1 ISTOG QUESTIONS 2008

2

3 ISTOG QUESTIONS IST Program Plan Submittals to Regulators: Prior to OM-2001, and going back to ASME Section XI, there was an item under the "grocery list" of Owner's Responsibilities (e.g., OM-1998, ISTA-1500(c)) listing "preparation of plans and schedules and filing of these plans with enforcement and regulatory authorities having jurisdiction at the plant site". Under this format, and based on the expressed wishes of the NRC that they were really only interested in reviewing the relief requests and would request additional information as necessary, a formal submittal of the Program Plan document was generally not done without such a request.

4 ISTOG QUESTIONS IST Program Plan Submittals to Regulators: In the 2001 Edition of the OM Code, Paragraph ISTA 3200(a) was added, which states: "IST Plans shall be filed with the regulatory authorities having jurisdiction at the plant site." Since 10 CFR 50.55a requires compliance with the Code, and since there are no limitations or modifications regarding this paragraph in 10 CFR 50.55a(b)(3), I understand this to mean that plants with IST Programs meeting the 2001 Edition of the OM Code or later are required to file their Program Plans with the regulatory authorities (i.e., the NRC and in some cases other regulatory agencies, such as IEMA). It would appear that the alternative would be to submit a relief request, which would be ridiculous.

5 ISTOG QUESTIONS IST Program Plan Submittals to Regulators: If your IST Program has been updated to the OM-2001 Code or later, please answer the following questions: Q1: Have you formally submitted your Program Plan document to the NRC? Q2: If so, within how much time after the start of your interval? On what basis? Q3: What is your policy on submitting revisions during the interval? Q4: Have you received any feedback from the NRC indicating their expectations with respect to this issue? If so, please describe.

6 ISTOG QUESTIONS Data Averaging: OE27285 [ 8/13/2008 ]- Improper Averaging of Hydraulic Pump Data for Comparison to Acceptance Criteria Averaging of multiple data points for differential pressure and flow for comparison to the acceptance criteria to determine pump operability during Inservice pump surveillance testing is not in compliance with the ASME OM code. The intent is that only one set of data is compared to acceptance criteria. The cause is misinterpreting ASME code requirements. The [NRC CDBI ] inspector contacted the office of Nuclear Reactor Regulation Regarding this matter, who posed the concern to the code committee and determined that averaging of several pump readings for the purpose of comparison to the acceptance criteria is not in compliance with the ASME OM Code and that a single reading needs to be compared to the acceptance criteria.

7 ISTOG QUESTIONS Data Averaging: ISTB-3510 (d) discussion on fluctuations states that "symmetrical damping devices or averaging techniques may be used to reduce instrument fluctuations". We use an averaging fluke to monitor the output of DP cells on a few pumps, where the instantaneous readings are really jumping around. It is set to record 60 seconds (120 total inputs based on the 500mSec sample rate) and then display the average VDC value. That value is used to derive DP. Q1: DO OTHERS USE THIS OR SIMILAR METHODOLOGY?

8 ISTOG QUESTIONS Data Averaging: 2. Data Averaging: The OE describes inappropriate use of averaging related to DP and Flow, but no mention of vibration is made. Q2: Do you believe that a similar scenario involving averaging of vibration readings would also be considered a non-compliance? Q3: Given what is stated in ISTB-3510, do you believe that this was truly a case of non-compliance?

9 ISTOG QUESTIONS Double Frequency for Group B Pumps: I have a Group B pump that is tested quarterly for which we obtain vibrations "for information only" (no ASME limits assigned), and the PIH vibrations were >0.325 in/sec. IF it was a Group A pump I would double the test frequency to every 6 weeks (assumes vibrations are in alert range). Q1: Would I also double the comprehensive pump test (CPT) frequency to annually? IF it was the comprehensive test (CPT), I would double the test frequency to annually (assumes vibrations are in alert range).

10 ISTOG QUESTIONS Double Frequency for Group B Pumps: Q2: However, since this was a Group B test, I don't believe I have to double the test frequency to every 6 weeks (even though I do gather vibrations for information only), but should I double the test frequency of the CPT even though I never performed it, but only because I know that vibrations will probably be high and in the alert range when I do perform it next summer (2009)? The Group B test and CPT are performed at the same flow rate have the same vibration limits.

11 ISTOG QUESTIONS Component Risk Evaluation: In Reg. Guide and in App. III there are statements saying the following: "When extending exercise test intervals for high risk MOVs beyond a quarterly frequency, licensees must ensure that the potential increase in Core Damage Frequency (CDF) and risk associated with the extension is small and consistent with the intent of the Commission’s Safety Goal Policy Statement."

12 ISTOG QUESTIONS Component Risk Evaluation: Most of the MOVs classified for risk as "High" in your GL Programs are probably modeled in your PSA Program such that their individual contribution to CDF is quantified. However, that calculation is based on complete failure of the component to function. Our PSA experts do not have the ability to actually calculate the "increase" in risk associated with extending a test interval.

13 ISTOG QUESTIONS Component Risk Evaluation: In theory, if the testing extension is still within the standard PM intervals there is zero increase in failure risk. The testing itself does not serve to maintain the component health. The industry has not seen any evidence of reliability differential between MOVs stroked once a quarter vs. once a cycle, although this might be a plausible issue for AOVs and SOVs. I think what the NRC is after is an understanding that a component could be in a failed state and undetected for a longer period of time, but that is quite different from something having an actual effect on failure probability.

14 ISTOG QUESTIONS Component Risk Evaluation: If you choose to assume failure as a consequence of the test interval extension In order to quantify the CDF impact in an evaluation then you will most likely get numbers that are quite small and easily justified. However, it opens the door to questions about common mode failure. You would likely need to group all of the applicable MOVs (being extended) and calculate composite CDF impact, and those numbers may be significantly higher. I don't see this as limited to OMN-1 / App. III. The terminology being used can be implied as applicable to any CSJ or ROJ. I think we are going to have to work on this with the NRC and establish some sort of standard basis / assumptions. Opinions? Alternate interpretations?

15 ISTOG QUESTIONS Multiple Valves – One Control Switch: I have 3 sets of solenoid valves, 5 solenoids each on 2 switches and 2 solenoids on another switch, with all solenoids having their own individual indicating lights. When preconditioning became an issue I revised the procedures to manipulate the switches only one time, recording the stroke time of the slowest valve as the official stroke time for all associated valves. In doing so I never submitted a relief, believing that a relief is not required based on satisfying the acceptance criteria for rapid acting valves. Q1: Does anyone have a similar configuration, and if so, do you believe relief Is required?

16 ISTOG QUESTIONS Test Frequency for Initial Comprehensive Pump Test: Q1: When performing the initial comprehensive pump test in a new IST test interval, does SR (25% grace period) apply? Q2: Specifically, am I allowed 2 years plus 25% to perform my initial comprehensive pump test from the start of my new test interval or is only 2 years from the start of my interval allowed?

17 ISTOG QUESTIONS-2008 NRC Questions/Feedback to ISTOG?