear Rulemakings and Adjudications Staff,
The Nuclear Energy Institute (NEI) 1, on behalf of our members, submitted comments on the proposed 10 CFR 50.55a Rule Change, and Draft Regulatory Guide DG-1407 on proposed revisions to Regulatory Guide 1.192 on June 15, 2023. Comments were made on the change to both Sections 50.55a(y)(2)(i) and the proposed Reg Guide 1.192 condition on OM Code Case OMN-31 that require licensees to be adopt OM Code 2020 Edition. As noted in our June 15 comments, NEI was in the process of working with ASME OM to provide a detailed comparison of the ASME OM 2017 and 2020 Editions at the time our comment letter was submitted.
NEI received permission from ASME OM to use the ASME OM 2020 Summary of Changes to compare the changes from OM 2017 Edition to the 2020 Edition. Attachment 1 documents the evaluation of each change from OM 2017 to OM 2020 and shows the changes are mainly administrative, clarifications, editorial, and corrections. The few technical changes are not substantive and did not remove any requirements for testing or examinations. Therefore, the changes will have no impact on safety. We respectfully request that the NRC consider the attached change evaluation as a supplement to our June 15 comments. We believe the evaluation demonstrates that there is no safety basis for the condition included in the proposed rule that requires licensees to implement the ASME OM 2020 Edition to use OM Code Case OMN-31. Making this revision would extend the application of the proposed rule change and the code case to more licensees, 1
The Nuclear Energy Institute (NEI) is responsible for establishing unified policy on behalf of its members relating to matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEIs members include entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect and engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations involved in the nuclear energy industry.
Rulemakings and Adjudications Staff June 23, 2023 Page 2 without the significant and unnecessary burden of having to update their Inservice Testing Program to the OM 2020 Edition.
NEI requests the NRC consider this supplemental information as part of the comments submitted in our letter dated June 15, 2023. Please contact me at tbb@nei.org or (484) 366-7534 with any questions or comments about the content of this letter or the attachment.
Sincerely, Thomas Basso Attachment c: Andrea Veil, NRR/NRC Robert Taylor, NRR/NRC Andrea Kock, NRR/NRC NRC Document Control Desk
Reprinted from ASME OM-2020, by permission of The American Society of Mechanical Engineers. All rights reserved.
Attachment 1: Industry Review of Summary of Changes to OM 2017 Edition Incorporated for the OM 2020 Edition Following approval by the ASME OM Committee and ASME, and after public review, ASME OM-2020 was approved by the American National Standards Institute on May 11, 2020.
ASME OM-2020 includes the following changes identified by a margin note, (20).
Page Location Change Type of Change 1 ISTA-1400 (1) Revised Administrative: Adds responsibility to the Owner to ensure specific revisions of standards and specifications are acceptable for use.
(2) Table ISTA-1400-1 deleted Administrative: Table with specific year /
revision of referenced standards and specifications was deleted based on chance in ISTA-1400 4 ISTA-3200 (1) Former subpara. (a) deleted, and Administrative: Removed requirement to file remaining subparagraphs redesignated IST Plan with regulatory authority. This requirement has been relocated to NRCs jurisdiction in 10 CFR 50.55a for the USA.
(2) Subparagraph (e) added Administrative: New subparagraph which replaces previous (f)(1), (f)(2), and (f)(3) to relocate requirements for determining the code of record for preservice and inservice intervals from OM to the regulatory authority.
5 ISTA-5000 Revised Administrative: New Section and language which simply points to applicable subsections of OM for the specific test requirements 5 ISTA-6000 Revised Administrative: New and language which simply points to applicable subsections of OM for the monitoring, analysis, and evaluation requirements 6 ISTB-1400 Subparagraph (d) revised Administrative: Revised language to remove refence to Appendix V which was incorporated into ISTB 6 ISTB-2000 Definitions of baseline test and pump Clarification: New definition for baseline periodic verification test test to replace the term preservice test to added clarify the test is required regardless of whether it is during the preservice period or inservice period. The test requirements (when and how) have not changed - just the name in order to eliminate confusion.
