ML21003A009
| ML21003A009 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 01/12/2021 |
| From: | Nuclear Energy Institute |
| To: | Douglas Bollock NRC/NRR/DRO |
| Douglas Bollock, NRR/DRO/IRIB, 415-6609 | |
| Shared Package | |
| ML21003A007 | List: |
| References | |
| Download: ML21003A009 (8) | |
Text
Compliance with 10 CFR 50.55a(b)(3)(xi)
OM Condition: Valve Position Indication
10 CFR 50.55a(b)(3)(xi) OM Condition Valve Position Indication. When implementing paragraph ISTC-3700, "Position Verification Testing," in the ASME OM Code, 2012 Edition through the latest edition and addenda of the ASME OM Code incorporated by reference in paragraph (a)(1)(iv) of this section, licensees shall verify that valve operation is accurately indicated by supplementing valve position indicating lights with other indications, such as flow meters or other suitable instrumentation to provide assurance of proper obturator position for valves with remote position indication within the scope of Subsection ISTC including its mandatory appendices and their verification methods and frequencies.
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OM Code Purpose and ISTC-3700 OM Code assess operational readiness of components AFTER they have met all requirements of the construction code (reference OM Code, ISTA-1100 and ISTA-1200). Specifically, periodic Inservice Testing requirements of OM Code commence after a component is known to be operating acceptably (e.g., meets design requirements). OM Code acceptance criteria for most Inservice Testing activities establish a range of acceptable performance using baseline data obtained during construction code testing, preservice testing, or post-modification/ maintenance testing. All subsequent periodic Inservice Testing data is compared to this acceptable range of performance. This approach monitors component performance degradation and ensure corrective actions are taken before the component degrades to a point where it can no longer perform its safety function. With few exceptions (e.g.,
MOVs), the intent of the OM Code is not designed to perform design basis testing because it is a component testing code and not a system testing code.
ISTC-3700 - Position Verification Testing Valves with remote position indicators shall be observed locally at least once every 2 yr. to verify that valve operation is accurately indicated. Where practicable, this local observation should be supplemented by other indications such as use of flow meters or other suitable instrumentation to verify obturator position. These observations need not be concurrent. Where local observation is not possible, other indications shall be used for verification of valve operation.
Position verification for active MOVs shall be tested in accordance with Mandatory Appendix III of this Division.
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Problem Statement:
NRC and Licensees have a different understanding regarding the implementation of ISTC-3700 and 10 CFR 50.55a(b)(3)(xi)
ASME OM Condition Valve Position Indication as it applies to:
- 1. When compliance with 10 CFR 50.55a(b)(3)(xi) is required and the frequency of the supplemental testing
- 2. The application of concurrent testing
- 3. Whether the condition does or does not add new testing requirements
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Compliance Timing NRC Position Licensee Position NRC contends compliance is tied to Compliance with 50.55a(b)(3)(xi) is required completion of actions to comply with ISTC- within 2 years (24 months) of the start of the interval that incorporates the 2012 Edition of 3700 that started in the previous 10 year OM Code or later interval The condition itself, states When 10 CFR 50.55a(b)(3)(xi) is a condition on implementing paragraph ISTC-3700, "Position Verification Testing," in the ASME OM Code, existing OM Code, ISTC-3700, therefore 2012 Edition through the latest edition compliance with the condition is required concurrent the existing periodic scheduling of The NRC has revised this condition to ISTC-3700 indicate that it is associated with implementation of the 2012 Edition of the ASME OM Code. As such, nuclear power plant licensees will be required to implement the condition when adopting the 2012 Edition of the ASME OM Code as their code of record for the 120-month IST interval.
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Concurrent Testing NRC Position Licensee Position 10 CFR 50.55a(b)(3)(xi) and
- ISTC-3700 states, These observations NUREG-1482 do not specify that need not be concurrent, providing the ability to comply with supplemental the supplemental position observation requirement imposed by verification observation(s) be the condition separately from the local stem observation concurrent with the valve indicating lights testing, nor does the
- Implementation of ISTC-3700 is dynamic and controlled by site specific condition prohibit the ISTC-3700 testing procedures which are provision that the observations scheduled to comply with the 2 year frequency requirement need not be concurrent.
- In many cases, local observation of stem travel for compliance with ISTC-3700 will be accomplished in different procedures and different plant configurations/alignments than the supplemental position verification activities for compliance with 10 CFR 50.55a(b)(3)(xi)
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New Testing Requirement NRC Position Licensee Position
- 10 CFR 50.55a(b)(3)(xi) does not add
- 10 CFR 50.55a(b)(3)(xi) adds new test new test requirements requirements that are not included in ISTC-3700 by the phrase where
- Final Rulemaking (Federal Register, Vol practicable 82, No 136, Tuesday, July 18, 2017),
- The condition changed the language of Section IX, Backfitting and Issue ISTC-3700 regarding supplemental position verification from a should to Finality, regarding addition of 10 CFR a shall which equates to a new 50.55a(b)(3)(xi) states, this requirement and contradicts OM condition emphasizes the OM Code Interpretation 12-01 (Record 11-913) requirements for valve position
- Public comments on the draft indication and is not a change to those rulemaking from Utilities, ASME, and requirements. As such, this condition is IST Owners Group all noted 10CFR50.55a(b)(3)(xi) was a new not a backfit requirement adding significant changes
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Conclusions Compliance with 10 CFR 50.55a(b)(3)(xi) OM Condition: Valve Position Indication, is required upon licensee adoption of the 2012 Edition of the ASME OM Code as their code of record for the 120-month IST interval 10 CFR 50.55a(b)(3)(xi) nor NUREG-1482 require concurrent testing and ISTC-3700 clearly states that the observations of valve indicating lights and the supplemental position indication need not be concurrent 10 CFR 50.55a(b)(3)(xi) imposed new generic requirements that required modification of procedures to operate plants, therefore meeting the definition of backfitting (10 CFR 50.109(a)(1))
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