Administrative: Definition for periodic verification test was relocated from Appendix V to ISTB-2000 as part of integration of Appendix V into ISTB.
6 ISTB-3100 (1) First paragraph and subpara. (c) revised Clarification: Language was changed as part of the change from preservice test to baseline test to clarify that the baseline test is requirements are applicable in both preservice and inservice periods.
xxiv
Reprinted from ASME OM-2020, by permission of The American Society of Mechanical Engineers. All rights reserved.
(2) Subparagraph (d) deleted Administrative: Deleted unnecessary subparagraph. ISTB-3100(d) is duplicate of ISTB-3100(c) since both pump types are positive displacement pumps and reference the same section, ISTB-5310 7 Table ISTB-3000-1 Second column head and Note (1) revised Administrative: Part of the larger change of preservice test to baseline test 7 ISTB-3310 Revised in its entirety Clarification and Administrative: ISTB-3310 was restructured to split requirement into two new subparagraphs ISTB-3311 and ISTB-331. These new subparagraphs clarify when a baseline test (previously designated as a preservice test) is required. The new language reflects the original intent of when a preservice test was required and is consistent with how the industry has implemented the previous editions of OM with respect to preservice testing. This clarification is part of the larger change of preservice test to baseline test 8 Table ISTB-3400-1 Note (1) revised Administrative: Part of the change which integrated the requirements from Mandatory Appendix V from the 2017 Edition into Subsection ISTB and deleted Appendix V 8 ISTB-3400 Revised Administrative: Part of the change which integrated the requirements from Mandatory Appendix V from the 2017 Edition into Subsection ISTB and deleted Appendix V 9 Table ISTB-3510-1 (1) Third column head revised Administrative: Part of the larger change from preservice test to baseline test (2) Fourth column added Administrative: Part of the change which integrated the requirements from Mandatory Appendix V from the 2017 Edition into Subsection ISTB and deleted Appendix V 9 ISTB-5000 Revised Administrative: Part of the larger change from preservice test to baseline test 10 ISTB-5110 Title and subpara. (a) revised Administrative: Part of the larger change from preservice test to baseline test 10 ISTB-5122 First paragraph and subparas. (c) and (d) Correction: Corrected language from an revised earlier code change which allowed variance from the fixed reference value. The variance language was inadvertently included in the section for Group B pump tests although it should not have been applicable since only one hydraulic parameter is required to be measured.
11 ISTB-5124 Added Administrative: Part of the change which integrated the requirements from Mandatory Appendix V from the 2017 Edition into Subsection ISTB and deleted Appendix V 12 ISTB-5210 Title and subpara. (a) revised Administrative: Part of the larger change from preservice test to baseline test, and Administrative: Part of the change which integrated the requirements from Mandatory Appendix V from the 2017 Edition into Subsection ISTB and deleted Appendix V xxiv
Reprinted from ASME OM-2020, by permission of The American Society of Mechanical Engineers. All rights reserved.
12 ISTB-5222 First paragraph and subparas. (c) and (d) Correction: Corrected language from an revised earlier code change which allowed variance from the fixed reference value. The variance language was inadvertently included in the section for Group B pump tests although it should not have been applicable since only one hydraulic parameter is required to be measured.
13 ISTB-5224 Added Administrative: Part of the change which integrated the requirements from Mandatory Appendix V from the 2017 Edition into Subsection ISTB and deleted Appendix V 13 ISTB-5310 Title revised Administrative: Part of the larger change from preservice test to baseline test 14 ISTB-5322 First paragraph and subparas. (c) and (d) Correction: Corrected language from an revised earlier code change which allowed variance from the fixed reference value. The variance language was inadvertently included in the section for Group B pump tests although it should not have been applicable since only one hydraulic parameter is required to be measured.
16 ISTB-5324 Added Administrative: Part of the change which integrated the requirements from Mandatory Appendix V from the 2017 Edition into Subsection ISTB and deleted Appendix V 16 ISTB-6000 First paragraph added Clarification: Added language to better differentiate when systematic error (ISTB-6300) can be used versus corrective action (ISTB-6200) 16 ISTB-6200 Subparagraph (b) revised Administrative: Part of the change which integrated the requirements from Mandatory Appendix V from the 2017 Edition into Subsection ISTB and deleted Appendix V 16 ISTB-9100 Subparagraph (e) added Administrative: Part of the change which integrated the requirements from Mandatory Appendix V from the 2017 Edition into Subsection ISTB and deleted Appendix V 18 ISTC-1200 Subparagraph (d) revised Administrative: Removed reference to Category A and Category B as it was determined to be unnecessary to distinguish different possible categories of safety and relief valves 19 ISTC-3000 ISTC-3800 deleted Administrative: ISTC-3800 was renumbered to ISTC-4000. The actual text of the paragraph did not change. Title of ISTC-4000 was revised accordingly 20 Table ISTC-3500-1 (1) Third entry in first column and fifth entry Clarification: Added Note 4 to provide a in last column revised pointer to Mandatory Appendix I for PORVs (2) Note (4) added, and subsequent Notes Clarification: Added Note 4 to provide a redesignated pointer to Mandatory Appendix I for PORVs.
The language of the referenced Appendix I paragraphs did not change.
22 ISTC-4000 Revised Administrative: ISTC-3800 was renumbered to ISTC-4000. The actual text of the paragraph did not change. Title of ISTC-4000 was revised accordingly 23 ISTC-5112 Revised Clarification: Added reference to specific paragraphs of Mandatory Appendix I xxiv
Reprinted from ASME OM-2020, by permission of The American Society of Mechanical Engineers. All rights reserved.
28 Subsection ISTD Title revised Administrative: Title change only. Changed words Examination and Testing of to Requirements for 28 ISTD-1110 Revised Clarification: Added language to refer to ISTD-1800 28 ISTD-1400 (1) First paragraph and subpara. (b) Clarification: Revised language to clarify revised emphasize the requirements of Subsection ISTA must be met. Technically, this is redundant since you cant get to Subsection ISTD without going through ISTA.
(2) Subparagraph (d) added Administrative: Change to be consistent with the title change of Subsection ISTD 28 ISTD-1600 Revised Clarification: Added repair and to better reflect the title of ISTD-1600, Snubber Modification and Replacement 29 ISTD-1800 Revised Clarification: Language changed to better clarify when the evaluation requirements of ISTD-1800 apply. The evaluation requirement itself is unchanged.
29 ISTD-2000 (1) Definition of service life revised Clarification: Changed an item to a snubber and added clarification at its installed location.
(2) Definition of service life monitoring Clarification: New definition to better added describe the overall intent of service life monitoring required by ISTD-6200. Note that the requirements of ISTD-6200 have not changed.
30 ISTD-3240 Revised Clarification: Added language to clarify intent which includes newly identified design difference.
30 ISTD-4110 Revised Clarification: Minor change in language to replace the term supported system with affected systems, structures, or components to reduce confusing terms 33 ISTD-5240 Revised Technical: Relaxed timeframe for start of pre-outage activities from 60 days to 92 days.
While this is technically a relaxation in requirements, it is intended to provide flexibility for implementation of ISTD requirements. It doesnt change the actual testing or examination requirements.
35 ISTD-5331 Revised Editorial: Revised formula by replacing mathematical expressions with defined terms, then defining those terms using the previous mathematical expressions. Overall, there was no change to the math or results - the only thing that change is how it is written.
37 ISTD-6000 (1) Title revised Administrative: Revised title to better represent the subordinate requirements (2) ISTD-6100 and ISTD-6200 revised in Clarification: Revised language to better their entirety reflect original intent. While the language was changed considerably, the revised language doesnt add or remove requirements that werent originally intended to be performed 38 ISTD-9500 Added Technical: Added new requirement for maintaining service life records. While this changed is identified as Technical it only adds administrative requirements for record keeping. It doesnt change actual test or examination requirements.
xxiv
Reprinted from ASME OM-2020, by permission of The American Society of Mechanical Engineers. All rights reserved.
42 ISTE-4160 Revised Technical: Add a new requirement to provide a basis if the PRA model is not updated to address added risk from a failure of a component that is not modeled. This is a documentation requirement which does not affect testing or examination requirements.
Therefore, it is inconsequential from a safety benefit perspective.
44 ISTE-5121 Subparagraphs (b) and (c) revised Correction: Changed wording for the comprehensive test to reflect the change in flow rate which was first made to ISTB in the 2017 Edition, but the change in flow rate terms was inadvertently missed for ISTE in the 2017 Edition. This change corrects that error.
44 ISTE-5122 Subparagraph (b) revised Correction: Changed wording for the comprehensive test to reflect the change in flow rate which was first made to ISTB in the 2017 Edition, but the change in flow rate terms was inadvertently missed for ISTE in the 2017 Edition. This change corrects that error.
45 ISTE-5220 Revised Administrative: Simplified language to refer to ISTC for check valve testing rather than specific sections or Appendix II. The general reference to ISTC is more correct and covers all scenarios for check valve testing.
46 ISTE-6110 Revised Clarification: Added the word testable to clarify those attributes which are selected for monitoring. This change clarifies the original intent.
47 ISTF-2000 Definition of baseline test added Administrative: Part of the larger change from preservice test to baseline test 47 ISTF-3100 (1) First paragraph revised Administrative: Part of the larger change from preservice test to baseline test (2) Subparagraph (d) deleted Administrative: Eliminated differentiation between positive displacement pumps and reciprocation pumps since both are positive displacement pumps. The deleted paragraph referenced the same paragraph that is also referenced in the remaining requirement for positive displacement pumps.
48 Table ISTF-3000-1 Second column head revised Editorial: No discernable change other than format.
48 ISTF-3310 Revised in its entirety Clarification and Administrative: ISTF-3310 was restructured to split requirement into two new subparagraphs ISTF-3311 and ISTF-331. These new subparagraphs clarify when a baseline test (previously designated as a preservice test) is required. The new language reflects the original intent of when a preservice test was required and is consistent with how the industry has implemented the previous editions of OM with respect to preservice testing. This clarification is part of the larger change of preservice test to baseline test 49 Table ISTF-3510-1 Second column head revised Administrative: Part of the larger change from preservice test to baseline test 50 ISTF-5000 Revised Administrative: Part of the larger change from preservice test to baseline test 50 ISTF-5110 Title revised Administrative: Part of the larger change from preservice test to baseline test xxiv
Reprinted from ASME OM-2020, by permission of The American Society of Mechanical Engineers. All rights reserved.
51 ISTF-5210 Title revised Administrative: Part of the larger change from preservice test to baseline test 52 ISTF-5310 Title revised Administrative: Part of the larger change from preservice test to baseline test 52 ISTF-6000 First paragraph added Clarification: Added language to better differentiate when systematic error (ISTF-6300) can be used versus corrective action (ISTF-6200) 55 I-1200 First paragraph revised Correction: Corrected reference to ASME PTC 25 by elimination mention of Mandatory Appendix I.
56 I-1320 Subparagraphs (a) and (c)(3) revised Administrative: Change related to integration of Code Case OMN-25 into Mandatory Appendix I 56 I-1350 Subparagraph (a)(3) revised Administrative: Change related to integration of Code Case OMN-25 into Mandatory Appendix I 58 I-3220 Revised Technical: Removed the requirement to determine set-pressure when installed in the system and raising system pressure up to the setpoint. The requirement was simplified to just require set pressure testing within 6 months. This change was made to address difficulties in performing set pressure testing using the installed system pressure which have been subject of previous requests for alternatives. Although this is a technical change with respect to the use of the installed system, it does not change the requirement to perform set pressure testing.
65 II-4000 Subparagraph (b)(5) revised Editorial: Revision to incorporate Errata from 2017 Edition (reference OM Record 16-424) 68 III-3500 Subparagraph (a) revised Clarification: Added language to clarify the original intent that each valve in the group is required to be tested.
78 Division 1, Mandatory Deleted Administrative: Part of the change which Appendix V integrated the requirements from Mandatory Appendix V from the 2017 Edition into Subsection ISTB and deleted Appendix V Reprinted from ASME OM-2020, by permission of The American Society of Mechanical Engineers. All rights reserved.
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